If you are a business customer, the answer is yes. If you are a retail customer, you may no longer use methylene chloride strippers or paint removers. Only businesses with appropriate safety precautions in place may use these chemicals under current EPA regulations. Transene Company will not ship these products to residential addresses.
EPA COMPLIANCE KIT
FOR METHYLENE CHLORIDE IN PAINT AND COATING REMOVERS
This kit contains information to enable distributors, industrial and other professional users to comply with current EPA rules for the use of paint and coating removers that contain methylene chloride. EPA compliance is the responsibility of the purchaser/user of methylene chloride paint and coating removers. Many of the paint and coating removers manufactured by Transene Company contain methylene chloride.
Our paint and coating removers that contain methylene chloride ARE NOT formulated for retail sale or consumer use. If you are not a business-to-business vendor, a professional doing surface preparation, or a licensed business professional doing refinish work, we cannot, so we will not, sell you paint and coating removers that contain methylene chloride.
Business-to-business vendors must provide evidence that they are a lawful business serving professional industrial (non-retail) clientele. Sole proprietors, general contractors and those who perform surface preparation and refinishing services must provide a general business license, contractor’s license or other written proof that supports a non-retail, non-consumer purpose for acquiring our paint and coating removers.
Prohibition and Definition of Retailer
Under the final rule, retailers cannot distribute methylene chloride-containing products for any paint and coating removal purposes. A retailer is defined by the EPA’s regulation as a person who distributes in commerce, or makes available, a chemical substance or mixture to consumer end users, including by e-commerce internet sales or distribution. A distributor that
has at least one consumer end-user customer is considered a retailer.
A person who distributes in commerce, or makes available a chemical substance or mixture solely to commercial or industrial end users or solely to commercial or industrial businesses, and does not have any consumer customers, is not considered a retailer for purposes of EPA’s regulation of methylene chloride for consumer paint and coating removal.
The final rule allows distribution of methylene chloride in paint and coating removal by business-to-business vendors, or by industrial establishments or e-commerce sites that do not have consumer customers.
To reduce the likelihood of movement of methylene chloride for consumer paint and coating removal through the supply chain and thus prevent unreasonable risks to consumers, distributors and other businesses who serve both retail and business customers will need to partition those businesses and treat the customers of each as separate to ensure, as best they can,
that consumers do not have access to methylene chloride for paint and coating removal, while allowing access for commercial users of methylene chloride for paint and coating removal through other distribution networks.
FOR MORE INFORMATION VISIT: WWW.EPA.GOV/ASSESSING-AND-MANAGING-CHEMICALS-UNDER-TSCA/FINAL-RISK-EVALUATION-METHYLENE-CHLORIDE
Recordkeeping and Downstream Notification Requirements
The final rule also includes requirements for recordkeeping and downstream notification of these restrictions to others in the supply chain. Downstream notification ensures that processors and distributors are aware of the restrictions for methylene chloride in paint and coating removal; enhances the likelihood that the risks associated with this use of methylene chloride are
addressed throughout the supply chain; and streamlines compliance and enforcement. The final rule requires manufacturers (including importers), processors, and distributors to: