6PPD Testing for Products – FAQ

Understanding

What is 6PPD and why is it regulated?

6PPD (N-(1,3-dimethylbutyl)-N′-phenyl-p-phenylenediamine, CAS 793-24-8) is an antidegradant – an antiozonant and antioxidant – that has been used since the 1960s in virtually every motor vehicle tire, as well as in other rubber goods. It works by migrating to the rubber surface, where it preferentially reacts with ozone and reactive oxygen species, forming a protective film that prevents the tire from cracking and degrading. It is therefore considered critical to tire safety and durability. 6PPD itself is not the primary regulatory concern: it is regulated because its ozone-reaction product, 6PPD-quinone, is released to the environment in tire road wear particles (TRWP) and is acutely lethal to certain fish. Regulators in California, Washington State and at the US EPA have consequently begun formal processes targeting 6PPD in tires.

What is 6PPD-quinone and why is it harmful?

6PPD-quinone (6PPD-q, CAS 2754428-18-5) is a transformation product formed when 6PPD reacts with ozone and oxygen at the tire surface. As tires wear against the road, the particles they shed carry 6PPD and 6PPD-q; rain then washes these particles from roads into streams and other water bodies. A 2021 publication in Science (Tian et al.) identified 6PPD-q as the cause of “urban runoff mortality syndrome” – the death of adult coho salmon returning to spawn in urban streams of the US Pacific Northwest after storm events. Its acute toxicity to sensitive species is extraordinary: the reported 24-hour LC50 for juvenile coho salmon is about 95 ng/L, and a later study found early-life-stage coho even more sensitive (24-h LC50 of 41 ng/L), roughly three orders of magnitude more sensitive than juvenile Chinook in the same study. Coastal cutthroat trout have since been identified as the second most sensitive species tested. In June 2024, US EPA issued a final (non-regulatory) acute aquatic-life screening value of 11 ng/L for 6PPD-q in freshwater. Research has also detected 6PPD-q in human urine and cerebrospinal fluid, prompting expanding toxicological study, though the aquatic effects remain the established regulatory driver.

Why is 6PPD being banned or restricted?

Because concentrations of 6PPD-q measured in salmon-bearing urban waterways after storms can reach or exceed the levels shown to kill coho salmon in the laboratory, and affected populations include species listed as endangered or threatened. In California, DTSC documented 6PPD-q in state waterways at levels above laboratory-lethal concentrations for coho and noted the significant impact of coho losses on Native American tribes; the loss of salmon also affects treaty-reserved tribal fishing rights in the Pacific Northwest, which is why the Yurok, Port Gamble S’Klallam and Puyallup Tribes petitioned US EPA under the Toxic Substances Control Act (TSCA) to address 6PPD in tires – a petition EPA granted. Importantly, no jurisdiction has yet enacted an outright ban (see Regulatory Trend below); the current instruments are alternatives-analysis mandates, priority-chemical designations, water-quality values and rulemaking processes designed to drive the industry toward a safer, performance-equivalent substitute.

Requirements

Do I need to test for 6PPD in my products?

There is currently no law that imposes a numeric 6PPD content limit on products, so “testing” obligations are indirect and depend on who you are. Tire manufacturers selling in California: motor vehicle tires containing 6PPD became a Priority Product under the Safer Consumer Products regulations on October 1, 2023; manufacturers had to file Priority Product Notifications (by November 30, 2023) and submit Alternatives Analyses (preliminary AAs were filed March 29, 2024, with final reports to follow) – processes that require knowing and documenting 6PPD use in your formulations. Tire manufacturers selling in Washington: 6PPD is a designated priority chemical and tires containing it a priority consumer product under Safer Products for Washington; the Department of Ecology is scheduled to determine regulatory actions and adopt implementing rules by June 2028, and Washington has adopted an aquatic-life water-quality criterion for 6PPD-q (2024). Other rubber-product manufacturers: no verified 6PPD-specific product regulation applies today, but 6PPD is used beyond tires, and DTSC proposed in July 2025 to add PPD derivatives to its Candidate Chemicals list – so formulation knowledge and analytical capability are prudent. Stormwater/environmental programs: monitoring for 6PPD-q in water is increasingly expected, using EPA’s draft Method 1634. In short: if you make tires for the US market, yes – you need analytical visibility of 6PPD and 6PPD-q; for other rubber products it is currently risk management rather than legal mandate.

What industries are affected by 6PPD regulations?

The tire industry is the direct target: California’s Priority Product regulation and Washington’s priority-product designation both apply to motor vehicle tires containing 6PPD, and compliance duties fall first on tire manufacturers (domestic and foreign) whose products enter those markets. Adjacent sectors affected in practice include: the broader rubber goods industry (6PPD is used as an antiozonant/antioxidant in rubber products generally); recycled-tire product sectors – Washington’s Safer Products Cycle 2 draft report (November 2024) highlighted artificial turf (which commonly uses recycled tire crumb) alongside tires as priority products; chemical suppliers of antidegradants, who are developing alternatives (e.g., Flexsys’ replacement program, reported by Rubber News to have narrowed to two candidate molecules); stormwater utilities and transportation agencies, which face monitoring and mitigation expectations; and testing laboratories supporting all of the above.

Are there alternatives to 6PPD?

