Required Before Shipment

Methylene Chloride Product Acknowledgment

A brief acknowledgment that you understand the rules governing methylene chloride paint strippers and that your use will comply with them.

The rules, in brief

Federal law now restricts most uses

Under EPA's 2024 rule (40 CFR Part 751, Subpart B), methylene chloride in paint strippers is banned for consumer use and most commercial/industrial uses. A short list of continuing uses is still permitted, including: as a laboratory chemical; a bonding agent for solvent welding; a processing aid; in plastic/rubber manufacturing; on safety-critical aircraft and spacecraft components; in aircraft, space-vehicle, and turbine adhesives and sealants (until May 8, 2029); for refinishing wooden furniture, decorative pieces, and architectural fixtures of artistic, cultural, or historic value (until May 8, 2029); as a reactant, for repackaging, for recycling, or as a solvent reclaimed inside a manufacturing process; for disposal and export; and under certain time-limited TSCA 6(g) exemptions (civilian aviation, NASA).

Permitted uses come with workplace requirements

Any permitted use must comply with EPA's Workplace Chemical Protection Program: exposure limits of 2 ppm (8-hour TWA) and 16 ppm (15-minute short-term), monitoring, regulated areas, supplied-air respirators where needed, dermal controls, a written Exposure Control Plan, training, and recordkeeping. OSHA's methylene chloride standard (29 CFR 1910.1052) also applies. Historic furniture refinishing is subject to a separate interim protection regime under 40 CFR 751.107 that requires regulated areas, local exhaust ventilation, and full-facepiece supplied-air respirators (APF 50).

State and local laws may go further

Regulations change constantly, and states, counties, and municipalities may impose additional or stricter rules. You are solely responsible for verifying compliance with every law that applies to your operations. Express Chem cannot and does not confirm your compliance on your behalf.

This summary is a starting point, not a legal opinion. Rules change, deadlines move, and the details matter. Confirm your own compliance with qualified counsel and with federal, state, and local regulators.

Where to learn more

Primary sources for doing your own research:

EPA Risk Management for Methylene Chloride EPA — PDF EPA Compliance Guide: 2024 Rule eCFR 40 CFR Part 751, Subpart B — full regulation OSHA OSHA Methylene Chloride Standard

Heads up: This portal and the signed acknowledgment are not a substitute for legal advice or for confirming compliance with the agencies that regulate your operations. If you are unsure whether your intended use is permitted, stop and consult qualified counsel before signing.

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Acknowledgment

I acknowledge that I have read and understand the regulations summarized above governing methylene chloride paint strippers. I represent that my company's use of Express Chem products containing methylene chloride will be limited to a use permitted under 40 CFR Part 751, Subpart B, and that my company will comply with all applicable federal, state, and local laws, including the Workplace Chemical Protection Program and the OSHA methylene chloride standard. I understand that this acknowledgment is not an exhaustive statement of the law, that I am responsible for verifying my own compliance with all relevant regulators, and that my company will indemnify Express Chem LLC for any liability arising from use of the products not in compliance with those laws, whether intentional or unintentional.

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Thank you. Your signed acknowledgment has been recorded and a copy has been emailed to you.

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