TRI Reporting 101: What You Need To Know for 2025 Compliance

If your facility manufactures, processes, or uses certain toxic chemicals, you may be required to report to the Toxics Release Inventory (TRI). TRI is not just a regulatory obligation – it’s a transparency tool that informs the public and helps facilities improve their environmental performance.

In a recent webinar entitled, “Toxic Release Inventory Reporting: A Q&A with Kara and Friends,” Kara Van Blarcum, CESCO, Antea Group’s Waste and Materials Management Service Line Leader, led a conversation with Jason Lagowski, CPG, Senior Consultant; Mike Pauli, Water Management Service Line Leader; and Tony Rossano, Senior Manager, on this subject.

This blog recaps the webinar and breaks down the key requirements, recent updates, and common compliance pitfalls to help you prepare for the July 1, 2025, reporting deadline for the 2024 calendar year.

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What Is TRI and Why Does It Matter? 

TRI reporting is mandated under the Emergency Planning and Community Right-to-Know Act (EPCRA), which was enacted in 1986 in response to major chemical disasters in Bhopal, India, and Institute, West Virginia. TRI aims to provide communities with information about the presence and release of toxic chemicals in their area.

Unlike Tier II reporting, which tracks hazardous chemicals stored onsite, TRI focuses on the release and management of specific chemicals that exceed reporting thresholds.

TRI data is publicly available, which means accuracy and transparency are critical—for both compliance and reputation management.

Do TRI Requirements Apply to You? 

A facility must meet all three criteria to be subject to TRI:

1. Employee Threshold: 10 or more full-time employee equivalents (about 20,000 work hours per year).
2. NAICS Code Coverage: Your primary industry code must be on EPA’s list of covered sectors (e.g., manufacturing, utilities, mining, etc.).
3. Chemical Use: You manufacture, process, or otherwise use a TRI-listed chemical above the reporting threshold.

Thresholds by Activity: 

• 25,000 lbs. for chemicals manufactured or processed,
• 10,000 lbs. for chemicals otherwise used,
• 100 lbs. or less for Persistent Bioaccumulative Toxic (PBT) substances like lead or PFAS.

Common TRI Chemicals: 

• Metals and metal compounds (e.g., lead, copper)
• Nitric acid, ethylene glycol, solvents
• Diesel byproducts like naphthalene and polycyclic aromatic compounds
• Wastewater treatment chemicals
• Per- and polyfluoroalkyl substances (PFAS)

Understanding Key Definitions 

• Manufactured: Intentionally produced, imported, or created during processes (e.g., ammonia generated during commercial baking).
• Processed: Incorporated into a product, blended, or packaged for distribution (e.g., solvents in paint).
• Otherwise Used: Utilized without being part of the final product (e.g., nitric acid in wastewater treatment).

Article Exemption: 

Articles like copper tubing or wire may be exempt from reporting—unless they are cut, melted, or ground in a way that releases TRI chemicals.

Calculating Releases: What Counts? 

If thresholds are exceeded, you must quantify how much was released or managed, including:

• Air emissions (stacks, fugitive)
• Wastewater discharges (from treatment systems)
• Stormwater runoff
• On-site disposal or treatment
• Off-site transfers (e.g., hazardous waste, scrap metal)

Tools used include: 

• Stack testing, water sampling data
• Waste manifests and profile sheets
• Material balance or engineering calculations

You’ll then report using Form R or Form A via the EPA’s TRI-MEweb platform on CDX.

TRI and PFAS: What’s New for RY 2025? 

PFAS reporting has evolved rapidly:

• 2020: PFAS first added to the TRI list
• 2024: EPA added 9 new PFAS compounds, including 7 PFOS variants
• De minimis exemption removed for all PFAS in 2024
• PFAS now designated as chemicals of special concern (PBTs)
• Form A no longer allowed for PFAS reporting—must use Form R

Currently, there are around 180 TRI-listed PFAS and that number is expected to grow. The current reporting threshold is 100 lbs., but future rules could reduce it to 10 lbs.

Many safety data sheets (SDSs) do not clearly list PFAS—screening tools or supplier outreach may be required.

Quick Look: Reporting Deadlines 

• July 1, 2025 – Reports due for calendar year 2024
• Use TRI-MEweb via EPA CDX
• All data is public, and EPA may follow up on year-over-year discrepancies

Common Audit Findings 

Antea Group’s audit teams frequently encounter these issues:

• Failure to Evaluate Applicability: Many facilities meet TRI criteria but have never assessed thresholds.
• Missed Releases: Things like fugitive lead from soldering or byproducts from wastewater processes (e.g., nitrate formation) are often overlooked.
• Misuse of Exemptions: Activities like wire grinding may invalidate the article exemption, triggering reportability.

Regular evaluations, good records, and updated SDS reviews are essential to avoid violations.

Frequently Asked Questions 

Q: We just learned we should’ve been reporting. Do we need to go back? 
A: Yes. TRI requires 5 years of historical review. It’s better to self-disclose than wait for EPA to flag missing reports.

Q: Are TRI chemicals listed on the SDS? 
A: Yes—check Section 15 and Section 3. But suppliers may delay updates, so verify CAS numbers against EPA’s TRI list.

Q: Is there a checklist to conduct an evaluation? 
A: There’s no universal template, but a good process includes:

• Reviewing your product inventory and SDSs,
• Calculating chemical usage and comparing against thresholds,
• Evaluating all potential release pathways (air, water, waste).

Q: How do I find my NAICS code and determine if it’s TRI-covered? 
A: Check your OSHA 300 log, EPA ECHO portal, or use an online SIC-to-NAICS crosswalk to see if you’ve ever reported it before. If not, you will need to review the NAICS list to determine which best matches with your operations. Then compare against EPA’s TRI-covered NAICS list.

Q: If my SDS doesn’t mention PFAS, should I keep looking? 
A: Yes. PFAS may be hidden under trade names or proprietary listings. Use screening tools or request supplier certifications.

Q: Do any states have separate TRI reporting? 
A: Massachusetts has a parallel program, the Toxic Use Reduction Act (TURA), requiring additional forms. All others follow federal TRI rules.

Q: Can I revise a TRI report if I find a mistake? 
A: Yes. Revisions can be made within five years via TRI-MEweb.

Q: If I move or close a facility, do I still report? 
A: Yes. If thresholds were exceeded at any point during the year, even a closed or relocated facility may require reporting.

Q: I exceeded the threshold but have no releases—do I still file? 
A: Yes. You must still submit a form—likely Form A, unless the chemical is a PBT or otherwise disqualified.

Final Thoughts 

TRI reporting is complex—but manageable with the right systems in place. Consistent tracking, supplier engagement, and periodic audits can help you stay ahead of evolving requirements, especially as PFAS and PBT oversight increases.

Do you need help with TRI applicability evaluations, report preparation, or PFAS disclosure? Reach out to Antea Group’s experts today to get guidance every step of the way.