On December 23, 2020, news provider Chemical Watch reported on a new set of restrictive rules for the substance phenol isopropylated phosphate (3:1), also known as PIP (3:1) (CAS 68937-41-7) by the US Environmental Protection Agency (EPA) under the Toxic Substances Control Act (TSCA).

PIP (3:1) is commonly used multi-functionally including, among others, as a plasticizer, flame retardant in consumer products, and a lubricant and hydraulic fluid. However, the chemical is a known aquatic toxicant, with the potential to cause reproductive, developmental, and neurological effects and to impact systemic organs like the liver, heart, and lungs. Therefore, the new rules were implemented to “protect human health and the environment because they address risks and reduce exposure to [persistent, bioaccumulative, and toxic] PBT chemicals.”

Under the final rule, the EPA will prohibit the release of PIP (3:1) to water and will ban the processing and distribution of PIP (3:1) as well as of products containing it. There will be exceptions for its use including in e.g., recycling of plastic that contained the substance prior to being recycled.

According to the Food Packaging Forum’s recently published FCCdb database (FPF reported), PIP (3:1) is listed, among others, as part of Japan’s 2020 final positive list for additives and coatings for food contact plastics as well as Switzerland’s 2019 of food contact inks. PIP (3:1) is currently also under assessment by the European authorities as an endocrine-disrupting chemical (EDC) and as a suspected PBT and a very persistent very bioaccumulative (vPvB) substance.

Manufacturers and downstream users are required to notify their customers about these new restrictions, and certain industries are being given an extended time to comply.


EPA (December 21, 2020). “Phenol, Isopropylated Phosphate (3:1) (PIP 3:1); Regulation of Persistent, Bioaccumulative, and Toxic Chemicals under TSCA Section 6(h).” (pdf)

Read More

Terry Hyland (December 23, 2020). “US EPA imposes partial bans on five PBTs.” Chemical Watch

EPA (December 22, 2020). “Persistent, Bioaccumulative, and Toxic (PBT) Chemicals under TSCA Section 6(h).