CAS 100-21-0 · TSCA · United States of America

Purified terephthalic acid under TSCA

C8H6O4 · 精对苯二甲酸

Status: Listed. Purified terephthalic acid is on the TSCA Inventory as a grandfathered pre-1979 substance and is currently listed as TSCA Active. No PMN is required. PTA is NOT on the TRI Section 313 reporting list (TRI lists isophthalic acid and certain phthalates but not PTA itself). No DEA scheduling, no EPA RMP threshold listing. Section 301 List 3 25% additional duty applies to Chinese-origin PTA (HS 291736).

The US PTA lane is regulatorily clean: TSCA-listed, no DEA scheduling, no RMP, no Prop 65, no TRI HAP listing, no current AD/CVD case. The dominant practitioner-facing compliance work is Section 301 List 3 25% additional duty pricing. The 2014 Investigation A-570-970 (filed by domestic producers, did not result in active orders; verify case number against https://www.usitc.gov/ before relying) is precedent that periodic re-petitions are realistic; petition history should be monitored before invoicing volume contracts. US PET-resin demand (Coca-Cola, PepsiCo, Niagara Bottling, Mountain Valley) is structural; US is net-importer of PTA. The structural commercial story is the gradual rPET-content shift driven by state-level recycled-content laws (California AB 793, Washington 5022, New Jersey A4676) which mirror the EU Single-Use Plastics rPET target trend.

Listing and threshold

Substance Purified terephthalic acid (CAS 100-21-0), C8H6O4
Regime US Toxic Substances Control Act (TSCA), administered by EPA
Jurisdiction United States of America
Status Listed
Tonnage threshold CDR (Chemical Data Reporting) threshold: 25,000 lb (11,340 kg) manufactured or imported per site per year triggers reporting in the next CDR cycle

Classifications under this regime

  • NOT subject to TSCA Section 4 test rule
  • NOT currently subject to TSCA Section 6 unreasonable-risk evaluation
  • NOT on the TSCA Section 5(a)(2) Significant New Use Rule list
  • OSHA Hazard Communication Standard (HCS, 29 CFR 1910.1200): GHS H319 (eye irritation), H335 (respiratory irritation)
  • No substance-specific OSHA PEL; dust falls under the PNOR / nuisance-dust category at 29 CFR 1910.1000 Table Z-1 (PEL 15 mg/m³ total dust, 5 mg/m³ respirable; verify against https://www.osha.gov/annotated-pels/table-z-1)
  • NOT on EPA RMP threshold list
  • NOT on DEA List I or List II
  • NOT on California Proposition 65 list (verify against OEHHA https://oehha.ca.gov/proposition-65/proposition-65-list before relying on negative listing)
  • NOT on TRI Section 313 reporting list
  • FDA 21 CFR 177.1630 approves PET resin (with PTA monomer) for food-contact applications

Restrictions and conditions of use

  • No TSCA-specific use restrictions for PTA
  • OSHA-compliant SDS and workplace HazCom training required
  • Section 301 List 3 25% additional duty applies to Chinese-origin PTA (HS 291736); structural cost layer that must be priced into every Chinese-origin US lane invoice
  • NO active US AD/CVD case on Chinese-origin PTA currently (verify against https://access.trade.gov/ before invoicing). Department of Commerce Investigation A-570-970 was filed in 2014 by domestic producers but did not result in active AD/CVD orders (verify case number and history against https://www.usitc.gov/ before relying); periodic re-petitions are filed by domestic producers (Indorama Ventures USA, FlintHills Resources, BP Amoco)
  • FDA 21 CFR 177.1630 sets PET resin (with PTA monomer) compositional requirements for food-contact applications; PTA monomer residue limits apply at the resin specification level, not PTA shipment level

Importer obligations

TSCA is a self-certification regime: importers attest at customs entry that the substance is on the TSCA Inventory. The TSCA Section 13 Import Certification statement is filed via the customs broker on the entry summary (CBP Form 7501). For PTA specifically, the practitioner-facing layer is Section 301 List 3 25% additional duty pricing. NO active AD/CVD currently but periodic re-petitions are filed; petition history should be monitored before invoicing volume contracts. Workplace handling SDS drives OSHA HazCom training for handling facilities.

Required documents

  • TSCA Section 13 Import Certification statement on customs entry
  • OSHA-compliant SDS (Safety Data Sheet) in 16-section GHS format reflecting H319 + H335 classification
  • CDR filing every 4 years if site exceeds 25,000 lb/yr threshold (next cycle 2026)
  • FDA 21 CFR 177.1630 compliance documentation where PET resin downstream is food-contact (downstream-PET-resin obligation, not PTA monomer obligation)

Common compliance traps

The pitfalls that have bitten importers on this lane in the past. None of these is theoretical.

  • Section 301 List 3 25% additional duty applies to Chinese-origin PTA (HS 291736); structural cost layer
  • No active US AD/CVD on PTA currently but the 2014 Investigation A-570-970 is precedent that periodic re-petitions are filed by domestic producers (verify case number and current re-petition status against https://www.usitc.gov/ and https://access.trade.gov/); monitor Department of Commerce filings
  • US is structurally net-importer of PTA (despite domestic producer presence at FlintHills Resources, Indorama Ventures USA, BP Amoco) because domestic PET-resin demand exceeds domestic PTA capacity
  • OSHA HazCom training required for handling facilities; bag-handling and pneumatic-conveyance loading points are dust-exposure focal areas
  • No DEA scheduling, no EPA RMP, no Prop 65, no TRI Section 313 listing. PTA is regulatorily lighter than the precursor chemicals (sulfuric, methanol, HCl) and lighter than MEG (which IS on TRI as HAP)
  • Coal-route Chinese petrochemical feedstock-chain MEG/PX integration vs gas-route distinction is less material for PTA than for MEG (PTA is produced from p-xylene via oxidation; the upstream PX production route is the carbon-intensity differentiator)

Where to read next

For substance-level identifiers (formula, molecular weight, SMILES, InChIKey), GHS hazard profile, IMDG transport class, and full sourcing reference for purified terephthalic acid, see the CAS 100-21-0 sourcing reference.

For grade-by-grade buying notes, freight maths, supplier-tier pricing, and a worked landed-cost example, the purified terephthalic acid cornerstone hub covers the full sourcing chain.

For the structure and history of TSCA, see the TSCA glossary entry.

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Cross-jurisdiction profile and sourcing references

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