CAS 105-60-2 · TSCA · United States of America

Caprolactam under TSCA

C6H11NO · 己内酰胺

Status: Listed. Caprolactam is on the TSCA Inventory as a grandfathered pre-1979 substance and is currently listed as TSCA Active. No PMN is required. **Active US AD/CVD case status on Chinese-origin caprolactam is unverified at audit date 2026-05-09**: prior dataset drafts cited case number A-570-001 / C-570-002 with ITC investigations 731-TA-1310 / 701-TA-565 and a China-wide rate of ~262%, but A-570-001 is the case number for potassium permanganate from China (established 1984), not caprolactam, and the cited investigation numbers and rates could not be confirmed against primary sources. Verify whether an active US AD/CVD order on Chinese caprolactam exists by querying https://access.trade.gov/ before invoicing; AD/CVD cash deposit and case routing must be based on the actual current order, not the prior dataset assertion. Section 301 List 3 25% additional duty applies on Chinese-origin caprolactam (HS 293371) regardless of AD/CVD status.

The US caprolactam lane carries a Section 301 List 3 25% additional duty on Chinese-origin caprolactam (HS 293371). The prior dataset draft asserted an active US AD/CVD order (China-wide rate ~262%, individual rates 27-58%, case A-570-001 / C-570-002) but at audit date 2026-05-09 those specific case numbers and rates could not be verified against primary sources (notably A-570-001 is the case number for potassium permanganate from China, not caprolactam). Verify current US AD/CVD status against https://access.trade.gov/ before invoicing. US is comparatively self-sufficient in caprolactam through domestic supply (AdvanSix Hopewell, Honeywell Frankford); AdvanSix Hopewell is also the largest US AS producer through the same caprolactam-coupled by-product chain.

Listing and threshold

Substance Caprolactam (CAS 105-60-2), C6H11NO
Regime US Toxic Substances Control Act (TSCA), administered by EPA
Jurisdiction United States of America
Status Listed
Tonnage threshold CDR (Chemical Data Reporting) threshold: 25,000 lb (11,340 kg) manufactured or imported per site per year

Classifications under this regime

  • NOT subject to TSCA Section 4 test rule
  • NOT currently subject to TSCA Section 6 unreasonable-risk evaluation
  • NOT on the TSCA Section 5(a)(2) Significant New Use Rule list
  • OSHA Hazard Communication Standard (HCS): GHS H302 / H315 / H319 / H332 / H335
  • OSHA PEL: not specifically established (general dust nuisance applies)
  • NIOSH REL: 1 mg/m³ TWA dust
  • NOT on EPA RMP threshold list
  • NOT on DEA List I or List II
  • NOT on California Proposition 65 list (verify against OEHHA https://oehha.ca.gov/proposition-65/proposition-65-list before relying on negative listing)
  • TRI Section 313: caprolactam is on TRI listed substance reporting requirement (added 1995)
  • IARC: caprolactam was Group 4 in Monograph Vol 71 (1999); IARC abolished Group 4 in 2019 (verify current classification at https://monographs.iarc.who.int/list-of-classifications); apply ACGIH TLV and NIOSH REL for workplace controls

Restrictions and conditions of use

  • No TSCA-specific use restrictions for caprolactam
  • OSHA-compliant SDS and workplace HazCom training required
  • US AD/CVD status on Chinese-origin caprolactam unverified at audit date 2026-05-09 (prior dataset drafts cited specific case numbers and rates that could not be confirmed against access.trade.gov; verify before invoicing)
  • Section 301 List 3 25% additional duty applies on top of AD/CVD on Chinese-origin caprolactam (HS 293371)
  • TRI Section 313 Form R annual reporting required for facilities above 25,000 lb manufacture / 10,000 lb other-use thresholds
  • FDA 21 CFR 177.1500 approves nylon-6 (with caprolactam monomer) for food-contact applications subject to monomer residue limits

Importer obligations

TSCA is a self-certification regime: importers attest at customs entry that the substance is on the TSCA Inventory. The TSCA Section 13 Import Certification statement is filed via the customs broker on the entry summary (CBP Form 7501). For caprolactam specifically, current US AD/CVD status on Chinese-origin product needs to be verified against access.trade.gov before invoicing (prior dataset drafts cited an active case A-570-001 / C-570-002 with rates ~262%, but those specifics could not be confirmed and A-570-001 is the case number for potassium permanganate not caprolactam). Section 301 List 3 25% additional duty applies regardless of AD/CVD status. US domestic supply is via AdvanSix Hopewell and Honeywell Frankford.

Required documents

  • TSCA Section 13 Import Certification statement on customs entry
  • OSHA-compliant SDS (Safety Data Sheet) in 16-section GHS format
  • AD/CVD producer-specific margin documentation for Customs Form 7501 entry (where active AD/CVD order applies; verify current US AD/CVD status on Chinese-origin caprolactam at https://access.trade.gov/ before relying on the prior-draft case-number citation)
  • AD/CVD cash deposit at entry equivalent to producer-specific rate (where active order applies)
  • TRI Form R annual report (where site exceeds 25,000 lb manufacture / 10,000 lb other-use thresholds)
  • CDR filing every 4 years if site exceeds 25,000 lb/yr threshold (next cycle 2026)
  • FDA 21 CFR 177.1500 compliance documentation for nylon-6 food-contact downstream applications

Common compliance traps

The pitfalls that have bitten importers on this lane in the past. None of these is theoretical.

  • US AD/CVD status on Chinese caprolactam unverified at audit date; the prior dataset assertion of an active case (China-wide rate ~262%, individual rates 27-58%) could not be corroborated against access.trade.gov in the audit pass. Section 301 List 3 25% additional duty applies on Chinese-origin caprolactam regardless. Verify current AD/CVD status before invoicing
  • AD/CVD periodic administrative reviews (annual) can adjust producer-specific rates upward or downward
  • AdvanSix Hopewell (Virginia) is largest US domestic caprolactam producer; Honeywell Frankford (Pennsylvania) is secondary. AdvanSix is also major US AS producer (caprolactam by-product chain)
  • TRI Form R annual reporting is the most-missed compliance step for new importers
  • US is comparatively self-sufficient in caprolactam through AdvanSix Hopewell + Honeywell Frankford domestic supply; imports for specialty applications flow despite AD/CVD
  • NOT on Prop 65, NOT on EPA RMP, NO DEA scheduling. Caprolactam is regulatorily lighter than phenol upstream (which IS on RMP and is more hazardous)
  • Acute Tox. 4 oral / inhalation + STOT SE 3 hazard drives OSHA HazCom training; nylon-6 polymerisation-reactor handling at downstream facilities (Invista, BASF, DSM, Lanxess, Domo) requires engineered dust and vapour controls

Where to read next

For substance-level identifiers (formula, molecular weight, SMILES, InChIKey), GHS hazard profile, IMDG transport class, and full sourcing reference for caprolactam, see the CAS 105-60-2 sourcing reference.

For grade-by-grade buying notes, freight maths, supplier-tier pricing, and a worked landed-cost example, the caprolactam cornerstone hub covers the full sourcing chain.

For the structure and history of TSCA, see the TSCA glossary entry.

Need cross-jurisdiction compliance support on this substance? Run it through the REACH / TSCA / IECSC / AICIS / K-REACH checker, or send us the substance and the destination and we will quote FOB China and CIF / DDP landed including the regulatory work on the destination side.

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Cross-jurisdiction profile and sourcing references

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