The U.S. Environmental Protection Agency (EPA) has expanded the Toxics Release Inventory (TRI) to include additional per- and polyfluoroalkyl substances (PFAS). This action is mandated under Section 7321 of the National Defense Authorization Act (NDAA) for FY 2020, strengthening transparency and reporting obligations for facilities handling PFAS chemicals.
Staggered Implementation Schedule
The additions are phased based on statutory triggers:
• Reporting Year 2024 (due July 1, 2025): Seven PFAS added
• Reporting Year 2025 (due July 1, 2026): Nine PFAS added, effective Jan 1, 2025
• Reporting Year 2026 (due July 1, 2027): One PFAS scheduled for inclusion, effective Jan 1, 2026
These updates increase mandatory reporting for facilities across manufacturing and industrial sectors.
Regulatory Implications
Facilities managing PFAS must:
• Report releases, waste management, and transfers of listed PFAS
• Comply without de minimis exemptions, as these are chemicals of special concern
• Meet supplier notification requirements starting Jan 1, 2025, for 2025-listed PFAS
This initiative aligns with EPA’s goals for enhanced accountability, transparency, and community data access.
Industry Action Steps
Companies should:
• Review operations to determine applicability of new PFAS listings
• Begin tracking PFAS usage and releases to meet upcoming reporting deadlines
• Ensure supplier communication supports PFAS notification rules
• Monitor EPA announcements for future chemical additions and policy changes
Reference: EPA TRI PFAS Additions under NDAA
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