Washington, D.C. (Dec. 3, 2025) — The American Chemistry Council’s (ACC) Formaldehyde Panel today issued the following statement in response to the U.S. Environmental Protection Agency’s (EPA) decision to revisit its Toxic Substances Control Act (TSCA) risk evaluation for formaldehyde:
“We welcome EPA’s updated draft risk calculations and its decision to reevaluate key scientific inputs in the TSCA formaldehyde risk evaluation. EPA’s revised approach reflects meaningful consideration of the recommendations from the Scientific Advisory Committee on Chemicals (SACC), the Human Studies Review Board (HSRB), and other authoritative bodies, and strengthens alignment with TSCA’s requirements to use the best available science and the weight of scientific evidence.
“Any assessment of formaldehyde must begin with the best available science. Formaldehyde is a natural part of our world and, through decades of responsible innovation and regulation, is essential to critical applications for housing, agriculture, transportation, healthcare, and national security. Formaldehyde technologies have broad roles in the economy, supporting over 1.5 million jobs and $1.6 trillion in manufacturing shipments and other economic output in 2023 in the United States.
“The final risk evaluation for formaldehyde did not fully align with statutory requirements for scientific quality, peer review, or engagement with public and interagency comments. It relied heavily on an assessment from EPA’s Integrated Risk Information System (IRIS) program, which has faced questions about its transparency, authorization, and scientific methods. As a result, a flawed evaluation may lead to regulations that are more restrictive than necessary for this important chemistry, with potential implications for the U.S. economy and domestic production.
“EPA’s updated draft analysis incorporates important scientific principles long supported by the Panel and other scientific bodies, including the recognition ofaportal-of-entry threshold mode of action,the finding that sensory irritation is the most sensitive endpoint and protective of effects for all durations, that formaldehyde does not follow Haber’s Law because effects are driven by concentration rather than duration, and that controlled human exposure studies provide stronger scientific rigor than observational epidemiology. These updates help align the TSCA process with the best available science and improve the scientific foundation of EPA’s evaluation.
“The Panel has consistently supported a transparent and scientifically sound approach to chemical risk assessment. In prior comments, we noted concerns with the earlier evaluation, including the importance of using the best available science and better accounting for real-world exposure scenarios.
“Formaldehyde is integral to modern life, and businesses and families rely on the important products it enables. Without robust formaldehyde manufacturing in the United States, we could face increased product prices, reduced economic output, and a loss of the U.S.’s competitive edge.
“We remain committed to working constructively with the EPA and all stakeholders throughout this process. Our goal is to support a balanced and credible risk evaluation that protects public health while recognizing the important contributions of this building block chemistry.”
