Facilities required to submit Toxics Release Inventory (TRI) reports are reminded that the deadline for the 2024 reporting year is July 1, 2025. All reports must be filed with the United States Environmental Protection Agency (USEPA) by this date.
What is the Emergency Planning and Community Right-to-Know Act (EPCRA) Section 313/TRI?
TRI reports are required to be submitted annually to USEPA by specific industry sectors. Facilities must report data covering releases and waste management of certain chemicals and chemical categories. All reported TRI data is made publicly available, so accuracy is key.[1]
Who is required to report?
Your facility is required to report if it meets all of the following three conditions:
- Your facility is in a covered industry sector, based on the facility’s North American Industrial Classification System code.
- You have 10 or more full-time employees (or a combination of full-time and part-time employees who work a total of 20,000 hours or more).
- Your facility manufactures, processes, or otherwise uses specific TRI chemicals in amounts that exceed the established thresholds. Most commonly, the thresholds are 25,000 pounds for manufacturing and processing, and 10,000 pounds for chemicals otherwise used, although lower thresholds exist for the more toxic chemicals such as persistent bioaccumulative toxins (PBTs) and per- and poly-fluoroalkyl substances (PFAS).[2]
What is required to be reported?
Facilities are required to submit a TRI Form R or Form A for each TRI chemical they manufacture, process, or otherwise use in quantities that exceed designated thresholds. Form R includes general facility information and specific chemical information, including the following:
- On-site releases, such as releases to air, waste, and water
- Off-site transfers, including waste management and discharges to wastewater treatment plants
- Waste treatment, energy recovery, and recycling activities
- Source reduction and waste management
Facilities with smaller reportable amounts may be eligible to use Form A, which is a simplified form that can be used in place of Form R under certain conditions.[3]
Key Changes in 2025
The following key changes have been introduced this year for TRI reporting requirements:
- Seven additional PFAS are reportable.
- PFAS are now designated as “chemicals of special concern,” which means the de minimis exemption, Form A certification, and some range reporting are no longer available for TRI reporting of PFAS.
- The de minimis exemption can no longer be used for supplier notifications.
- The de minimis levels for select cobalt and antimony compounds have been changed from 1.0% to 0.1%.
- A diisononyl phthalate category (N125) has been added to the TRI list.[4]
Questions? We’re here to help
Navigating complex TRI reporting requirements and keeping up with regulatory changes can be challenging. As industry leaders in chemical management and compliance, EHS Support can help ensure accurate and timely reports, and help simplify the TRI reporting process. Contact Katie Milk at katie.milk@ehs-support.com or Jessica Myer at jessica.myer@ehs-support.com for expert guidance and to ensure seamless compliance with these regulations.
[1] https://www.epa.gov/toxics-release-inventory-tri-program/what-toxics-release-inventory
[2] https://www.epa.gov/toxics-release-inventory-tri-program/tri-threshold-screening-tool
[3] https://guideme.epa.gov/ords/guideme_ext/f?p=guideme:chemical-list-advanced-search:0
[4] https://www.epa.gov/toxics-release-inventory-tri-program/reporting-tri-facilities
