CAS 108-95-2 · TSCA · United States of America

Phenol under TSCA

C6H5OH · 苯酚

Status: Listed. Phenol is on the TSCA Inventory as a grandfathered pre-1979 substance and is currently listed as TSCA Active. No PMN is required. Phenol is on the TRI Section 313 reporting list as a Hazardous Air Pollutant under Clean Air Act Section 112; manufacturers, importers, and processors above the activity thresholds must file annual TRI Form R reports. OSHA PEL for phenol is 5 ppm (8-hour TWA, with skin absorption notation). Phenol is classified by EPA as a hazardous waste under RCRA (waste codes U188 + F004). NOTE: phenol is NOT on the EPA RMP regulated toxic substances list at 40 CFR 68.130 Table 1; only cresols (CAS 1319-77-3) are listed at TQ 10,000 lb. Verify all phenol RMP claims against https://www.epa.gov/rmp/list-regulated-substances-under-rmp.

The US phenol lane is regulatorily heavy at the workplace and facility level (note: phenol is NOT on EPA RMP at 40 CFR 68.130 Table 1; only cresols are listed at TQ 10,000 lb): TRI Form R annual reporting (above 25,000 lb thresholds), OSHA PEL 5 ppm with SKIN notation, EPCRA Tier II reporting, and RCRA hazardous waste handling. Section 301 List 3 25% additional duty on Chinese-origin phenol is a structural cost layer. NO active US AD/CVD on Chinese phenol currently; periodic petitions are filed by domestic producers (INEOS, Honeywell, Altivia, AdvanSix) but no active orders. US is structurally net-importer of phenol; Chinese, Saudi, and Korean supply origins compete. The downstream BPA cascade is the dominant medium-term demand-side regulatory uncertainty: state-level BPA bans (Washington 2008, California, Massachusetts) and FDA BPA-in-food-contact reviews demonstrate regulatory pressure that will likely tighten further. The hazard profile is materially more demanding than trivial-hazard substances; engineered-handling infrastructure is mandatory.

Listing and threshold

Substance Phenol (CAS 108-95-2), C6H5OH
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 H301 / H311 / H314 / H331 / H341 / H373
  • OSHA PEL: 5 ppm (19 mg/m³) 8-hour TWA with SKIN absorption notation (29 CFR 1910.1000 Table Z-1, verified against https://www.osha.gov/annotated-pels/table-z-1)
  • NIOSH REL: 5 ppm 10-hour TWA with SKIN notation
  • ACGIH TLV: 5 ppm 8-hour TWA with SKIN notation
  • EPA RMP: phenol is NOT on the 40 CFR 68.130 Table 1 regulated toxic substances list (verify against https://www.epa.gov/rmp/list-regulated-substances-under-rmp); the structurally similar cresols (mixed isomers, CAS 1319-77-3) ARE listed at TQ 10,000 lb but phenol itself is not RMP-regulated
  • NOT on DEA List I or List II
  • California Proposition 65: phenol is NOT listed on Prop 65 (despite Mut. 2 EU classification; verify against https://oehha.ca.gov/proposition-65/proposition-65-list)
  • RCRA waste classification: U188 (commercial chemical product when discarded) and F004 (spent non-halogenated solvent waste)
  • IARC: phenol Group 3 (not classifiable as to its carcinogenicity to humans), Monograph Vol 71 (1999) reaffirmed in Vol 117 (2019) (verify against https://monographs.iarc.who.int/list-of-classifications)

Restrictions and conditions of use

  • No TSCA-specific use restrictions for phenol
  • 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; engineered-controls and PPE for skin and inhalation exposure
  • Phenol is NOT on EPA RMP at 40 CFR 68.130 Table 1 (verify against https://www.epa.gov/rmp/list-regulated-substances-under-rmp); RMP compliance is NOT required for phenol storage at the federal level (cresols ARE at TQ 10,000 lb but phenol itself is not RMP-regulated)
  • Section 301 List 3 25% additional duty applies to Chinese-origin phenol (HS 290711)
  • NO active US AD/CVD case on Chinese-origin phenol currently. Periodic petitions are filed by domestic producers (INEOS Chocolate Bayou, Honeywell Frankford, Altivia Petrochemicals, AdvanSix Hopewell) but no active orders
  • RCRA hazardous waste handling required for phenol-contaminated waste streams

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). NOTE: phenol is NOT on the EPA RMP regulated toxic substances list at 40 CFR 68.130 Table 1 (only cresols are listed at TQ 10,000 lb); no federal RMP filing is required for phenol storage. The practitioner-facing layer is TRI Form R annual reporting (above thresholds), Section 301 List 3 25% additional duty pricing, EPCRA Tier II reporting at 500 lb (phenol is on the EHS list at 40 CFR 355 App A), and OSHA workplace exposure compliance at the 5 ppm PEL with SKIN notation. The hazard profile is materially more demanding than the trivial-hazard substances in the dataset; engineered-handling infrastructure (closed-system loading, secondary containment, eye-wash + emergency-shower) is mandatory.

Required documents

  • TSCA Section 13 Import Certification statement on customs entry
  • OSHA-compliant SDS (Safety Data Sheet) in 16-section GHS format reflecting H301 / H311 / H314 / H331 / H341 / H373 classification
  • TRI Form R annual report (where site exceeds 25,000 lb manufacture / 10,000 lb other-use thresholds)
  • EPA Risk Management Plan (40 CFR Part 68) where facility holds >5,000 lb threshold quantity
  • CDR filing every 4 years if site exceeds 25,000 lb/yr threshold (next cycle 2026)
  • OSHA workplace HazCom training documentation reflecting 5 ppm PEL with SKIN notation
  • RCRA hazardous waste manifest for phenol-contaminated waste streams

Common compliance traps

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

  • Common first-pass error: phenol is NOT on the EPA RMP regulated toxic substances list at 40 CFR 68.130 Table 1 (only cresols are at TQ 10,000 lb). No federal RMP filing is required for phenol storage; OSHA HazCom 5 ppm PEL with SKIN notation, EPCRA Tier II reporting, and state-level rules are the binding compliance layers
  • OSHA PEL at 5 ppm with SKIN notation drives engineered-controls and PPE; skin-absorption is a documented exposure route making PPE selection (chemical-resistant gloves, face shields, splash goggles) materially important
  • TRI Form R annual reporting is the most-missed compliance step for new importers; verify reporting thresholds at the importing facility
  • Section 301 List 3 25% additional duty applies to Chinese-origin phenol (HS 290711); structural cost layer
  • No active US AD/CVD on Chinese phenol currently but periodic petitions are filed; INEOS Chocolate Bayou, Honeywell Frankford, Altivia Petrochemicals, AdvanSix Hopewell are dominant domestic producers
  • US is structurally net-importer of phenol despite domestic producer presence; Chinese, Saudi (SABIC), and Korean (Kumho P&B Chemicals, LG Chem) supply origins compete
  • BPA downstream is ~50% of US phenol demand; FDA BPA-in-food-contact reviews and state-level BPA bans (Washington, California, Massachusetts) create structural BPA demand reduction risk
  • Mut. 2 classification (EU) is not directly mirrored in OSHA / NIOSH classifications but informs hazard communication; Cal-OSHA Prop 65 review may extend to phenol

Where to read next

For substance-level identifiers (formula, molecular weight, SMILES, InChIKey), GHS hazard profile, IMDG transport class, and full sourcing reference for phenol, see the CAS 108-95-2 sourcing reference.

For grade-by-grade buying notes, freight maths, supplier-tier pricing, and a worked landed-cost example, the phenol 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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