CAS 9002-86-2 · TSCA · United States of America

Polyvinyl chloride under TSCA

(C2H3Cl)n · 聚氯乙烯

Status: Listed. Polyvinyl chloride is on the TSCA Inventory as a polymer of low concern (PMN-exempt under polymer exemption rules at 40 CFR 723.250). The constituent vinyl chloride monomer (VCM, CAS 75-01-4) is on the TSCA Inventory and is regulated separately as an OSHA-listed carcinogen and EPA-listed Hazardous Air Pollutant under Clean Air Act Section 112. PVC plasticiser phthalates (DEHP, DBP, BBP, DIBP) carry separate TSCA Section 6 regulation under EPA risk-management rules. US is structurally net-exporter of PVC.

The US PVC lane is regulatorily light at the polymer level: TSCA-listed polymer of low concern, no DEA scheduling, no Prop 65 listing, no active AD/CVD case (US is structurally net-exporter so AD risk is low). The dominant practitioner-facing compliance work is at the formulation step: CPSIA phthalate limits in childcare articles, TSCA Section 6 phthalate rules (DEHP / BBP final 2024), FDA 21 CFR 177.1980 food-contact compliance, and Section 301 List 3 25% additional duty pricing. Coal-route Chinese PVC (calcium carbide chain with mercury catalyst) raises Minamata Convention compliance concern that some US buyers factor into supplier selection. Ethylene-route Chinese PVC producers (Sinopec Qilu, LG Chem Daya Bay, Sumitomo Chemical Tianjin) carry cleaner Scope 3 profile vs coal-route producers concentrated in Inner Mongolia, Xinjiang, Qinghai, Shaanxi.

Listing and threshold

Substance Polyvinyl chloride (CAS 9002-86-2), (C2H3Cl)n
Regime US Toxic Substances Control Act (TSCA), administered by EPA
Jurisdiction United States of America
Status Listed
Tonnage threshold Polymer exemption applies; CDR (Chemical Data Reporting) threshold 25,000 lb/yr for polymer reporting

Classifications under this regime

  • Polymer of low concern, exempt from PMN under 40 CFR 723.250
  • Constituent VCM (CAS 75-01-4): OSHA Carcinogen Standard 29 CFR 1910.1017 (PEL 1 ppm 8-hr TWA, STEL 5 ppm, AL 0.5 ppm verified against https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.1017), Clean Air Act Section 112 HAP, EPA RMP Threshold Quantity 10,000 lb
  • IARC: VCM Group 1; finished PVC resin not separately evaluated
  • NOT subject to TSCA Section 4 test rule for PVC polymer
  • NOT currently subject to TSCA Section 6 unreasonable-risk evaluation for PVC polymer
  • OSHA Hazard Communication Standard (HCS): finished PVC resin requires SDS but typically not classified as hazardous
  • NOT on EPA RMP threshold list for PVC polymer (VCM monomer IS at 10,000 lb)
  • NOT on DEA List I or List II
  • NOT on California Proposition 65 list for PVC polymer (VCM IS listed as carcinogen)
  • TSCA Section 6 Phthalate Risk Evaluation: DEHP, DBP, BBP, DIBP, DCHP, DINP, DNOP, DIDP regulated as plasticiser additives, not PVC polymer itself
  • FDA 21 CFR 177.1980 approves PVC polymer for food-contact applications (with monomer residue limits and approved plasticiser limits)

Restrictions and conditions of use

  • Polymer EXEMPT from PMN under 40 CFR 723.250
  • OSHA-compliant SDS required (even for low-concern polymer)
  • Section 301 List 3 25% additional duty applies to Chinese-origin PVC (HS 3904); structural cost layer
  • NO active US AD/CVD case on Chinese-origin PVC primary form currently; US is structurally net-exporter of PVC (Westlake, Shintech, Formosa Plastics, OxyChem) so domestic producers have not historically petitioned AD on imported PVC. Periodic petitions are filed on PVC-containing finished goods (resilient flooring, etc.) but not on PVC polymer itself
  • CPSC-mandated phthalate limits in toys and childcare articles (Consumer Product Safety Improvement Act 2008, CPSIA): DEHP, DBP, BBP at 0.1%; DIBP, DPENP, DHEXP, DCHP at 0.1%
  • FDA 21 CFR 177.1980 sets PVC food-contact compositional requirements including monomer residue limits and approved plasticiser positive list
  • DEHP and other phthalates regulated separately under TSCA Section 6 (final risk-management rules issued 2024 for DEHP, BBP)
  • EPA Mercury Export Ban Act of 2008 restricts US mercury export to overseas PVC producers using mercury-catalysed acetylene-to-VCM route

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 PVC specifically, the practitioner-facing layer is plasticiser composition compliance (CPSIA phthalate limits, TSCA Section 6 phthalate rules), Section 301 List 3 25% additional duty pricing, and FDA 21 CFR 177.1980 food-contact compliance for food-grade applications. US has limited AD/CVD risk on Chinese PVC given US net-exporter status.

Required documents

  • TSCA Section 13 Import Certification statement on customs entry
  • OSHA-compliant SDS (Safety Data Sheet) in 16-section GHS format
  • CDR filing every 4 years if site exceeds 25,000 lb/yr threshold (next cycle 2026)
  • Plasticiser composition declaration with CPSIA / TSCA Section 6 phthalate compliance certification
  • FDA 21 CFR 177.1980 compliance documentation where food-contact application applies
  • Mercury-catalyst-free certification for coal-route Chinese PVC (where buyer requires under EPA Mercury Export Ban / Minamata Convention compliance)

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 PVC (HS 3904); structural cost layer
  • No active US AD/CVD on PVC primary form currently; US is structurally net-exporter (Westlake, Shintech, Formosa, OxyChem) so AD risk is low
  • CPSIA phthalate limits in childcare articles is the dominant CPSC compliance concern for flexible PVC; verify plasticiser composition before invoicing toys / childcare-grade product
  • TSCA Section 6 phthalate rules (final 2024) impose DEHP and BBP risk-management measures; verify plasticiser composition compliance
  • Coal-route Chinese PVC (calcium carbide / mercury catalyst chain) raises Minamata Convention compliance concern; some US buyers prefer ethylene-route Chinese PVC over coal-route
  • Ethylene-route Chinese PVC producers (Sinopec Qilu, LG Chem Daya Bay, Sumitomo Chemical Tianjin) carry cleaner Scope 3 profile vs coal-route producers (Inner Mongolia Junzheng, Xinjiang Tianye, Qinghai Salt Lake)
  • No DEA scheduling, no Prop 65 listing for PVC polymer (VCM monomer IS Prop 65 listed as carcinogen); finished PVC resin is regulatorily light at the Federal level

Where to read next

For substance-level identifiers (formula, molecular weight, SMILES, InChIKey), GHS hazard profile, IMDG transport class, and full sourcing reference for polyvinyl chloride, see the CAS 9002-86-2 sourcing reference.

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