EPA Proposes Delisting Dow’s 2-BEB from Hazardous Air Pollutants

Jan. 8 — WASHINGTON — The U.S. Environmental Protection Agency is proposing to remove a Dow Chemical-produced compound from its list of hazardous air pollutants.

This rarely used regulatory action could ease federal restrictions on some industrial and consumer products but is already raising concerns among environmental advocates.

In a proposed rule published in late December, EPA Administrator Lee Zeldin said the agency intends to grant a petition filed by Dow in 2019 to delist 2-Butoxyethyl Benzoate, commonly known as 2-BEB, from the Clean Air Act's hazardous air pollutant, or HAP, list.

Dow manufactures the chemical for use in paints, coatings, printing inks, adhesives and some cosmetics.

Hazardous air pollutants are regulated under the Clean Air Act based on evidence linking them to cancer, respiratory illness or other serious health effects. Congress listed nearly 190 substances when it amended the law in 1990, and facilities that emit them are subject to strict federal controls.

In more than three decades, EPA has removed only four substances from the list.

EPA officials said the proposed change reflects a review of newer scientific data indicating that 2-BEB does not meet the statutory criteria for classification as a hazardous air pollutant.

"If finalized, this action would allow industry to use 2-BEB in formulations in place of other similar chemicals without increasing hazardous air pollutant emissions," the agency said in a summary of the proposal.

According to EPA and industry analyses, 2-BEB is primarily used as a solvent and plasticizer that improves the flow and stability of liquid products. The agency found it has low volatility — meaning it does not readily evaporate into the air — and available studies suggest low toxicity at typical exposure levels. It is not classified as a known or probable human carcinogen.

Dow argued in its petition that customers "strongly prefer to avoid using any listed HAP" and that the designation discouraged use of 2-BEB even when it could replace more hazardous chemicals. The company also said delisting could lead to environmental benefits by encouraging substitution away from solvents with higher emissions or toxicity.

The petition process stretched over several years. EPA initially determined the 2019 petition was incomplete and requested additional data, which Dow provided through 2021. EPA deemed the petition complete later that year before issuing its proposed approval in December 2025.

Under the Clean Air Act, EPA may delist a substance if there is adequate information showing its emissions and environmental presence "may not reasonably be anticipated" to cause adverse health or environmental effects.

Environmental advocacy groups have historically been skeptical of delisting actions, warning they can weaken long-standing Clean Air Act protections. Critics argue that removing a chemical from the HAP list can reduce oversight and emissions controls, potentially increasing cumulative exposure — particularly in communities already burdened by industrial pollution.

Some environmental groups have also raised concerns about language in EPA's proposal describing a more "streamlined" approach to reviewing future delisting petitions, which they fear could limit opportunities for public input or lower the bar for removing chemicals from the list.

EPA officials say delisting decisions require extensive scientific review and emphasize that many chemicals were originally listed in 1990 based on broad chemical categories rather than individual risk assessments.

The proposed rule does not immediately change any regulations.

EPA is accepting public comments through Feb. 20, and a virtual public hearing may be held if requested. After reviewing comments, the agency will decide whether to finalize the delisting of 2-BEB.

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