Fatima Noor
Jul 17, 2026
The US Environmental Protection Agency has added nine additional PFAS to the Toxics Release Inventory for Reporting Year 2025, bringing the total number of reportable per- and polyfluoroalkyl substances to 205. Facilities meeting reporting thresholds must submit their 2025 data by July 1, 2026. For procurement teams sourcing fluorochemicals and chemical manufacturers using or producing PFAS, this expansion of reporting obligations creates new compliance requirements, supply chain transparency demands and strategic implications around PFAS exposure that extend beyond the directly regulated facilities to affect purchasing decisions and supplier relationships.
The steady expansion of TRI-reportable PFAS demonstrates EPA's commitment to increasing public visibility into where these persistent chemicals are manufactured, processed and released into the environment.
The TRI serves as a publicly accessible database tracking industrial releases of toxic chemicals to air, water and land plus waste management activities including recycling, treatment and disposal.
Core TRI characteristics include:
Annual reporting requirement for facilities meeting activity and threshold criteria
Public disclosure through EPA's searchable online database
Community right-to-know enabling residents near industrial facilities to understand chemical exposures
Regulatory driver influencing permitting, enforcement and cleanup priorities
Facilities must report when they:
Employ 10 or more full-time equivalent employees
Fall within specified manufacturing sector codes
Manufacture, process or otherwise use listed chemicals above threshold quantities
The reporting captures not just releases but also quantities transferred off-site for disposal, recycling, treatment or energy recovery.
EPA has not publicly detailed the specific chemical identities of all nine newly added PFAS in readily accessible summary formats as of this regulatory update. The additions emerged from EPA's systematic review of PFAS substances with commercial use or environmental presence.
Typical characteristics of PFAS added to TRI include:
Commercial production or import volumes indicating significant use
Environmental detection through monitoring programs
Persistence concerns given the chemical stability inherent to PFAS structures
Regulatory priority based on hazard profiles or exposure pathways
Facilities manufacturing, processing or using these nine substances above reporting thresholds will need to implement tracking systems capturing:
Annual quantities manufactured or processed
Releases to air, water and land by pathway
Transfers to off-site locations for waste management
Recycling, energy recovery and treatment activities
Chemical manufacturers should review the complete updated TRI chemical list to identify whether the new additions affect their operations.
The growth from zero PFAS on the TRI several years ago to 205 substances reflects EPA's accelerating focus on this chemical class.
Expansion timeline:
2020 - EPA began adding PFAS to TRI with initial substances
2021-2023 - Steady additions as agency reviewed commercial PFAS
2024-2025 - Acceleration driven by regulatory priorities and stakeholder pressure
2026 forward - Likely continued expansion as EPA evaluates remaining PFAS
The 205 total represents a small fraction of the thousands of PFAS in commercial use or identified in environmental monitoring. EPA prioritizes substances with higher production volumes, greater environmental presence or specific regulatory concern for TRI listing.
However, the direction clearly favors comprehensive PFAS coverage over time. Facilities using any fluorinated chemicals should prepare for eventual TRI reporting even if current substances are not yet listed.
Not every facility using listed PFAS must report. Specific thresholds determine reporting obligations.
Manufacturing threshold:
Facilities that manufacture a listed PFAS exceeding 25,000 pounds annually must report
Processing and otherwise use thresholds:
Facilities that process or otherwise use listed PFAS exceeding 25,000 pounds annually must report
Lower 10,000-pound threshold applies to certain persistent bioaccumulative toxic (PBT) chemicals, though most PFAS currently use 25,000-pound threshold
De minimis exemptions:
Substances present below 1% concentration in mixtures generally do not count toward thresholds
However, EPA has proposed or finalized rules eliminating de minimis exemptions for PFAS, meaning any amount counts
The threshold calculations require careful tracking of PFAS quantities in raw materials, intermediates and final products across calendar year operations.
TRI reporting captures detailed information about chemical quantities and management practices.
Required data elements include:
Maximum amount on site at any time during the year
Quantity released to air through stacks, fugitive emissions or other pathways
Quantity discharged to water bodies or publicly owned treatment works
On-site land disposal through landfills, surface impoundments or other methods
Off-site transfers for disposal, recycling, treatment or energy recovery
Additional information required:
Release estimation methods and basis for calculations
Source reduction and recycling activities
Waste treatment efficiency for certain releases
One-time releases from catastrophic events or remedial actions
The reporting demands significant data collection infrastructure tracking PFAS flows through manufacturing processes, waste streams and environmental release points.
Understanding the compliance calendar helps facilities prepare for timely submission.
