On June 5, 2024, under the Toxic Substances Control Act (TSCA), the U.S. Environmental Protection Agency (EPA) released a proposed rule to limit the use of N-Methylpyrrolidone (NMP) in certain commercial and consumer products.
The proposal will be open for public comment for 45 days following its publication in the Federal Register. Additionally, the EPA plans to host a public webinar on June 20 at 1:00 PM to provide an overview of the proposed rule. Interested businesses can participate through the following registration link:
The specifics of the NMP use restrictions proposed rule are as follows:
1. Commercial Use Ban
The EPA proposes to prohibit the application of NMP under five commercial use conditions:
As lubricants and lubricant additives in mechanical manufacturing;
- In antifreeze and de-icing products, automotive care products, and the use of lubricants and greases;
- In the industrial and commercial use of metal products, excluding lubricants and lubricant additives, including hydrophilic coatings;
- In the industrial and commercial use of cleaning and degreasing products, including wood cleaners and gasket removers;
- In the manufacturing of fertilizers and other agricultural chemicals as processing aids and solvents.
2. Consumer Use Restrictions
For consumer products, the EPA proposes the following restrictions:
- Limiting container sizes and imposing labeling requirements: ensuring products are only sold in small volumes (no more than 16 ounces) and labeled "For Consumer Use Only";
- Concentration limits: specific products such as adhesives and sealants must not exceed a 45% concentration of NMP.
3. Occupational Use Controls
For NMP use in occupational settings, the EPA proposes tiered control measures:
a. Prescriptive controls: applicable to seven occupational use conditions, including the use of personal protective equipment (PPE) and concentration limits.
Four occupational uses will see a 45% concentration limit of NMP in formulated products, requiring workers to use skin PPE and specified respirators. These conditions include:
- Processing: incorporating it into paint additives and coating additives in the manufacture of transportation equipment;
- Industrial and commercial use of paints, varnishes, dyes, varnishes, primers, and floor coatings, as well as in surface preparation;
- Industrial and commercial use of paint additives and coating additives in construction, metal product manufacturing, machinery manufacturing, other manufacturing, paint and coating manufacturing, primary metal manufacturing, transportation equipment manufacturing, wholesale, and retail trade;
- Industrial and commercial use of adhesives and sealants, including adhesives, single-component adhesives, and lubricant adhesives, and two-component adhesives and sealants, including certain resins.
Three other use conditions will face lower concentration limits and skin controls, as follows:
- Industrial and commercial use of paint, coating, and adhesive removers - 30% concentration limit, plus specific respiratory protection;
- Industrial and commercial use of inks, colorants, and dye products in printer inks - 5% concentration limit;
- Industrial and commercial use in welding materials - 1% concentration limit.
b. Direct Dermal Contact Control (DDCC): applicable to all other occupational use conditions, requiring regulated entities to determine the most effective way to prevent direct skin contact based on the actual conditions of their workplace. Private companies will have 12 months to develop appropriate WCPPs, while federal agencies and their contractors will have three years.
Reasons for NMP Use Restrictions
NMP is a solvent widely used in industrial, commercial, and consumer products such as electronics, paint removers, and cleaners. Despite its critical role in many production processes, a 2020 risk assessment by the EPA highlighted that NMP could cause serious health issues including miscarriages and decreased fertility, as well as potential damage to the liver, kidneys, immune system, and nervous system.
Implementation Timeline
Manufacturers, processors, and distributors will need to begin phasing out non-compliant uses within 12 months of the final rule's publication; The deadline for industrial and commercial users will be announced later.
Further Information
Proposed rule（pre-publication）
EPA
Risk Evaluation for n-Methylpyrrolidone (2-Pyrrolidinone, 1-Methyl-) (NMP)
