TSCA Update: Inventory Changes and Draft Risk Evaluations for Phthalates

The U.S. Environmental Protection Agency (EPA) recently released two important updates under the Toxic Substances Control Act (TSCA): the semiannual update to the TSCA Inventory and draft risk evaluations for two widely used phthalates—butyl benzyl phthalate (BBP) and diisobutyl phthalate (DIBP). These developments have implications for manufacturers, retailers, and suppliers handling chemicals in commerce.

Updated TSCA Inventory

On August 14, 2025, the EPA published its latest TSCA Inventory update. The Inventory now contains 86,862 chemicals, of which 42,578 are designated as active in U.S. commerce.

Key updates include:

• Revisions to commercial activity data.
• Clarifications on unique identifiers and regulatory designations (e.g., Significant New Use Rules (SNURs), test orders).
• Ongoing review of Confidential Business Information (CBI) claims, with more substances being moved into the public portion of the Inventory.

This update supports TSCA’s goal of increasing transparency in chemical use and regulation, giving businesses and the public better visibility into which substances are actively used in commerce. The next update is expected in winter 2026.

Draft Risk Evaluations: BBP and DIBP

On August 6, 2025, EPA released draft risk evaluations for butyl benzyl phthalate (BBP) and diisobutyl phthalate (DIBP) for public review and comment. These evaluations stem from their designation as high-priority substances in 2019.

Chemical Use and Production Volumes

• BBP: Primarily used as a plasticizer in polyvinyl chloride (PVC) products such as flooring, adhesives, and coatings. Reported production volume ranged from 1–20 million pounds annually between 2016–2019.
• DIBP: Used in adhesives, lacquers, rubber, and cosmetics. Production volume reported at 380,000–441,000 pounds annually between 2016–2020.

Preliminary Findings

The draft evaluations conclude that both BBP and DIBP present unreasonable risks to human health and the environment under certain conditions of use. 

Concerns include:

• Human health risks: developmental and reproductive toxicity, particularly from occupational and consumer exposures.
• Environmental risks: aquatic toxicity affecting algae, fish, and invertebrates.

Call for Public Input

EPA is requesting additional data and public comments, particularly on:

• Workplace controls, such as PPE and engineering systems.
• Exposure data for inhalation, dermal contact, and consumer use.
  Environmental release data across air, water, and waste pathways.
• Use-specific details such as spray applications, dust exposure, and mouthing behaviors (for children’s products).
  
  

The comment period is open until October 6, 2025, after which EPA will finalize the risk evaluations with input from the Science Advisory Committee on Chemicals (SACC).

What This Means for Industry

Companies manufacturing, importing, or selling products containing BBP or DIBP should be prepared for potential regulatory actions following these evaluations. Possible measures include:

• Expanded risk management requirements.
• Restrictions on certain uses.
• Increased reporting or recordkeeping obligations.

In parallel, the ongoing TSCA Inventory updates mean businesses need to track chemical listings carefully to ensure compliance with reporting and disclosure requirements.

Conclusion

The latest TSCA updates underscore EPA’s continued focus on transparency and chemical safety. With BBP and DIBP under review for unreasonable risk, stakeholders across the supply chain—from chemical manufacturers to retailers—should closely monitor developments and prepare for possible regulatory changes.
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