EPA’s 2026 Unified Agenda Includes TSCA Rulemakings

On July 3, 2026, the Office of Management and Budget (OMB) published the Trump Administration’s 2026 Unified Agenda. The U.S. Environmental Protection Agency’s (EPA) Unified Agenda includes the following rulemakings under the Toxic Substances Control Act (TSCA):

• Cyclic Aliphatic Bromide Cluster (HBCD); Regulation under TSCA: According to EPA, this rulemaking will address the unreasonable risk of injury to health presented by HBCD. EPA states that TSCA Section 6(a) requires that EPA, when it determines in a TSCA risk evaluation that a chemical presents an unreasonable risk of injury to health or the environment, under the conditions of use (COU), apply one or more requirements under TSCA Section 6(a) by rule to the extent necessary so the chemical substance no longer presents an unreasonable risk. EPA intends to publish a notice of proposed rulemaking (NPRM) in September 2026 and a final rule in July 2027. More information on EPA’s evaluation of HBCD is available in our June 30, 2022, memorandum.

• TSCA Risk Management Rules and Critical Uses for Federal Agencies: EPA states that it is developing a proposed rule under TSCA that would allow federal agencies and/or their contractors to temporarily continue using certain chemical substances under certain COUs (e.g., methylene chloride) when necessary to prevent significant disruptions to the national economy, national security, or critical infrastructure. EPA notes that under TSCA Section 6(g), “those uses must be time-limited with the possibility of future extensions and the Agency must make public an analysis regarding the need for the continued use and a statement describing how that analysis was taken into account.” EPA intends to present such information with the planned rulemaking. EPA intends to publish an NPRM in December 2026.

• Tris(2-chloroethyl) Phosphate (TCEP); Regulation under TSCA: This rulemaking will address the unreasonable risk of injury to health and the environment from TCEP. EPA plans to publish an NPRM in December 2026 and a final rule in December 2027. More information on EPA’s final risk evaluation of TCEP is available in our October 2, 2024, memorandum.

• Asbestos Part 2: Legacy Uses and Associated Disposals of Asbestos; Regulation under TSCA: EPA states that this rulemaking will address the unreasonable risk of injury to health from asbestos, as a chemical substance, identified by EPA in a risk evaluation completed under TSCA Section 6(b) that focused on legacy uses of asbestos and associated disposals, asbestos-containing talc, and types of asbestos fibers other than chrysotile. EPA notes that it has bifurcated the risk management of asbestos into two parts; Part 1: Chrysotile Asbestos and Part 2: Legacy Uses and Associated Disposals of Asbestos. EPA notes that it completed its Part 1 risk evaluation and rulemaking activities for Chrysotile Asbestos. EPA intends to publish an NPRM for Part 2 in February 2027 and a final rule in March 2028. More information is available in our July 2, 2026, memorandum.

• Formaldehyde; Regulation under TSCA: This rulemaking will address the unreasonable risk of injury to health from formaldehyde. EPA intends to publish an NPRM in August 2026 and a final rule in August 2027. More information on EPA’s risk evaluation of formaldehyde is available in our December 8, 2025, memorandum.

• Diisodecyl Phthalate (DIDP); Regulation under TSCA: This rulemaking will address the unreasonable risk of injury to health presented by DIDP. EPA intends to publish an NPRM in July 2026 and a final rule in July 2027. More information on EPA’s risk evaluation for DIDP is available in our May 24, 2024, memorandum.

• Diisononyl Phthalate (DINP); Regulation under TSCA: This rulemaking will address the unreasonable risk of injury to health presented by DINP. EPA intends to publish an NPRM in November 2026 and a final rule in October 2027. More information on EPA’s final risk evaluation for DINP is available in our January 17, 2025, memorandum.

• Certain Existing Chemicals; Request to Submit Unpublished Health and Safety Data under TSCA; Revision to Regulation: EPA is proposing to revise the final rule published on December 13, 2024, for Health and Safety Reporting Rule under TSCA to require manufacturers (including importers) of the sixteen chemical substances identified in the rulemaking to submit copies and lists of certain unpublished health and safety studies to EPA. According to EPA, health and safety studies sought by this action will inform EPA actions in carrying out its responsibilities pursuant to TSCA, including prioritization, risk evaluation, and risk management. EPA intends to publish an NPRM in July 2026 and a final rule in January 2028. More information on EPA’s December 13, 2024, final rule is available in our December 23, 2024, memorandum.

