TRI/Form R Reporting

Each year, the Environmental Protection Agency (EPA) requires Toxics Release Inventory (TRI – aka “Form R”) data to be reported from applicable industrial facilities in the United States.

The purpose of TRI reporting is to monitor toxic chemical releases into the environment by industrial facilities and encourage pollution prevention practices. The EPA sets specific thresholds for each TRI-listed chemical, and facilities that manufacture, process, or otherwise use any of the listed chemicals above the set threshold must submit a TRI report. To view TRI-listed chemicals and their thresholds, click here.

To determine if your facility needs to report, it must answer “yes” to the following criteria:

1. The facility’s primary NAICS code is covered by the TRI program.
2. The facility has 10 or more full-time employees.
3. The facility manufactures, processes, or otherwise uses TRI-listed chemicals above any of the thresholds for a chemical or chemical category.

Additionally, under the Emergency Planning and Community Right-to-Know Act (EPCRA) 313(b)(2) determination, the EPA can request a TRI report from any facility.

Facilities that meet the above criteria must submit a TRI report to the EPA and the state in which the facility is located. TRI submissions must be reported using TRI-MEweb.

TRI reports are due July 1 each year and report data from the previous year. For example, reports submitted in 2025 will include data from January 1–December 31, 2024.

Additional Requirements

In 2023, the EPA published a final rule [TSCA section 8(a)(7)] that requires manufacturers and importers of PFAS and PFAS-containing articles since 2011 to report information on PFAS use, production volumes, disposal, exposures, and hazards. This is a separate requirement from TRI, which also requires PFAS to be reported.

The difference is, TRI sets reporting thresholds for PFAS (usually 100 pounds) and the TSCA PFAS rule does not. Any manufacturer or importer of PFAS since 2011, regardless of amount, is required to report the requested information.

This PFAS reporting period is open from April 13, 2026 to October 13, 2026 (for small manufacturers reporting as article importers, the deadline is extended to April 13, 2027).

For more information on the new PFAS reporting requirements under TSCA section 8(a)(7), please refer to Walden’s PFAS guide. The EPA also offers many resources to assist with understanding this new rule, as well as how to report.

Contact Walden’s EHS team at 860-846-4069 for help understanding all of the PFAS and other chemical reporting requirements that apply to your operation.