CAS 67-56-1 · TSCA · United States of America

Methanol under TSCA

CH3OH · 甲醇

Status: Listed. Methanol is on the TSCA Inventory as a grandfathered pre-1979 substance and is currently listed as TSCA Active (post-2017 inventory reset). No PMN (Pre-Manufacture Notification) is required. NOTE: methanol is NOT on the EPA Risk Management Plan regulated toxic or flammable substances lists at 40 CFR 68.130 Tables 1 and 2 (verify against https://www.epa.gov/rmp/list-regulated-substances-under-rmp), and is NOT on the DEA Chemical Diversion Lists I or II at 21 CFR 1310.02 (verify against https://www.ecfr.gov/current/title-21/section-1310.02). The TSCA layer is the primary federal-chemical regime that applies; FDA denatured-alcohol formulas (27 CFR 21) and EPCRA Tier reporting are the practical compliance overlays.

Methanol is TSCA-clean and the federal layer is lighter than first-pass drafts asserted: methanol is NOT on DEA List I or II, NOT on EPA RMP Tables 1 or 2. Operational layers are EPCRA Tier I/II at 10,000 lb, FDA denatured-alcohol formulas (27 CFR 21) for downstream ethanol-denaturant uses, and state-level carbon-intensity scoring (CARB LCFS, Oregon LCFS) for fuel-blending applications. The China-US methanol lane is structurally substantial because the US is a net importer for MTO feedstock, biodiesel co-solvent, and fuel-blending applications, but the Section 301 List 3 25% additional duty plus Trinidad / Middle East / domestic shale-gas-route competition keeps Chinese methanol margin tight. Carbon-intensity scoring under California LCFS may shift the lane further toward Middle East gas-route supply over 2025-2030.

Listing and threshold

Substance Methanol (CAS 67-56-1), CH3OH
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: Acute Tox. 3 (oral, dermal, inhalation), Flammable Liquid 2, STOT SE 1 (eyes)
  • EPA RMP: methanol is NOT on the regulated toxic substances list at 40 CFR 68.130 Table 1 NOR on the regulated flammable substances list at Table 2 (verify against https://www.epa.gov/rmp/list-regulated-substances-under-rmp); methanol has NFPA flammability rating 3 and does not meet RMP Table 2 criteria
  • DEA chemical-diversion lists at 21 CFR 1310.02: methanol is NOT on List I (precursors to controlled substances) NOR on List II (essential chemicals incl. acetone / toluene / MEK / sulfuric acid / HCl) (verify against https://www.ecfr.gov/current/title-21/section-1310.02); no DEA Form 510 registration is required for methanol
  • CERCLA hazardous-substance reportable quantity (RQ) at 40 CFR 302.4: 5,000 lb (verify against https://www.ecfr.gov/current/title-40/section-302.4)

Restrictions and conditions of use

  • No TSCA-specific use restrictions for industrial methanol
  • OSHA PEL for methanol: 200 ppm 8-hour TWA (29 CFR 1910.1000 Table Z-1; verify against https://www.osha.gov/annotated-pels/table-z-1); ACGIH TLV 200 ppm with skin notation (non-binding industry guidance)
  • No DEA registration required for methanol (not on List I or II per 21 CFR 1310.02)
  • DOT and US Coast Guard rules govern transport (UN 1230, Class 3 + 6.1, PG II for both flammable and toxic hazards)
  • EPCRA (Emergency Planning and Community Right-to-Know Act) Tier I / Tier II reporting for sites storing >10,000 lb (methanol is on the EHS list at 40 CFR 355 Appendix A)
  • CARB (California Air Resources Board) methanol emission rules apply for industrial sites in California

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). Methanol is NOT on the DEA chemical-diversion lists at 21 CFR 1310.02 and NOT on the EPA RMP regulated lists at 40 CFR 68.130; the federal layer is TSCA, EPCRA Tier I/II for sites >10,000 lb, and FDA denatured-alcohol formulas (27 CFR 21) where methanol is used as an ethanol denaturant. State-level rules (CARB, Oregon LCFS, NY EHS, NJ Right-to-Know) add carbon-intensity and storage layers on top.

Required documents

  • TSCA Section 13 Import Certification statement on customs entry
  • OSHA-compliant SDS in 16-section GHS format with Acute Tox. 3 + Flam. Liq. 2 hazard statements
  • OSHA-compliant labelling on packaging
  • CDR filing every 4 years if site exceeds 25,000 lb/yr threshold (next cycle 2026)
  • EPCRA Tier I / Tier II reporting if site stores above 10,000 lb
  • FDA denatured-alcohol formula registration (27 CFR 21) if methanol is used as an ethanol denaturant in downstream consumer or industrial products

Common compliance traps

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

  • Common first-pass error: methanol is NOT on DEA List I or List II per 21 CFR 1310.02; no DEA Form 510 registration is required (verify at https://www.ecfr.gov/current/title-21/section-1310.02)
  • Common first-pass error: methanol is NOT on the EPA RMP regulated toxic or flammable substances lists at 40 CFR 68.130 Tables 1 and 2; no RMP plan is required (verify at https://www.epa.gov/rmp/list-regulated-substances-under-rmp)
  • Section 301 List 3 25% additional duty applies to Chinese-origin methanol (HS 2905.11.0000)
  • Coal-to-methanol US carbon-intensity policies (CARB LCFS in California, OR LCFS in Oregon) penalise high-carbon-intensity methanol imports for fuel-blending applications; Middle East methanol has lower CI than Chinese coal-route methanol
  • EPA SPCC (Spill Prevention Control and Countermeasure) plan required for bulk storage; do not commingle with hydrocarbon SPCC plans

Where to read next

For substance-level identifiers (formula, molecular weight, SMILES, InChIKey), GHS hazard profile, IMDG transport class, and full sourcing reference for methanol, see the CAS 67-56-1 sourcing reference.

For grade-by-grade buying notes, freight maths, supplier-tier pricing, and a worked landed-cost example, the methanol 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

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