Distribution in Commerce

Under TSCA, distribution in commerce means to sell, introduce for sale, or hold after introduction into commerce. Includes import. Many PBT prohibitions target distribution—meaning companies cannot sell or import PBT-containing products after the prohibition date.

TSCA § 3(5); 40 CFR Part 751, Subpart E.

PIP (3:1)-containing articles can be distributed until October 31, 2026 (with exclusions). Import is included. Companies holding PBT inventory must track distinct processing vs. distribution prohibition dates.

A distributor holds PIP (3:1) hydraulic fluid inventory. Distribution is allowed until the applicable date; after that, remaining inventory cannot be sold.