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The 60-second self-audit

Does the TCE ban touch your shop?

Three questions about the cans on your shelf. The verdict comes straight from our TCE compliance report, the same rules, the same dates, one page shorter.

Question 1 of 3

Does your wheel-prep or brake cleaner SDS list trichloroethylene (TCE) or perchloroethylene (perc) in Section 3?

Question 2 of 3

Aerosol cans or bulk?

Question 3 of 3

How many bays run it daily?

Verdict: affected

You are affected. Here is the timeline.

Section 3 with TCE or perc in it puts that product inside the 2024 EPA rules. The dates, from our compliance report:

  • December 17, 2024: the EPA finalized the TCE rule. All uses prohibited, most by September 15, 2025, degreasers and adhesion prep included.
  • September 15, 2025: the core TCE prohibitions took effect on schedule. The court fight since (a ten-week stay, lifted March 28, 2025; a February 11, 2026 refusal to pause the rule again) has argued the edges, not the center. Nothing in the sequence restores TCE to a parts shelf. A TCE product should already be out of service.
  • January 17, 2025: the PCE rule took effect. Every consumer use, brake cleaners included, exits inside a roughly three year window. A perc product belongs on a replacement plan now, on your schedule instead of the supply chain's.

General industry guidance sourced from our TCE compliance report, not legal or regulatory advice.

Verdict: likely affected

Likely affected. Check Section 3. Here is how.

"Not sure" is the most common honest answer, and for classic nonflammable brake cleaner it usually resolves to yes. Five minutes settles it:

  • Pull the SDS for every solvent, degreaser, and brake cleaner in the building. No SDS on file is its own finding.
  • Open Section 3 (composition) and search for trichloroethylene, CAS 79-01-6 and perchloroethylene, CAS 127-18-4.
  • TCE listed: that product's uses have been prohibited since September 15, 2025 and it should already be out of service.
  • Perc listed: the January 2025 PCE rule phases out all consumer uses, brake cleaners included, inside a roughly three year window. Put it on a replacement plan.
  • Neither listed: you are clear on the carcinogen axis. Re-run this audit when a new SKU lands on the shelf, labels have been changing ahead of the products.

General industry guidance sourced from our TCE compliance report, not legal or regulatory advice.

Verdict: clear

You are clear. Here is what changed anyway.

No TCE and no perc in Section 3 means those products sit outside both 2024 rules. The market around them still moved:

  • The legitimate supply chain for TCE based product is gone, and perc based aerosols are on a countdown that ends inside a roughly three year window from January 2025.
  • SDS language duties already hit the paperwork: required PCE wording by February 18, 2025 for manufacturers and June 16, 2025 for processors and distributors. That is why familiar labels changed before the products did.
  • Brake cleaner on wheels was always an off label habit. Wheel prep is a defined job, and the rules just retired the chemistry that let the habit slide.

General industry guidance sourced from our TCE compliance report, not legal or regulatory advice.