Key dates:
January 1 - December 31, 2025 - Reporting year for covered activities
July 1, 2026 - Deadline for submitting TRI Form R or Form A reports
Extended deadline available for facilities meeting certain criteria requesting extensions
Facilities should begin preparation well before July 2026 deadline given the complexity of:
Identifying all PFAS-containing materials
Calculating annual quantities manufactured, processed or used
Estimating releases through various pathways
Compiling required supporting documentation
First-time reporters face steeper learning curves requiring additional lead time for system implementation.
TRI reporting obligations extend beyond direct compliance to affect supplier relationships and procurement decisions.
Supply chain dynamics include:
Customer inquiries about PFAS content in supplied materials
Specifications evolving to limit or eliminate PFAS triggering reporting
Supplier questionnaires requesting disclosure of PFAS presence above specified thresholds
Contract provisions addressing PFAS reporting obligations and potential reformulations
Procurement teams sourcing materials from suppliers subject to TRI reporting should understand:
Whether purchased materials contain reportable PFAS
Concentration levels affecting de minimis calculations
Alternative non-PFAS materials available as substitutes
Supplier compliance capabilities and track records
Proactive engagement with suppliers about PFAS content and TRI implications strengthens supply chain transparency and reduces regulatory risk.
TRI reporting creates business considerations extending beyond compliance mechanics.
Reputation and stakeholder relations:
Public disclosure makes PFAS releases visible to communities, investors, customers and NGOs
Media attention often focuses on facilities with high reported releases
Environmental justice concerns arise when releases occur near disadvantaged communities
Corporate sustainability commitments require addressing PFAS use and releases
Competitive dynamics:
Facilities reporting large PFAS releases may face competitive disadvantages versus those with lower environmental footprints
Customers increasingly prefer suppliers with minimal PFAS use
Investors apply ESG screening potentially affecting capital access
Operational planning:
TRI data informs decisions about process improvements reducing releases
Investments in pollution control equipment or alternative chemistries
Site selection for new capacity considering community acceptance
Companies viewing TRI reporting purely as compliance obligation miss strategic implications affecting market positioning and stakeholder relationships.
TRI reporting exists within ecosystem of expanding PFAS regulations affecting manufacturing, use and disposal.
Related regulatory developments include:
TSCA reporting requiring manufacturers and importers to report PFAS production volumes and uses
Drinking water standards limiting PFAS concentrations in public water systems
CERCLA designation potentially listing PFAS as hazardous substances requiring cleanup
State regulations implementing bans, restrictions or disclosure requirements for PFAS
The cumulative regulatory pressure creates incentives to reduce or eliminate PFAS use where technically and economically feasible. TRI reporting adds transparency dimension making continued PFAS reliance more visible and potentially controversial.
Facilities should develop integrated PFAS strategies addressing TRI alongside other regulatory obligations rather than treating each requirement in isolation.
Accurate TRI reporting requires robust estimation methods for releases that cannot be directly measured.
Common estimation approaches include:
Engineering calculations based on process knowledge, mass balances and emission factors
Monitoring data from stack testing, effluent sampling or ambient measurements
Mass balance tracking PFAS inputs versus outputs accounting for accumulation and destruction
Emission factors from industry databases or literature applied to process activities
EPA provides guidance documents explaining acceptable methods and documentation standards. However, PFAS-specific emission factors remain limited given the relative novelty of comprehensive PFAS reporting.
Data quality challenges include:
Analytical detection limits for PFAS in complex matrices
Unknown PFAS content in purchased materials lacking detailed specifications
Fugitive emissions difficult to measure directly
Destruction efficiency uncertainty in incineration or treatment processes
Facilities should document estimation methods and underlying assumptions supporting reported values. Conservative approaches assuming higher releases provide regulatory safety margin but potentially overstate environmental impacts.
Failure to comply with TRI reporting requirements triggers enforcement consequences.
Potential penalties include:
Civil fines up to $70,000+ per violation per day
Criminal penalties for knowing and willful violations
Injunctive relief requiring compliance and corrective actions
Supplemental environmental projects offsetting environmental harm
EPA prioritizes enforcement against facilities that:
Fail to report despite meeting thresholds
Submit late or incomplete reports
Provide inaccurate data through inadequate estimation methods
Ignore warnings or notices of violation
Non-monetary consequences include:
Increased regulatory scrutiny and inspection frequency
Public disclosure of enforcement actions
Litigation from citizen groups or affected communities
Reputational damage affecting customer and investor relationships
The risks justify investment in robust compliance systems even for facilities where reporting obligations create minimal operational burden.
Chemical buyers managing PFAS-containing materials should take proactive steps addressing TRI expansion.
