Published June 4 2025 • Updated as litigation progresses

The U.S. Environmental Protection Agency’s 2024 final rule on perchloroethylene (perc / PCE) under the Toxic Substances Control Act (TSCA) is not on hold. While lawsuits are winding their way through the courts, all compliance dates remain enforceable unless a judge or a future EPA amendment says otherwise.

Below is your quick-start guide to the rule’s hard deadlines, what the pending litigation really means, and the smartest next moves for professional cleaners.

1. What’s Still in Force?

• No legal stay — The Fifth Circuit has not paused the rule’s requirements.

• Full compliance timeline — Both the 2025 machine-purchase ban and the 2034 absolute prohibition remain on the books.

• Ongoing litigation — Industry groups are challenging several provisions, but any change will require an official court order or a new EPA rulemaking.

2. Perc Phase-Out Timeline at a Glance

Deadline	Requirement	Impact on Your Plant
June 16 2025	No perc in any dry-cleaning machine purchased or leased after this date.	All new equipment must operate on alternative solvents or wet-cleaning processes. Leasing counts!
December 20 2027	Perc banned in 3rd-generation machines and related spot-cleaning.	Older transfer and vented units must be decommissioned, replaced, or converted.
December 19 2034	Full prohibition on all perc use in dry-cleaning and spotting.	Fourth- and fifth-generation machines must be emptied, removed, or converted; no spotters may use perc.

3. The Litigation Landscape—Should You Wait?

Short answer: No.

Although several industry coalitions have filed petitions for review, the court has not stayed the rule. EPA has indicated it may propose targeted amendments later in 2025, but any revisions must go through notice-and-comment rulemaking—meaning new requirements would take at least several months (most likely a year or more) to become final. In the meantime, inspectors will enforce the original deadlines.

4. Action Steps You Can Take Today

1. Freeze perc machine purchases. If you need a replacement, choose hydrocarbon, siloxane, liquid CO₂, or professional wet cleaning.

2. Map your equipment life cycle. Calculate depreciation so every remaining perc machine is off-line before December 19 2034.

3. Document your transition plan. Keep written records of solvent tests, equipment quotes, and staff training to demonstrate good-faith compliance during audits.

4. Educate customers. Use “perc-free” marketing to attract health- and eco-conscious clients—and to offset conversion costs with premium positioning.

5. Stay informed. Subscribe to EPA’s PCE list-serve and follow the docket for FabriClean Supply et al. v. EPA (5th Cir. No. 25-60006).

5. Frequently Asked Questions

If the rule changes, will EPA push back the 2025 date?

Only if an amended final rule is published before June 16 2025 or a court issues a stay—neither has happened. Plan as though the ban starts on schedule.

Can I keep a perc machine I already own?

Yes, but only until December 19 2034 and only if you meet all monitoring, record-keeping, and engineering-control requirements spelled out in the 2024 rule and EPA’s Compliance Guide.

Is professional wet-cleaning automatically compliant?

Wet-cleaning avoids perc restrictions, but you must still meet applicable wastewater, energy, and OSHA requirements.

6. Need More Details?

• Direct questions to: PCE.TSCA@epa.gov (Existing Chemicals Risk Management Division, EPA).

• Industry support: Contact the National Cleaners Association at info@nca-i.com or 212-967-3002 for help with planing for a new solvent.