CAS 7664-93-9 · TSCA · United States of America

Sulfuric acid under TSCA

H2SO4 · 硫酸

Status: Listed. Sulfuric acid 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 for new manufacture or import. Sulfuric acid is also subject to DEA List II chemical-precursor controls (21 CFR 1310). NOTE: anhydrous sulfuric acid (CAS 7664-93-9) is NOT on the EPA Risk Management Plan regulated toxic substances list at 40 CFR 68.130 Table 1 (verify against https://www.epa.gov/rmp/list-regulated-substances-under-rmp); only oleum / fuming sulfuric acid (CAS 8014-95-7, TQ 10,000 lb) and sulfur trioxide (CAS 7446-11-9, TQ 10,000 lb) are RMP-listed.

Sulfuric acid is TSCA-clean but operationally heavier than NaOH due to the DEA List II and EPCRA Tier reporting layers. Note: anhydrous sulfuric acid is NOT EPA RMP-regulated (only oleum and SO3 are); a common error is filing an unnecessary RMP plan for plain H2SO4 storage. The China-US sulfuric lane is small relative to caustic (US has abundant domestic sulfur supply from petroleum desulfurisation) but specialty grades (battery-grade, electronic-grade, fuming oleum) do flow from China. Importing oleum specifically DOES trigger RMP at the 10,000 lb TQ. The Section 301 List 3 25% additional duty is the operator-relevant cost layer.

Listing and threshold

Substance Sulfuric acid (CAS 7664-93-9), H2SO4
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: Skin Corrosive Cat 1A, Carcinogen 1A (mists)
  • EPA RMP regulated-substances list at 40 CFR 68.130 Table 1: anhydrous sulfuric acid (7664-93-9) is NOT listed; only oleum (8014-95-7, TQ 10,000 lb) and SO3 (7446-11-9, TQ 10,000 lb) are RMP-regulated (verify against https://www.epa.gov/rmp/list-regulated-substances-under-rmp)
  • DEA List II chemical (21 CFR 1310.02(b)): sulfuric acid is on the precursor list; threshold reporting and recordkeeping per 21 CFR 1310.04
  • CERCLA hazardous-substance reportable quantity (RQ) at 40 CFR 302.4: 1,000 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 sulfuric acid
  • OSHA PEL for sulfuric acid: 1 mg/m³ 8-hour TWA (29 CFR 1910.1000 Table Z-1; verify against https://www.osha.gov/annotated-pels/table-z-1); ACGIH TLV 0.2 mg/m³ for thoracic fraction (non-binding industry guidance)
  • DEA List II reporting required for transactions above threshold (per state, typically 250-2,500 gal); methamphetamine-precursor concern drives state-level regulation
  • DOT, US Coast Guard, and pipeline rules govern transport (UN 1830 concentrated, UN 2796 spent acid, UN 1832 spent battery acid, all Class 8 PG II)
  • EPCRA (Emergency Planning and Community Right-to-Know Act) Tier I / Tier II reporting for sites storing >500 lb

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 sulfuric acid specifically, DEA List II registration is the practitioner-facing layer: any importer or distributor must file DEA Form 510 and maintain transaction records under 21 CFR 1310. Note that anhydrous sulfuric acid is NOT on the EPA RMP regulated toxic substances list (only oleum and SO3 are); but EPCRA Tier I / II reporting applies for sites storing above 500 lb.

Required documents

  • TSCA Section 13 Import Certification statement on customs entry
  • DEA List II registration (Form 510) for sulfuric acid distribution above transaction threshold
  • 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)
  • EPA RMP submitted plan ONLY applies to oleum (8014-95-7) or SO3 (7446-11-9) storage above 10,000 lb TQ; anhydrous sulfuric acid (7664-93-9) is not RMP-regulated (verify at https://www.epa.gov/rmp/list-regulated-substances-under-rmp)
  • EPCRA Tier I / Tier II reporting if site stores above 500 lb (sulfuric acid is on the EHS list at 40 CFR 355 Appendix A)

Common compliance traps

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

  • DEA List II reporting is triggered by transaction size, not annual aggregate; missed transaction reports get auditors' attention
  • Common first-pass error: anhydrous sulfuric acid (7664-93-9) is NOT on the EPA RMP regulated toxic substances list at 40 CFR 68.130 Table 1; only oleum (8014-95-7) and SO3 (7446-11-9) trigger RMP. Do not file an RMP plan for plain H2SO4 storage; do file under EPCRA Tier II at 500 lb
  • Section 301 List 3 25% additional duty applies to Chinese-origin sulfuric acid (HS 2807.00.0000)
  • Texas, California, Indiana have additional state-level chemical-precursor reporting beyond Federal DEA
  • Used / spent battery acid (UN 1832) has separate hazardous-waste handling rules under RCRA; do not commingle waste-stream classifications

Where to read next

For substance-level identifiers (formula, molecular weight, SMILES, InChIKey), GHS hazard profile, IMDG transport class, and full sourcing reference for sulfuric acid, see the CAS 7664-93-9 sourcing reference.

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