Nine More PFAS Join the US TRI List: Compliance Reports Required by July 1, 2026

On January 3, 2025, the US Environmental Protection Agency (EPA) broadened the Toxic Release Inventory (TRI) by incorporating nine more per- and polyfluoroalkyl substances (PFAS), as per the National Defense Authorization Act (NDAA) for Fiscal Year 2020. This update elevates the count of PFAS on the TRI to 205.

The specifics of the added substances are as follows:

The NDAA annually establishes a structure for incorporating PFAS into the TRI, addressing related EPA activities. The nine new PFAS will be reported in the 2025 TRI reports, due by July 1, 2026.

EPA has stated that PFAS, as "chemicals of special concern," will no longer meet the minimum exemption for TRI supplier reporting. Thus, all producers of the 205 PFAS listed in the TRI must provide concentration information to downstream facilities, regardless of whether the PFAS concentration in a product or mixture is below 1%.

The US Toxic Release Inventory (TRI)

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

The TRI's PFAS monitoring has recently increased:

• Four additional PFAS were monitored in 2022;
• Nine additional PFAS were monitored in 2023;
• Seven additional PFAS were monitored in 2024; and
• Nine additional PFAS were monitored in 2025.

TRI Q&A

Companies must submit a TRI report if they:

1. Operate in sectors like manufacturing, mining, or power generation, with a NAICS code under the TRI program.
2. Employ at least 10 full-time workers.
3. Exceed the following usage thresholds for any TRI-listed chemical in a calendar year:

1. • Manufacture (or import) over 25,000 pounds,
   • Process over 25,000 pounds,
   • Use over 10,000 pounds in other ways.

When and how should reports be submitted?

Companies are obligated to communicate to EPA the quantities of environmentally released chemicals for the previous calendar year (January 1st to December 31st) annually, by July 1st. This report should also encapsulate how these chemicals are managed, whether through recycling, energy recovery, or treatment.

All non-confidential TRI reports must be submitted via the TRI-MEweb platform. Even if companies use their own software to compile reports, they must still upload and submit them to the EPA through TRI-MEweb's "Upload XML" feature.

CIRS advises all US companies to monitor TRI list updates and submit annual reports promptly to avoid compliance risks.

If you need any assistance or have any questions, please get in touch with us via service@cirs-group.com.

Chemradar Global PFAS Screening Tool

To help businesses build global compliance defenses, CIRS proudly launches the Global PFAS Screening Tool. The Global PFAS Screening Tool contains over 17,000 substances and allows you to search for PFAS substances through four dimensions: CAS number, substance name, molecular formula, and SMILES. In the future, the database will continue to roll out country-specific screening modules to support businesses in keeping pace with regulatory upgrades in various countries. Stay tuned!

Further Information

EPA