PFAS in TRI Reporting – 2024 and 2025

June 12, 2024

On May 17, 2024, the U.S. Environmental Protection Agency (EPA) expanded its Toxic Release Inventory (TRI) program to include seven additional per- and polyfluoroalkyl substances (PFAS), raising the total number of PFAS tracked under the TRI to 196 to report in 2025 for the year 2024—the PFAS to report on for 2023 on July 1, 2024 numbers 186.

This decision, mandated by the 2020 National Defense Authorization Act (NDAA), which requires annual updates to the PFAS list in the TRI, reflects ongoing efforts to monitor and manage environmental exposure to these persistent chemicals.

The EPA removed the de minimis exemption for PFAS under the “chemicals of special concern” category as of October 2023. This elimination underscores the increased regulatory focus on these substances due to their environmental and health risks, thereby intensifying the demands on facilities to track and report PFAS handling accurately. This ongoing regulatory evolution highlights the increasing scrutiny and accountability for environmental stewardship concerning PFAS.

SCS’s educational  video Toxics Release Inventory Reporting explains how to identify and quantify facilities subject to TRI reporting, including:

• Those having ten or more full-time employee equivalents (calculated using a specific method).
• Manufacture or process listed PFAS or PBTs during the calendar year.
  • Per- and polyfluoroalkyl substances (PFAS) will no longer have a de minimis concentration as of January 1, 2024, for the report due July 1, 2025.
  • Thresholds are established for TRI reports due July 1, 2024.
  • Persistent bioaccumulative toxins (PBTs) do not have a de minimis concentration.

Facilities must start compiling historical and new information to meet compliance requirements. The educational video covers the reporting thresholds and tips for collecting the data, calculating usage, and determining which form to report to the EPA. Some facilities accidentally overreport, so our expert tells you how to avoid this mistake.

Including additional PFAS in the TRI places a greater compliance burden on many industries. Companies must adapt by implementing more rigorous tracking systems and investing in technologies to reduce PFAS emissions or discharges.

Tracking specific product formulations is more important than ever. Safety Data Sheets (SDS) and historical reporting are a good place to start. Still, our expert explains how to minimize your facility’s risk of non-compliance, fines, or legal actions by not relying on SDS. She provides many tips for increasing the accuracy and accountability of this public information.

In addition to the TRI educational video, SCS Engineers offers a slide set with links to many helpful tools and great advice. All resources are educational.

Request Tools and Resources Slides or ask a Hazardous Waste Expert a question here.