Immediate actions:
Inventory PFAS-containing materials in current procurement portfolios
Request supplier confirmation of PFAS content and concentrations
Assess TRI reporting impact if your facility processes or uses supplied materials above thresholds
Engage compliance teams ensuring procurement understands internal reporting obligations
Strategic positioning:
Qualify PFAS-free alternatives for applications where substitution is technically and economically feasible
Develop supplier scorecards incorporating PFAS transparency and TRI compliance
Build contract provisions requiring suppliers to disclose material changes in PFAS content
Monitor regulatory developments anticipating further restrictions affecting sourced materials
Procurement organizations that integrate TRI and broader PFAS regulatory considerations into sourcing strategies position themselves to adapt as requirements continue tightening.
Unlike many regulatory submissions, TRI reports become publicly accessible through EPA's online databases within months of submission.
Public disclosure implications:
Facility-specific data searchable by company name, location or chemical
Annual trends visible showing whether releases increase, decrease or remain stable
Benchmarking against competitors and industry averages
Media and NGO scrutiny targeting high-volume reporters or facilities near sensitive populations
Communities, environmental organizations and media regularly analyze TRI data to:
Identify pollution hotspots requiring attention
Track company environmental performance over time
Support legislative advocacy for stronger regulations
Inform environmental justice research and activism
Companies should prepare communications strategies explaining their TRI reports to stakeholders before data becomes public. Proactive transparency about PFAS use, release reduction efforts and environmental stewardship builds credibility versus reactive crisis management after unfavorable coverage.
The expanding reporting universe creates business drivers to evaluate PFAS alternatives where performance allows.
Substitution considerations include:
Technical performance comparing PFAS versus alternative materials
Regulatory advantages avoiding TRI reporting and other PFAS obligations
Customer preferences increasingly favoring PFAS-free formulations
Innovation opportunities developing proprietary alternatives creating competitive differentiation
Substitution challenges:
Limited alternatives for some applications requiring extreme chemical resistance, thermal stability or other unique PFAS properties
Qualification timelines extending months to years for applications with stringent performance requirements
Potentially higher costs for alternative materials or redesigned processes
Uncertain regulatory future for some substitutes which may face restrictions later
The decision to pursue substitution depends on balancing technical requirements, economic considerations and strategic positioning. Applications where PFAS is truly essential may justify continued use and associated reporting. Others benefit from transitioning to alternatives avoiding regulatory complexity.
The addition of nine PFAS bringing the total to 205 represents progress toward but not completion of comprehensive coverage.
Future expansion drivers:
Systematic review of remaining commercial PFAS for TRI listing
Stakeholder petitions requesting specific substances be added
Environmental monitoring identifying prevalent PFAS not currently reportable
Regulatory priorities targeting PFAS with specific health or environmental concerns
Facilities using any PFAS should assume eventual TRI reporting rather than viewing current non-listed status as permanent exemption. Building tracking and estimation capabilities now prepares for future additions without scrambling during short implementation windows.
The ultimate trajectory likely leads toward reporting requirements for all PFAS used above de minimis quantities, similar to how EPA has proposed treating PFAS as a class for certain regulations.
Implementing TRI reporting for new PFAS creates costs extending beyond filing forms.
Direct compliance costs include:
Staff time collecting data, performing calculations and preparing reports
Analytical testing measuring PFAS concentrations in materials and releases
Consulting support from environmental firms assisting with methodology and submissions
Software systems tracking chemical use and automating reporting workflows
Indirect costs stem from:
Management attention diverted to compliance versus operational priorities
Process disruptions from data collection requirements affecting production
Competitive disadvantage if reporting reveals practices less favorable than peers
Stakeholder management responding to inquiries about disclosed releases
For large facilities with established TRI programs, adding PFAS involves incremental effort integrating new substances into existing systems. Smaller facilities or those reporting for the first time face steeper initial investments developing capabilities.
The costs, while real, must be weighed against enforcement risks and business implications of non-compliance.
The addition of nine PFAS to the Toxics Release Inventory expanding the total to 205 reportable substances demonstrates EPA's systematic approach to increasing transparency around this chemical class. For facilities manufacturing, processing or using PFAS above reporting thresholds, the July 1, 2026 deadline for Reporting Year 2025 data requires immediate preparation.
Procurement teams and chemical suppliers should recognize that TRI expansion is one element of broader PFAS regulatory tightening. Proactive strategies addressing PFAS transparency, use reduction and alternative development position organizations to navigate evolving requirements successfully.
The companies treating TRI reporting as pure compliance checkbox miss opportunities to demonstrate environmental leadership, strengthen stakeholder relationships and anticipate future regulatory directions. Those integrating TRI into strategic planning around PFAS create competitive advantages through transparency, innovation and environmental performance.
Understanding which substances require reporting, how to comply effectively and what the public disclosure means for business positioning separates companies that thrive under increasing PFAS scrutiny from those that struggle with each new regulatory development.
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