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Toxics Release Inventory Reporting Basics & 2025 Updates

Posted by Josef Posch on Monday, April 21, 2025

The Toxics Release Inventory (TRI) Program was created as part of a response to several events that raised public concern about local preparedness for chemical emergencies and the availability of information on hazardous substances. The TRI reporting requirements are part of the Environmental Protection Agency’s (EPA) Emergency Planning and Community Right-to-Know Act (EPCRA).

The TRI tracks the management of certain toxic chemicals that may pose a threat to human health and the environment. U.S. facilities in different industry sectors must report annually how much of each chemical they release into the environment and/or managed through recycling, energy recovery and treatment, as well as any practices implemented to prevent or reduce the generation of chemical waste.

Who Must Submit a TRI Report?

Facilities that are required to submit a TRI report are typically larger facilities involved in manufacturing, metal mining, electric power generation, chemical manufacturing and hazardous waste treatment. Not all industry sectors are covered by the TRI Program, and not all facilities in covered sectors are required to submit a TRI report. See all industries covered. Covered industry facilities are required to report if they meet the below criteria:

the equivalent of 10 or more full-time employees and;
meet the established thresholds for manufacture, processing, or "otherwise use" of listed chemicals (i.e., manufactures or processes over 25,000 pounds or uses more than 10,000 pounds of any designated chemical or chemical category) must report their releases and other waste management quantities, including quantities transferred off-site for further waste management.

EPCRA originally required TRI reporting using four-digit Standard Industrial Classification (SIC) codes. However, the Office of Management and Budget replaced the SIC code system with the NAICS code system developed by the U.S. Census Bureau, and TRI adopted this system in 2006. NAICS codes are updated every five years, and TRI facilities currently use OMB-revised 2012 six-digit NAICS codes on their TRI reporting forms. EPA added seven industry sectors in 1997 and natural gas processing facilities in 2021.

These requirements help ensure transparency and inform communities about potential environmental and health risks.

What Are TRI Toxic Chemicals?

In general, chemicals covered by the TRI Program are those that cause:

Cancer or other chronic human health effects.
Significant adverse acute human health effects.
Significant adverse environmental effects.

There are currently appoximately 800 individually listed chemicals and 30+ chemical categories covered by the TRI Program.

Reporting Basics

How to Report:

Submit TRI Form R for each TRI-listed chemical that meets the reporting threshold.
Use TRI-MEweb, EPA’s online reporting application.

When to Report:

Annual reports are due by July 1st, covering activities from the previous calendar year.

Additional Requirements:

Facilities must also report on pollution prevention activities and efforts to reduce chemical waste.

Changes for Reporting Year (RY) 2024

The changes below apply to RY 2024 TRI forms, which are due to EPA by July 1, 2025.

Changes in TRI reporting requirements for PFAS:

Effective November 30, 2023, (see 88 FR 74360), all PFAS included on the TRI list pursuant to sections 7321(b) and 7321(c) of the 2020 NDAA are added to the list of Lower Thresholds for Chemicals of Special Concern.
Starting in RY 2024, PFAS are designated as “chemicals of special concern.” The de minimis exemption, Form A Certification, and some range reporting are no longer available for TRI reporting of PFAS.
The de minimis exemption is unavailable for supplier notification purposes (for PFAS and all other chemicals of special concern).

The de minimis levels for the following chemicals have been changed from 1.0% to 0.1% since these chemicals are classified as carcinogens due to assessments by the International Agency for Research on Cancer:

Some cobalt compounds (N096): soluble cobalt(II) salts, cobalt(II) oxide.
Some antimony compounds (N010): trivalent antimony.

7 additional per- and polyfluoroalkyl (PFAS) are reportable.
A diisononyl phthalate (DINP) category (N125) has been added to the TRI list. The DINP category includes branched alkyl di-esters of 1,2-benzenedicarboxylic acid in which alkyl ester moieties contain a total of nine carbons.
Note that for RY 2025 (reporting forms due July 1, 2026), 9 PFAS were added to the TRI list. Read more about these requirements on the TRI Laws and Regulatory Activities webpage.

Pennsylvania Fee Requirements:

For each chemical reported on the Toxic Chemical Release Inventory or alternate Threshold Certification Form, a fee of $250 is to be paid to the "Pennsylvania Hazardous Material Response Fund." These are payable only by check or money order.

The maximum fee for any facility is $5,000, regardless of how many chemicals are reported.
Publicly owned facilities are fee exempt.
Under Act 165, there are no county fees for TRI reporting.

Takeaways

The TRI reporting deadline is fast approaching. Facilities should evaluate the need to report each year. If you have questions or need support, Entech can help you make informed decisions to keep you in compliance and stay on top of environmental reporting requirements, including TRI.