CAS 107-21-1 · TSCA · United States of America

Monoethylene glycol under TSCA

C2H6O2 · 乙二醇

Status: Listed. Monoethylene glycol is on the TSCA Inventory as a grandfathered pre-1979 substance and is currently listed as TSCA Active. No PMN is required. MEG is on the Toxics Release Inventory (TRI) Section 313 reporting list as a Hazardous Air Pollutant (HAP) under Clean Air Act Section 112; manufacturers, importers, and processors above the activity thresholds must file annual TRI Form R reports.

The US MEG lane is regulatorily clean on the federal side: TSCA-listed, no DEA scheduling, no RMP. MEG IS on Cal Prop 65 as developmental toxicant (oral exposure, listed 19 June 2015) so California-distributed consumer products containing MEG may require Prop 65 warning. No current AD/CVD case on Chinese-origin MEG; the 2023-2024 ITC investigation 731-TA-1641 through 731-TA-1644 covered Saudi Arabia, Trinidad and Tobago, and Kuwait (not China) and ended with a negative final determination (verify case status and date at https://www.usitc.gov/investigations). The dominant practitioner-facing compliance work is annual TRI Form R reporting (above 25,000 lb thresholds), Section 301 List 3 25% additional duty pricing, and FHSA retail-packaging labelling for downstream antifreeze formulators. The structural commercial story for Chinese-origin US lane is the coal-route vs gas-route carbon-intensity divergence: gas-route MEG (Shenghong, Hengli, Sinopec) increasingly preferred by US PET-resin buyers (Indorama, Eastman) with Scope 3 reporting commitments over coal-route MEG (Yulin, Tongliao, Xinjiang Tianye). US domestic producers (LyondellBasell, MEGlobal, Indorama) periodically petition for AD investigations; petition history should be monitored before invoicing volume contracts.

Listing and threshold

Substance Monoethylene glycol (CAS 107-21-1), C2H6O2
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. TRI Section 313 threshold: 25,000 lb manufactured or processed; 10,000 lb otherwise used

Classifications under this regime

  • TRI Section 313 (Toxics Release Inventory) listed as Hazardous Air Pollutant
  • Clean Air Act Section 112 HAP list
  • OSHA Hazard Communication Standard (HCS, 29 CFR 1910.1200): GHS H302 (harmful if swallowed), H373 (kidney damage on prolonged exposure)
  • NIOSH ceiling REL: 50 ppm (125 mg/m³)
  • OSHA does not have a specific PEL for MEG; ACGIH TLV ceiling 100 mg/m³ aerosol (verify against https://www.osha.gov/annotated-pels/table-z-1 for OSHA-specific PELs)
  • 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
  • NOT on EPA RMP threshold list
  • NOT on DEA List I or List II
  • California Proposition 65: ethylene glycol (ingested) is LISTED as Developmental Toxicity endpoint, effective 19 June 2015 (verify against https://oehha.ca.gov/proposition-65/proposition-65-list); Prop 65 warning may be required for California-distributed consumer products that could lead to oral exposure

Restrictions and conditions of use

  • No TSCA-specific use restrictions for MEG
  • TRI Form R annual reporting required for facilities above 25,000 lb manufacture / process or 10,000 lb other use thresholds
  • OSHA-compliant SDS and workplace HazCom training required
  • Section 301 List 3 25% additional duty applies to Chinese-origin MEG (HS 290531)
  • NO active US AD/CVD case on Chinese-origin MEG currently. The 2023-2024 ITC investigations 731-TA-1641 through 731-TA-1644 (with parallel CVD 701-TA-694) covered Saudi Arabia, Trinidad and Tobago, and Kuwait (NOT China); ITC voted final negative, terminating the case with no AD/CVD orders imposed (verify case status, vote, and date at https://www.usitc.gov/investigations and https://access.trade.gov)
  • Federal Hazardous Substances Act (FHSA) labelling required for retail consumer products containing MEG (antifreeze, coolant, screenwash) above defined thresholds

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 MEG specifically, the practitioner-facing layer is annual TRI Form R reporting (above thresholds), Section 301 List 3 additional duty, and FHSA retail-packaging labelling (for downstream antifreeze formulators). The 2023-2024 AD investigation on MEG terminated negative in April 2024; no current AD/CVD applies, but periodic petitions are filed by domestic producers (LyondellBasell, Indorama, MEGlobal) and the petition history should be monitored before invoicing volume contracts.

Required documents

  • TSCA Section 13 Import Certification statement on customs entry
  • OSHA-compliant SDS (Safety Data Sheet) in 16-section GHS format
  • TRI Form R annual report (where site exceeds 25,000 lb manufacture / 10,000 lb other-use thresholds)
  • CDR filing every 4 years if site exceeds 25,000 lb/yr threshold (next cycle 2026)
  • FHSA-compliant labelling for retail consumer products (downstream formulator 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 MEG (HS 290531); structural cost layer that must be priced into every Chinese-origin US lane invoice
  • No active US AD/CVD on MEG currently but the 2023-2024 ITC case (Saudi / Trinidad / Kuwait, terminated April 2024 negative) demonstrates that domestic-producer-initiated petitions are realistic; monitor Department of Commerce filings
  • TRI Form R annual report is the most-missed compliance step for new importers; verify reporting threshold at the importing facility
  • Coal-route Chinese MEG (CTMEG) carries 3-4x higher embedded CO2 vs gas-route; California LCFS-equivalent Scope 3 reporting frameworks may extend to industrial chemicals as state-level climate disclosure rules expand
  • US is structurally net-importer of MEG (despite being a major producer) because PET resin and antifreeze demand exceeds domestic capacity; lane economics are stable
  • No DEA scheduling, no EPA RMP threshold listing. MEG IS on Cal Prop 65 as developmental toxicant since 19 June 2015 (oral exposure pathway); Prop 65 warning may apply for California-distributed consumer products. MEG is regulatorily lighter than the precursor chemicals (sulfuric, methanol, HCl) on the federal side

Where to read next

For substance-level identifiers (formula, molecular weight, SMILES, InChIKey), GHS hazard profile, IMDG transport class, and full sourcing reference for monoethylene glycol, see the CAS 107-21-1 sourcing reference.

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

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

Need cross-jurisdiction compliance support on this substance? Run it through the REACH / TSCA / IECSC / AICIS / K-REACH checker, or send us the substance and the destination and we will quote FOB China and CIF / DDP landed including the regulatory work on the destination side.

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Cross-jurisdiction profile and sourcing references

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