Tier II Reporting and Hazardous Waste Biennial Reporting for fiscal year 2025 has snuck up on us once again, with a deadline of March 1, 2026. Facilities subject to federal and state environmental reporting requirements must have submitted both of these reports by March 1 to be in compliance.
Tier II Reports
Emergency Planning and Community Right-to-Know Act (EPCRA) Section 312 reports, also known as Tier II reports, are due annually by March 1 and apply to facilities that store hazardous chemicals and Extremely Hazardous Substances (EHSs) above the threshold quantity (TQ) at any time during the prior calendar year.
The TQ for hazardous chemicals is 10,000 pounds. There is no single comprehensive list of hazardous chemicals; instead, a hazardous chemical is defined as a chemical that exhibits hazardous characteristics, as defined by the Occupational Safety and Health Administration Hazards Communication Standard.
The TQ for EHSs is 500 pounds or the listed threshold planning quantity (TPQ), whichever is less. EHSs and their TPQs can be found on United States Environmental Protection Agency’s EPCRA “List of Lists,” which was last updated in April 2025.
Tier II reports must be submitted to the State Emergency Response Commission, Local Emergency Planning Committee, and the local fire department. Common compliance issues include failure to aggregate chemical quantities across storage locations, under-reporting mixtures and fuels, outdated facility contact information, and inconsistencies between Tier II submissions and Safety Data Sheets. Tier II reporting requirements and procedures vary by state, so it is important that you verify your facility’s individual state requirements. Differences between state requirements may include items such as reporting thresholds, fee structures, and reporting portals.
Biennial Hazardous Waste Reports
Resource Conservation and Recovery Act (RCRA) Hazardous Waste Biennial Reports are due in even-numbered years by March 1 for facilities classified as Large Quantity Generators. These reports summarize hazardous waste generation, management, and off-site shipments for the previous calendar year. Common problem areas include incorrect waste codes, discrepancies between manifests and reported quantities, and misclassification of generator status due to episodic events or operational changes. In states that have adopted the RCRA Hazardous Waste Generator Improvements Rule, Small Quantity Generators are no longer required to submit a biennial report if they trigger an episodic event, as long as they comply with the episodic generator provisions. Not all states have adopted the new rule, however, so be sure to check your facility’s individual state reporting requirements.
Ensuring Compliance
Reports submitted under both of these programs are actively reviewed by regulators, with commonly cited enforcement actions being late, incomplete, or inaccurate submissions. Facilities are encouraged to verify state-specific requirements and electronic filing platforms and document retention obligations. Facilities seeking to reduce compliance risk may benefit from an independent review of chemical inventories, List of Lists applicability, generator status, and reporting data before submission.
The compliance calendar below can be used as a planning tool to track these and other recurring environmental reporting deadlines.
Reporting Deadlines 2026
| Report | Submission Deadline | Form |
| Tier II Chemical Reporting (Emergency Planning and Community Right-to-Know Act [EPCRA] Section 312) | March 1 (annual) | Varies by state
State Tier II Reporting Requirements and Procedures | US EPA |
| Resource Conservation and Recovery Act (RCRA) Biennial Report for Large Quantity Generators of Hazardous Waste and Other Solid Waste Reporting | March 1 (even years)
Check state requirements for annual reporting |
Biennial Report Form 8700-13A/B
Solid waste reporting varies by state (e.g., Chemical Analysis – Form 26R in Pennsylvania due March 1 INSTRUCTIONS (pa.gov) |
| United States Environmental Protection Agency (USEPA) Refrigerant Reports | March 1 (annual) | USEPA prefers the information be submitted electronically to 608reports@epa.gov |
| USEPA Air Emissions Inventory and Compliance Certifications | Varies by state | Varies by state |
| Occupational Safety and Health Administration (OSHA) 300 Log | February 1 (annual) | Post previous year’s information on-site during the period of February 1 to April 30 |
| OSHA Annual Summary/Incident Report for Certain Establishments | March 2 (annual) | Confirm OSHA requirements for submittal of Form 300A Annual Summary/Form 301 Incident Report |
| Quarterly Stormwater Visual Monitoring Reports | Varies by state (e.g., sampling due last day of each quarter, reports due April 7) | Varies by state and standard industrial classification (SIC) code |
| Greenhouse Gas (GHG) Reports | March 31 (annual) | USEPA’s electronic Greenhouse Gas Reporting Tool |
| Toxics Release Inventory (TRI) (EPCRA Section 313) | July 1 (annual) | TRI-MEweb, accessed through the CDX |
| Annual Stormwater Compliance Evaluation/Inspection | Varies by state | Varies by state |
Compliance questions?
If you need help determining which of these deadlines apply to you, or assistance completing the forms, our team is here to help. Contact Katie Milk at katie.milk@ehs-support.com.