• Multiple Compliance Date Extensions for Regulation under TSCA: EPA is proposing to extend the compliance dates for certain restrictions of TSCA Section 6(a) final rules addressing the unreasonable risk presented by methylene chloride, trichloroethylene (TCE), perchloroethylene (PCE), and carbon tetrachloride (CTC). EPA states that it is proposing to extend these compliance dates for certain activities to avoid disruption of important functions of various entities potentially affected by the 2024 final rules. EPA intends to publish an NPRM in July 2026 and a final rule in October 2026. More information on the compliance dates for PCE and CTC is available in our March 25, 2026, memorandum.

• PCE; Amendments to Regulation under TSCA: EPA states that it is considering amendments to certain aspects of the December 2024 TSCA Section 6(a) rule addressing the unreasonable risk presented by PCE. Following a risk evaluation carried out under the authority of TSCA Section 6(b), EPA determined that PCE presents an unreasonable risk of injury to health. EPA is initiating a rulemaking to amend previously promulgated provisions to address this unreasonable risk as appropriate. EPA will solicit public comment on potential amendments through an NPRM. EPA intends to publish an NPRM in July 2026 and a final rule in July 2027. More information on EPA’s reconsideration of the PCE rule is available in our August 1, 2025, blog item.

• Laboratory Requirements under TSCA: EPA states that it is considering a TSCA Section 6(a) rule to address the unreasonable risk presented by laboratory use of chemicals that have undergone a TSCA risk evaluation. According to EPA, laboratories perform important functions such as conducting environmental monitoring needed for cleanup sites and wastewater treatment. EPA is initiating a rulemaking so that the requirements for laboratories are consistent for all chemicals evaluated under TSCA Section 6. EPA notes that it intends to consider the existing U.S. Occupational Safety and Health Administration (OSHA) standards, including OSHA’s laboratory standard, during the development of this rule to avoid conflicting or duplicative regulation. EPA will solicit public comment through an NPRM. EPA intends to publish an NPRM in October 2026 and a final rule in August 2027.

• TCE; Amendments to Regulation under TSCA: EPA is considering amendments to certain aspects of the December 2024 TSCA Section 6(a) rule addressing the unreasonable risk presented by TCE. EPA states that it is initiating a rulemaking to amend previously promulgated provisions to address this unreasonable risk as appropriate. EPA will solicit public comment on potential amendments through an NPRM. EPA intends to publish an NPRM in July 2026 and a final rule in July 2027. More information on EPA’s final risk management rule for TCE is available in our January 13, 2025, memorandum.

• CTC; Amendments to Regulation under TSCA: EPA is considering amendments to certain aspects of the December 2024 TSCA Section 6(a) rule addressing the unreasonable risk presented by CTC. EPA states that it is initiating a rulemaking to amend previously promulgated provisions to address this unreasonable risk. EPA will solicit public comment on potential amendments through an NPRM. EPA intends to publish an NPRM in July 2026 and a final rule in September 2027. More information on EPA’s final risk management rule for CTC is available in our October 15, 2025, blog item.

• Extension for TSCA and TSCA Section 8(d) Health and Safety Data Reporting: EPA is proposing to extend the reporting deadline for the TSCA Health and Safety Data Reporting Rule. EPA is seeking public comment on the proposed action, including any considerations or concerns that stakeholders may have regarding the proposed extension of the reporting deadline. EPA states that the proposed extension is intended to delay the compliance burdens associated with the one-time reporting rule while EPA considers potential modifications to the regulation and to make consequent changes to the electronic reporting application in EPA’s Central Data Exchange (CDX) necessary to collect the required information. EPA intends to publish an NPRM and a final rule in July 2026. More information on EPA’s previous extension is available in our June 2, 2026, blog item.

• 1-Bromopropane (1-BP); Regulation under TSCA: EPA is developing a final rule under TSCA Section 6(a) to address unreasonable risk of injury to health presented by 1-BP. EPA issued a proposed rule on August 8, 2024. According to EPA, 1-BP “is a widely used solvent in a variety of occupational and consumer applications, including vapor degreasing, aerosol degreasing, adhesives and sealants, and in insulation.” EPA states that it determined that 1-BP presents an unreasonable risk of injury to health due to the significant adverse health effects associated with exposure to 1-BP and that it is developing a final rule to address the identified unreasonable risk presented by 1-BP under its COUs. EPA proposed requirements to, among other things, prevent consumer access to the chemical, restrict the industrial and commercial use of the chemical while also allowing for a reasonable transition period where an industrial and commercial use of the chemical is being prohibited, and protect workers from the unreasonable risk of 1-BP while on the job. EPA notes that its development of the rule incorporates significant stakeholder outreach and public participation, including public webinars and more than 40 external meetings, federalism and Tribal consultations, and consultations with potentially affected small entities by a Small Businesses Advocacy Review Panel. According to EPA, it engaged in discussions with industry, non-governmental organizations, other government agencies, technical experts and users of 1-BP, and the general public to hear from users, academics, manufacturers, and members of the public health community about practices related to commercial uses of 1-BP. EPA intends to publish a final rule in August 2026. More information on EPA’s proposed risk management rule is available in our August 13, 2024, memorandum.

