Phase-In Prohibition

A time-limited transition period before a PBT prohibition takes full effect. PIP (3:1) timelines: 7 years (consumer electronics replacement), 10 years (manufacturing equipment), 15 years (new motor vehicle parts, aerospace lubricants), 25 years (service life replacement), 30 years (replacement motor vehicle parts).

40 CFR § 751.407(a)(2); EPA Final Rule (November 2024).

Companies must identify their specific phase-in, document reliance, calculate the prohibition date, and develop substitution plans. Unlike permanent exclusions, phase-ins have definite end dates.

An aerospace lubricant manufacturer has 15 years to transition from PIP (3:1). R&D on alternatives begins immediately.