Processing (under TSCA)

Under TSCA § 3(13), processing means preparation of a chemical after manufacture for distribution: formulation, blending, incorporation into products. Processing prohibitions may have different dates than manufacturing or distribution prohibitions.

TSCA § 3(13); 40 CFR Part 751.

A company that blends PIP (3:1) into a product is processing, even if it did not manufacture or import the substance. PIP (3:1) processing prohibitions took effect October 2024 for many uses.

A formulator blending PIP (3:1) into flame retardant packages is processing. After October 2024, this is prohibited for most applications unless an exclusion applies.