CAS 1310-73-2 · TSCA · United States of America

Sodium hydroxide (caustic soda) under TSCA

NaOH · 氢氧化钠

Status: Listed. Sodium hydroxide is on the TSCA Inventory as a grandfathered pre-1979 substance and is currently listed as TSCA Active (post-2017 inventory reset; substances actively in commerce that filed Form A by the deadline). No PMN (Pre-Manufacture Notification) is required for new manufacture or import.

NaOH is the cleanest industrial chemical to import to the US from a TSCA standpoint: listed, active, no Section 6 risk-evaluation flag, no PMN. The work is routine: TSCA Section 13 certification on the customs entry, OSHA-compliant SDS + labelling, CDR reporting every 4 years if site volume crosses 25,000 lb/yr. Section 301 List 3 25% on Chinese-origin NaOH is the operator-relevant cost layer; TSCA itself is not a barrier.

Listing and threshold

Substance Sodium hydroxide (caustic soda) (CAS 1310-73-2), NaOH
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 triggers reporting in the next CDR cycle

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, 29 CFR 1910.1200) applies as Skin Corrosive Cat 1A
  • NaOH is NOT on the EPA Risk Management Plan (RMP) regulated substances list at 40 CFR 68 Appendix A; RMP does not apply (verify against https://www.epa.gov/rmp/list-regulated-substances-under-rmp)

Restrictions and conditions of use

  • No TSCA-specific use restrictions for industrial caustic soda
  • OSHA workplace exposure ceiling: 2 mg/m³ (29 CFR 1910.1000 Table Z-1; verify against https://www.osha.gov/annotated-pels/table-z-1)
  • NaOH is NOT on the California Proposition 65 list (verify against https://oehha.ca.gov/proposition-65/proposition-65-list); no Prop 65 warning label is required for caustic-soda shipments to CA
  • DOT and US Coast Guard rules govern transport (UN 1823 solid, UN 1824 liquid solution, both Class 8 PG II)

Importer obligations

TSCA is a self-certification regime: importers attest at customs entry that the imported substance is listed on the TSCA Inventory or qualifies for a Section 12(b) exemption. The TSCA Section 13 Import Certification statement is filed via the importer's customs broker on the entry summary (CBP Form 7501). No upfront EPA filing or fee is required for a listed-Inventory substance like NaOH.

Required documents

  • TSCA Section 13 Import Certification statement on customs entry
  • OSHA-compliant SDS (Safety Data Sheet) in 16-section GHS format
  • OSHA-compliant labelling on packaging
  • CDR filing every 4 years if site exceeds 25,000 lb/yr threshold (next cycle 2026)

Common compliance traps

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

  • Misclassifying NaOH as a "byproduct" or "non-isolated intermediate" to avoid CDR reporting; EPA inspectors check this against shipping records and tank-farm inventory
  • NaOH is not on Cal Prop 65 (verify against oehha.ca.gov); do not add Prop 65 warnings to consumer-grade bottling of caustic-soda solutions
  • NaOH is not on the EPA RMP regulated-substances list at 40 CFR 68 App A (verify against epa.gov/rmp); RMP does not apply, but state-level hazardous-storage rules still do (NY, NJ, CA EHS thresholds)
  • Some US state-level rules (NY, CA) require additional importer registration beyond Federal TSCA

Where to read next

For substance-level identifiers (formula, molecular weight, SMILES, InChIKey), GHS hazard profile, IMDG transport class, and full sourcing reference for sodium hydroxide (caustic soda), see the CAS 1310-73-2 sourcing reference.

For grade-by-grade buying notes, freight maths, supplier-tier pricing, and a worked landed-cost example, the sodium hydroxide (caustic soda) 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.

Read next

Cross-jurisdiction profile and sourcing references

Referenced in

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