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Environmental · U.S. Chemical Regulation · TSCA
Are Electronic Device Materials Regulated in the US?
Are Electronic Device Materials Regulated in the US?
An Explanation of TSCA (Toxic Substances Control Act)
Conclusion: TSCA is a US law regulating the manufacture, import, and use of chemicals, with reporting obligations and usage restrictions for specific substances.
TSCA (Toxic Substances Control Act) is a chemical substance management law supervised by the U.S. Environmental Protection Agency (EPA). Manufacturers involved in the export and procurement of electronic devices must sufficiently confirm whether regulated substances are included.
Cases where confirmation of components in resins, flame retardants, and additives is required
Plastics, paints, adhesives, and other materials used in electronic devices and cables contain many chemical substances such as flame retardants and plasticizers. Some of these are subject to usage restrictions and reporting obligations under TSCA.
Wire and Cable Sheathing/Insulation Materials
Confirmation of plasticizer and flame retardant components in PVC sheathing and flame-retardant compounds is required.
Plastic Parts such as Connectors and Casings
It is important to understand the types of flame retardants added to flame-retardant grade engineering plastics.
Adhesives, Paints, and Sealants
Chemical substances (such as TCE) contained in solvent-based products may be subject to TSCA Section 6 regulations.
TSCA Section 6 (Restriction of Hazardous Substances) — Main Regulated Substances
Based on scientific evidence, the EPA can impose usage restrictions and prohibitions on substances deemed to pose a "risk". Since 2021, the following chemical substances have been regulated under Section 6.
| Target Substance | Primary Use | Notes |
|---|---|---|
| RegulatedPIP (3:1) | Flame Retardant/Plasticizer | Sometimes used in plastic components and cable sheathing |
| RegulatedDecaBDE | Flame Retardant | Used for flame retardant treatment of plastic enclosures and circuit boards |
| RegulatedHBCD | Flame Retardant | Sometimes found in insulation materials such as expanded polystyrene |
| RegulatedTCE | Cleaning Agent | Used in cleaning processes for semiconductor manufacturing and metal processing |
If these substances are used, exports to the US market may be restricted or subject to prior reporting obligations.
Reporting Obligations to the EPA and Record Keeping
If regulated substances are contained in products, manufacturers and importers may have a reporting obligation to the EPA.
Even if a product is exempt, there are cases where it is necessary to retain records and certifications from the product design stage. Requests for certificates from business partners are also increasing.
Global Regulatory Compliance in conjunction with RoHS and REACH
Although TSCA is a US regulation, many substances overlap with other regional regulations such as RoHS (EU) and REACH (EU). For global product development, it is important to have a comprehensive understanding of environmental regulations in each region.
USA
TSCA
Manages the manufacture, import, and use of chemical substances. Section 6 restricts/prohibits the use of specific substances.
EU
RoHS
Restricts the use of certain hazardous substances (lead, mercury, cadmium, etc.) in electrical and electronic equipment.
EU
REACH
Registration, Evaluation, Authorisation, and Restriction of Chemicals. Obligation to disclose information on SVHC (Substances of Very High Concern).
Summary
What is TSCA
A chemical substance management law administered by the U.S. EPA. Regulates manufacturing, import, and use.
Section 6
Prohibits or restricts the use of specific substances such as PIP (3:1), DecaBDE, HBCD, and TCE.
Export procedures
May require confirmation of constituent components and reporting to the EPA, and submission of certificates.
Global compliance
Integrated management with international regulations such as REACH and RoHS is essential.
If you have any questions about identifying products or components that require TSCA compliance or investigating component content, please feel free to contact us.
Consultation on TSCA Compliance and Component Content Surveys
We provide comprehensive consultation on issuing certificates, chemSHERPA compliance, and global regulations.
