The Methylene Chloride Deadline Passed in April. Here Is the Actual Rule.
The short version. If there is a can of methylene chloride stripper on your shelf, the rule that covers it is 40 CFR 751.107(b)(6), and its date has already passed: after 28 April 2026, all persons are prohibited from industrial or commercial use of methylene chloride for the uses that section covers. Body shop paint stripping is one of them.
This page is read from the current text of the regulation, not from a summary of it. Where the rule is narrower than the headline, we say so, because the exemptions are the part people get wrong in both directions.
The dates, in the order they actually happened
The prohibition did not arrive all at once. EPA closed the supply chain first and the use last, which is why a shop can be sitting on legally purchased stock that is now illegal to use.
| Date | What became prohibited | Cite |
|---|---|---|
| 22 Nov 2019 | Manufacture, processing and distribution for consumer paint and coating removal | 751.105(a) |
| 3 Feb 2025 | Distributing in commerce to retailers, for any use | 751.107(b)(1) |
| 5 May 2025 | Retailers distributing it, for any use | 751.107(b)(2) |
| 5 May 2025 | Manufacture (including import) for the covered uses | 751.107(b)(3) |
| 1 Aug 2025 | Processing for the covered uses | 751.107(b)(4) |
| 28 Jan 2026 | Distributing in commerce for the covered uses | 751.107(b)(5) |
| 28 Apr 2026 | Industrial or commercial use | 751.107(b)(6) |
Read the last two rows together. Distribution stopped three months before use did. There was never a window in which a shop could lawfully restock, and the stock that remains is not grandfathered: the rule prohibits the use, not the possession.
Why collision repair is not exempt
This is the part worth reading slowly, because the answer sits in a cross-reference rather than in a list of trades.
Section 751.107 does not apply to the conditions of use "addressed under § 751.109(a)." That section, the Workplace Chemical Protection Program, is where a use goes on living under exposure limits instead of being banned. It lists thirteen conditions of use, and exactly one of them is paint and coating removal:
"Industrial or commercial use for paint and coating removal from safety-critical, corrosion-sensitive components of aircraft and spacecraft."
A collision repair facility is not aircraft or spacecraft. So shop paint stripping is not in § 751.109(a), which means § 751.107 applies to it, which means paragraph (b)(6) applies to it, which means it stopped being lawful on 29 April 2026.
The three uses that outlive the deadline are set out in 751.107(b)(7) through (9), and they are narrow:
- NASA emergency use by the agency or its contractors, until 8 May 2034
- Paint and coating removal for refinishing wooden furniture, decorative pieces and architectural fixtures of "artistic, cultural, or historic significance", until 8 May 2029
- Adhesives and sealants in aircraft, space vehicle and turbine applications, structural and safety-critical non-structural, until 8 May 2029
The furniture carve-out is the one people reach for, and it does not travel. It is written about antiques, not about the fact that a substrate is wooden, and a car is not a decorative piece of artistic, cultural or historic significance.
Two things not to say about this
Do not say EPA "banned methylene chloride." It did not. Thirteen conditions of use continue under the Workplace Chemical Protection Program, including manufacture, import, several kinds of processing, use as a laboratory chemical, use as a bonding agent for solvent welding, use as a processing aid, plastic and rubber products manufacturing, and disposal. The chemical is still made, still shipped and still used. What ended, for most of the economy, is using it to take paint off things.
Do not read the November 2025 extension as a reprieve for shops. There was a compliance-date extension, it is real, and it has nothing to do with you. EPA's own summary of the final rule published 13 November 2025 describes it as
"an 18-month extension of the Workplace Chemical Protection Program (WCPP) and associated recordkeeping compliance dates for industrial or commercial laboratories that are not owned or operated by Federal agencies."
Laboratories. The stated reason is to avoid disrupting environmental monitoring for cleanup sites and wastewater treatment, university laboratories and law enforcement laboratories. It moved nothing about paint and coating removal, and it did not touch 751.107(b)(6).
The exposure numbers, and who they are actually for
You will see three figures quoted in trade coverage of this rule. They are real and they are in the regulation, but they belong to the uses that continue, not to the use that stopped:
- ECEL: 2 ppm, as an 8-hour time-weighted average
- EPA STEL: 16 ppm, over a 15-minute sampling period
- ECEL action level: 1 ppm, as an 8-hour TWA
For a body shop stripping paint, these are the wrong numbers to be thinking about, and that distinction matters. There is no exposure level at which the use becomes lawful again. A shop cannot monitor, ventilate or respirator its way into compliance with a prohibition. If methylene chloride is still being used to remove coatings, the answer is not a control plan; it is a different product.
What to actually do
Check the label, not the brand name. Look for methylene chloride, dichloromethane, or CAS number 75-09-2. Aircraft-type strippers were the common formulation and the one most likely to still be on a shelf.
Do not use it, and do not assume old stock is grandfathered. The prohibited act is the use.
Dispose of it as the chemical it is. Disposal is one of the conditions of use that continues under the WCPP, so there is a lawful route. Your hazardous waste contractor will know it; this is not something to pour out or put in the skip.
Expect the paperwork to have changed too. Since 28 January 2026 the safety data sheet accompanying methylene chloride has had to carry a prescribed statement about the restricted purposes for which it may still be distributed or processed. An SDS in your file that predates that is a sign the stock predates it as well.
None of this is the OSHA respirator standard. They are separate regimes with separate clocks, and the one an inspector is statistically most likely to cite you under is the other one. Federal OSHA wrote 91 respiratory protection citations in body shops last year, more than any other standard by a factor of nearly two.
How this was checked
The regulation was read from the current text of 40 CFR part 751, subpart B, retrieved on 16 August 2026 from eCFR's published API at the title's most recent issue date of 13 August 2026. Every date, cite and quotation above comes from that text.
The compliance-date extension was read from the Federal Register's API entry for document 2025-19881, Methylene Chloride; Regulation Under the Toxic Substances Control Act (TSCA); Compliance Date Extension, a final rule published 13 November 2025 and effective 15 December 2025. We also checked the Federal Register for any later EPA methylene chloride rule that might have moved the April 2026 date, and found none.
A note on method, since it affects what you should trust here: eCFR and FederalRegister.gov both return a bot-check page to automated requests to their websites, and that page states that programmatic access is via their developer APIs. We used the APIs, which is the route the operators designate, and did not attempt the website pages again.
This is federal law under TSCA. A state may add to it. No state can subtract from it.
- What Federal OSHA actually cites in body shops
- Refinish materials and paint procedures
- Corrosion protection after collision repair
General consumer information: not legal, insurance, or financial advice. Requirements, coverage, and practices vary by state, policy, and manufacturer.