CAS 77-92-9 · TSCA · United States of America

Citric acid under TSCA

C6H8O7 · 柠檬酸

Status: Listed. Citric acid is on the TSCA Inventory as a grandfathered pre-1979 substance and is currently listed as TSCA Active. No PMN is required. Citric acid carries a light TSCA / OSHA / EPA regulatory profile (no DEA, no RMP, no EPCRA Tier reporting at industrial volumes); the operator-relevant complexity is the iconic active US AD/CVD case on Chinese-origin citric acid since 2009.

Citric acid is THE iconic Chinese-origin AD/CVD case in the US market. The Department of Commerce AD case A-570-937 and parallel CVD case C-570-938 (original orders 29 May 2009) have been continuous since 2009 with annual administrative reviews; the second sunset review continued the orders in January 2021 (https://www.federalregister.gov/documents/2021/01/04/2020-29114), and any third sunset review outcome and current cash-deposit rates must be verified at https://access.trade.gov before invoicing (do not rely on prior-period rates). Combined AD + CVD + Section 301 25% on some Chinese producers can exceed 150% landed cost, which has structurally favoured US domestic producers (Tate & Lyle, ADM, Cargill) and non-China imports. Sourzi-relevant practice: verify producer-specific margin per the most-recent ITA review before invoicing; circumvention via third-country repackaging triggers Commerce Department investigations; FSMA FSVP applies separately for food-grade. The case is the canonical teaching example of how AD/CVD framework affects landed-cost economics.

Listing and threshold

Substance Citric acid (CAS 77-92-9), C6H8O7
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): Eye Irrit. 2, Skin Irrit. 2
  • NOT on EPA RMP threshold list
  • NOT on DEA List I or List II
  • NOT on CERCLA hazardous-substance list
  • FDA GRAS (Generally Recognised As Safe) under 21 CFR 184.1033 for food-grade

Restrictions and conditions of use

  • No TSCA-specific use restrictions for citric acid
  • OSHA workplace exposure limits: PNOR / nuisance-dust thresholds at 29 CFR 1910.1000 Table Z-1 (PEL 15 mg/m³ total, 5 mg/m³ respirable; verify against https://www.osha.gov/annotated-pels/table-z-1)
  • DOT and US Coast Guard rules: citric acid is NOT a regulated dangerous good for transport
  • FDA GRAS / FCC (Food Chemicals Codex) compliance applies for food-grade product
  • **Active US AD/CVD case on Chinese-origin citric acid since 2009.** Department of Commerce conducts annual administrative reviews. Combined AD + CVD margins for some Chinese producers exceed 100%; specific producer rates vary by review period.
  • Section 301 List 3 25% additional duty applies on top of AD/CVD on Chinese-origin citric acid

Importer obligations

TSCA is a self-certification regime: importers attest at customs entry. The operator-relevant complexity is the AD/CVD compliance layer, not TSCA itself. Importers of Chinese-origin citric acid must verify producer-specific AD/CVD margins per the most-recent Department of Commerce administrative review (rates change annually); pay AD/CVD cash deposits at entry; file Customs Form 7501 with the AD/CVD case number; maintain records for the 5-year reconciliation period. Food-grade product additionally requires FDA Food Facility Registration and may require FSMA Foreign Supplier Verification Programme (FSVP) compliance.

Required documents

  • TSCA Section 13 Import Certification statement on customs entry
  • OSHA-compliant SDS (Safety Data Sheet) in 16-section GHS format
  • AD/CVD case number and producer-specific margin verification: AD case A-570-937 plus parallel CVD case C-570-938; original orders published 29 May 2009 (verify via https://access.trade.gov/case_segment_filter.aspx); second sunset review continuation Jan 2021 at https://www.federalregister.gov/documents/2021/01/04/2020-29114; current rates and any third-sunset-review outcome must be verified at access.trade.gov before invoicing
  • Form 7501 with AD/CVD cash deposits at entry
  • FDA Food Facility Registration (where food-grade)
  • FSMA Foreign Supplier Verification Programme (FSVP) compliance plan (where food-grade)
  • CDR filing every 4 years if site exceeds 25,000 lb/yr threshold (next cycle 2026)

Common compliance traps

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

  • **AD/CVD margins are producer-specific and change annually with each administrative review.** Verify current rates per the Department of Commerce ITA database before invoicing; substituting one Chinese producer for another mid-shipment can trigger surprise duty bills
  • Combined AD + CVD + Section 301 List 3 25% can exceed 150% on some Chinese producers; landed cost frequently makes Chinese citric uncompetitive vs Tate & Lyle / ADM US production or Cargill imports from non-China origins
  • Country-of-origin labelling: Chinese citric acid repackaged in third countries (Vietnam, Thailand, Mexico) is subject to circumvention investigations
  • Food-grade FCC Standard purity criteria are tighter than basic FDA GRAS; verify spec before invoicing
  • FSMA FSVP for food-grade product requires importer-side hazard analysis and supplier verification (separate workstream from AD/CVD)
  • EPA wastewater rules apply at citric-acid-using industrial facilities (food-and-beverage, pharma); no specific citric-acid Federal limit but state-level POTW pretreatment may apply

Where to read next

For substance-level identifiers (formula, molecular weight, SMILES, InChIKey), GHS hazard profile, IMDG transport class, and full sourcing reference for citric acid, see the CAS 77-92-9 sourcing reference.

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

Read next

Cross-jurisdiction profile and sourcing references

Referenced in

6 pages across the Sourzi moat

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