Not yet a proven, widely available one – DTSC itself stated when the California regulation took effect that 6PPD plays a crucial role in tire safety and that no widely available safer alternatives currently exist. The search is well underway, though: through California’s Preliminary Alternatives Analysis process, tire manufacturers collectively selected 21 candidate antidegradants for detailed evaluation in the Final Alternatives Analysis; a USTMA-coordinated consortium of more than 30 tire manufacturers screened some 60 candidates down to 7 warranting further investigation, with a final report expected in August 2026. A key complication is the risk of “regrettable substitution”: several candidates are structurally related para-phenylenediamine (PPD) derivatives that can also form quinones on reaction with ozone and may pose similar concerns (although evidence suggests some alternative PPDs and their quinones may be less hazardous to coho than 6PPD-q). Regulators are responding – DTSC proposed adding PPD derivatives to its Candidate Chemicals list (July 2025), and Washington’s 2026 phase-out bills expressly targeted “regrettable 6PPD substitutes” as well. Non-chemical mitigation avenues discussed by regulators and researchers include stormwater treatment (e.g., biofiltration/green infrastructure), tire coatings, and slowing the rate at which 6PPD leaches from wear particles – the approach Ace Laboratories’ leachability research is designed to support.

Execution

How do you test for 6PPD in rubber?

For the content of 6PPD (and related antidegradants) in a rubber compound itself, laboratories use solvent extraction of the vulcanizate followed by chromatographic to identify and quantify the antidegradant package. There is no single legally mandated standard method for 6PPD content in rubber comparable to the pharmaceutical nitrosamine framework, so labs apply validated in-house or compendial chromatographic approaches. In environmental and TRWP research, cryogenically milled tire tread (CMTT), the reference material recommended by the US Tire Manufacturers Association, is commonly used as a well-characterized surrogate for real tire tread. Note that most regulatory attention focuses on what leaves the rubber (6PPD-q in water) rather than what is in it, which is where migration testing comes in.

How do you test its migration into water?

Ace Laboratories developed a proprietary method for analyzing 6PPD and 6PPDq migration into water. The workflow has three stages.

  1. Generate representative wear particles: a tread compound is mixed and molded, then synthetic TRWP are produced. Methods used across the industry include DIN abrasion testing (ISO 4649/ASTM D5963), an RTM friction tester running a wheel over an asphalt-surfaced track with a rain-flush and runoff collection basin, USTMA-recommended cryo-grinding to produce CMTT, and a Lambourn abrasion tester used as a field performance simulator, which varies load and slip ratios and has a built-in particle collection system, giving a particle-morphology spread closer to normal driving.
  2. Weather and leach: when the target analytes are 6PPD/6PPD-q, the ground particles are first exposed to ozone for a period to form the transformation products, then soaked in water and agitated; when transformation products are not the target, samples go directly to the water soak and agitation. Particles are then filtered out and the water is analyzed.
  3. Analyze the leachate: Ace analyzes the filtered water by GC-MS using solid-phase micro-extraction (SPME), and separately runs elemental analysis by ICP after EPA digestion methods. Timing is critical, every sample must reach the instrument at the same interval after agitation because the concentration curve is highly time-sensitive, especially for 6PPD, whose half-life is at roughly 75 days in soil but only about three hours in water.

Regulatory Trend

Is 6PPD banned in the US or EU?

No – 6PPD is not banned in either the US or the EU as of September 2026. In the US, EPA granted the 2023 TSCA petition from the Yurok, Port Gamble S’Klallam and Puyallup Tribes and published an Advance Notice of Proposed Rulemaking under TSCA Section 6 (November 2024), alongside an agency-wide 6PPD/6PPD-q Action Plan, draft Method 1634 and final aquatic-life screening values – investigative and framework steps, not a ban. In the EU, 6PPD remains a REACH-registered substance in use; according to ETRMA (2025), the Austrian and Dutch chemical authorities are preparing a REACH restriction proposal on 6PPD in tires, which would start a restriction process. Separately, the EU’s Euro 7 regulation creates the first legal framework for tire abrasion (particle emission) limits, using test methods being developed at UN WP.29, with limits targeted for agreement in June 2026 for passenger-car tires (2028/2030 for heavier categories, and a fallback empowering EU-level limits by end-2030) – this addresses TRWP quantity rather than 6PPD chemistry itself.

What states are regulating 6PPD?

California: the first mover – DTSC listed motor vehicle tires containing 6PPD as a Priority Product under the Safer Consumer Products program, effective October 1, 2023 (the seventh priority product under the Green Chemistry law). Manufacturers filed Priority Product Notifications by November 30, 2023 and preliminary Alternatives Analyses on March 29, 2024; final AA reports evaluating 21 selected alternatives follow. In July 2025 DTSC proposed adding PPD derivatives to the Candidate Chemicals list to guard against regrettable substitutions.

Washington: the first state to pass 6PPD-specific legislation – SSB 5931 (enacted March 2024) added 6PPD as a priority chemical and tires containing it as a priority consumer product under Safer Products for Washington (RCW 70A.350); Ecology must determine regulatory actions and adopt rules by June 2028, and if a safer, feasible alternative is identified it could restrict the sale of tires containing 6PPD. Washington also adopted an aquatic-life water-quality criterion for 6PPD-q (2024) and published its Cycle 2 priority-products work covering tires and artificial turf. In the 2026 session, companion bills HB 2421 and SB 6119 proposed prohibiting the manufacture, sale and distribution of new vehicle tires containing 6PPD or regrettable substitutes from January 1, 2035 (with per-tire mitigation fees); the bills advanced through House committees but did not pass before the session ended – supporters have said they will return with revised legislation.

No other state was verified to have enacted 6PPD-specific product regulation as of this writing; activity elsewhere is largely monitoring- and stormwater-focused, coordinated through the EPA Action Plan and the Interstate Technology and Regulatory Council (ITRC) 6PPD workgroup. Given how quickly this area is moving, state-level status should be re-checked against DTSC, Washington Ecology and EPA sources before compliance decisions.

If you’d like to learn more, ACE Laboratories today at 330.577.4088. Or, contact us anytime so we can learn about your needs.