• N-Methylpyrrolidone (NMP); Regulation under TSCA: EPA is developing a final rule under TSCA to address the unreasonable risk of injury to human health presented by NMP. EPA issued a proposed rule on June 14, 2024. According to EPA, “NMP is a widely used solvent in a variety of industrial, commercial, and consumer applications including the manufacture and production of electronics such as semiconductors, polymers, petrochemical products, paints and coatings, and paint and coating removers.” EPA determined that NMP presents an unreasonable risk of injury to health due to the significant adverse health effects associated with exposure to NMP, including developmental post-implantation fetal loss from short-term exposure and reduced fertility and fecundity from long-term exposure. EPA states that it proposed requirements to: prohibit the manufacture (including import), processing, and distribution in commerce and use of NMP in several occupational COUs; require worker protections through an NMP workplace chemical protection program (WCPP) or prescriptive controls (including concentration limits) for most of the occupational COUs; require concentration limits on a consumer product; regulate certain consumer products to prevent commercial use; and establish recordkeeping, labeling, and downstream notification requirements. EPA notes that its development of this rule incorporated significant stakeholder outreach and public participation. EPA intends to publish a final rule in July 2026. More information on EPA’s proposed risk management rule is available in our June 21, 2024, memorandum.

• C.I. Pigment Violet 29 (PV29); Regulation under TSCA: On January 14, 2025, EPA proposed to address the unreasonable risk of injury to human health presented by PV29 under its COUs as documented in EPA’s January 2021 Risk Evaluation for PV29 and the September 2022 Revised Risk Determination for PV29 prepared under TSCA. According to EPA, PV29 is a perylene pigment that is reddish-purple in color and is currently manufactured as a powder, slurry, or paste. It is used to dye products, such as plastics and paints, and is commonly used in automobile paints and coatings. EPA states that it determined that dry powder PV29, but not PV29 already incorporated into a liquid mixture such as wet paint or ink, presents an unreasonable risk of injury to health due to the significant adverse health effects associated with inhalation exposure. To address the identified unreasonable risk, EPA proposed to require the use of assigned protection factor (APF) 50 respirators and equipment and area cleaning to address the risk from inhalation exposure to dry powder PV29 (also referred to as regulated PV29) for certain COUs where dry powder PV29 is expected to be present to protect workers from the unreasonable risk of PV29 during manufacturing and processing, certain industrial and commercial uses of the chemical, and disposal. EPA also proposed to establish recordkeeping and downstream notification requirements. EPA intends to publish a final rule in July 2026. More information on EPA’s proposed rule is available in our January 27, 2025, memorandum.

• Procedures for Chemical Risk Evaluation under TSCA: On September 23, 2025, EPA proposed to amend the procedural framework rule for conducting existing chemical risk evaluations under TSCA. According to EPA, when conducting an existing chemical risk evaluation under TSCA, EPA must determine whether a chemical substance presents an unreasonable risk of injury to health or the environment, without consideration of costs or non-risk factors, including unreasonable risk to a potentially exposed or susceptible subpopulation identified as relevant to the risk evaluation, under the COUs. EPA notes that in this action, it proposed to rescind or revise certain 2024 amendments to the procedural framework rule to effectuate the best reading of the statute and ensure that the procedural framework rule does not impede the timely completion of risk evaluations or impair the effective and efficient protection of health and the environment. After considering public comments, EPA intends to issue a final rule in July 2026. More information on EPA’s proposed amendments to the framework rule are available in our September 24, 2025, memorandum.

• Perfluoroalkyl and Polyfluoroalkyl Substances (PFAS) Data Reporting and Recordkeeping under TSCA; Revision to Regulation: EPA is considering a proposed rule to amend the TSCA regulation for reporting and recordkeeping requirements for PFAS. As promulgated in October 2023, the regulation requires manufacturers (including importers) of PFAS in any year between 2011 and 2022 to report certain data to EPA related to exposure and environmental and health effects. EPA states that it “plans to propose the incorporation of certain exemptions and other modifications to the scope of the reporting rule.” EPA intends to issue a final rule in July 2026. More information on EPA’s proposed rule is available in our November 13, 2025, memorandum.