In January 2025, the U.S. Environmental Protection Agency (EPA) expanded the Toxic Release Inventory (TRI) by adding nine additional per- and polyfluoroalkyl substances (PFAS), in accordance with the National Defense Authorization Act (NDAA) for Fiscal Year 2020. This update increases the total number of PFAS listed on the TRI to 205.

The specifics of the added substances are as follows:

Annual Updates to TRI Reporting for PFAS

The National Defense Authorization Act (NDAA) establishes a framework for incorporating per- and polyfluoroalkyl substances (PFAS) into the Toxic Release Inventory (TRI) and addresses related EPA activities. Starting with the 2025 reporting year, nine newly listed PFAS will be included in TRI reports, which are due by July 1, 2026.

The EPA has announced that PFAS, classified as “chemicals of special concern,” will no longer qualify for minimum exemption thresholds under TRI supplier reporting. Consequently, all producers of the 205 PFAS listed in the TRI must report concentration information to downstream facilities, even when PFAS concentrations in a product or mixture fall below 1%.

The U.S. Toxic Release Inventory (TRI)

Under Section 313 of the Emergency Planning and Community Right-to-Know Act (EPCRA), the EPA developed the TRI to inform the public about toxic chemical releases from industrial facilities and to enhance awareness of environmental pollution. The TRI currently tracks 794 individual substances and 33 substance categories.

Expanded PFAS Monitoring in TRI

Recent updates to PFAS monitoring under TRI include:

• 2022: Four additional PFAS listed.

• 2023: Nine additional PFAS listed.

• 2024: Seven additional PFAS listed in one update and nine more in a subsequent update.

TRI Reporting Requirements

Who Must Report?

Companies are required to submit a TRI report if they meet the following criteria:

• Operate in specific industries (e.g., manufacturing, mining, power generation) covered under TRI’s NAICS codes.

• Employ at least 10 full-time workers.

• Exceed these annual usage thresholds for any TRI-listed chemical:

  • Manufacture or import more than 25,000 pounds,

  • Process more than 25,000 pounds, or

  • Use more than 10,000 pounds in other ways.

Reporting Deadlines and Process

TRI reports must be submitted annually by July 1, detailing the quantities of TRI-listed chemicals released into the environment during the previous calendar year (January 1–December 31). Reports should also include how chemicals are managed—whether through recycling, energy recovery, or treatment.

All non-confidential TRI reports must be submitted electronically using the TRI-MEweb platform. While companies may use their own software to prepare reports, submissions must be uploaded through TRI-MEweb using the “Upload XML” feature.

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