EPA Issues 18-Month Extension on Use of Methylene Chloride by Laboratories. The Environmental Protection Agency has issued a final rule extending the compliance dates applicable to certain entities subject to the regulation of methylene chloride promulgated under the Toxic Substances Control Act (TSCA).
Specifically, EPA is finalizing an 18-month extension of the Workplace Chemical Protection Program (WCPP) and associated recordkeeping compliance dates for industrial or commercial laboratories that are not owned or operated by Federal agencies or contractors acting on behalf of the Federal government. Under this final rule, all non-Federal laboratories will share the same compliance dates with Federal and Federally contracted laboratories.
This final rule extends three compliance dates for non-Federally owned or operated industrial or commercial laboratories. For initial monitoring, the compliance date is extended from May 5, 2025, to November 9, 2026. For establishing regulated areas and ensuring compliance with the Existing Chemical Exposure Limit (ECEL), the compliance date is extended from August 1, 2025, to February 8, 2027. For ensuring the methods of compliance with EPA’s exposure limits and for developing and implementing an exposure control plan, the compliance date is extended from October 30, 2025, to May 10, 2027.
This final rule does not extend any of the compliance dates on prohibiting the sale of products containing methylene chloride, however.
See the timetable on page 25 of this EPA guidance document.
February 3, 2025— After February 3, 2025, all persons are prohibited from distributing in commerce (including making available) methylene chloride, including any methylene chloride-containing products, to retailers for any use. In other words, distributors cannot sell methylene chloride products to any retailers after February 3, 2025.
May 5, 2025— After May 5, 2025, all retailers are prohibited from distributing in commerce (including making available) methylene chloride, including any methylene chloride-containing products, for any use. This means that retailers cannot distribute methylene chloride products to any customer, including to commercial users, after May 5, 2025.
January 28, 2026— After January 28, 2026, all persons are prohibited from distributing in commerce (including making available) methylene chloride, including any methylene chloride-containing products, except for conditions of use that will continue under the Workplace Chemical Protection Program.
The definition of a “retailer” is found on page 34 of the guidance: “Any person or business entity that distributes or makes available products to consumers, including through e-commerce internet sales or distribution. Any distributor with at least one consumer end user customer is considered a retailer. A person who distributes in commerce or makes available a chemical substance or mixture solely to commercial or industrial end users or solely to commercial or industrial businesses is not considered a retailer.”
Thus, if you sell to at least one consumer user, you are a retailer and the May 5, 2025 deadline applied to you.
If you sell solely to commercial or industrial end users, the January 28, 2026 deadline applies to you.
But if you sell to any retailers, the February 3, 2025 deadline applied to you.
Rick Schweitzer
GAWDA General Counsel
November 14, 2025
(703) 946-2548
