ECIA Environmental Compliance Update: EPA Opts for More Industry Input on PIP (3:1)

Atlanta – The ECIA Global Industry Practices Committee (GIPC) is closely following any global legislation that will impact its members. This update concerns the PIP (3:1) legislation that ECIA reported on last week.

In the U.S., the Office of Chemical Safety and Pollution Prevention of the Environmental Protection Agency (EPA) has determined that the chemical phenol, isopropylated, phosphate (3:1) (PIP 3:1) poses a risk to the public and has banned the use of the chemical. The ban was scheduled to go into effect on March 8, 2021, under the Toxic Substances Control Act (TSCA). Due to the incredibly short compliance window and because PIP has not been regulated elsewhere in the world, it posed a major challenge to identify its potential presence in supply chains.

Last Friday, according to the National Law Review, the EPA announced it is extending certain compliance dates for PIP (3:1) to March 8, 2022, “to address the hardships inadvertently created by the original applicable compliance dates in the January 2021 final rule to ensure that supply chains are not disrupted for key consumer and commercial goods.” According to EPA, it will also soon issue a notice of proposed rulemaking that, if issued in final, would further extend the compliance dates.

EPA also requested additional comment on the final PIP (3:1) rule. According to EPA’s September 3, 2021, announcement, “industry commenters indicated the need for varying time frames to remove PIP (3:1) from their supply chains, and many did not provide sufficiently specific information about their operations to support their assertions.”

For more information about this regulation, visit PIP (3:1) (

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