Toxics Release Inventory (TRI) – PFAS

The Toxics Release Inventory (TRI) is a U.S. EPA program under the Emergency Planning and Community Right-to-Know Act (EPCRA) that requires certain facilities to report annual releases and transfers of toxic chemicals. PFAS were first added to the TRI in stages: the NDAA FY2020 added PFOA and PFOS; subsequent NDAA authorizations expanded the list. As of 2025, EPA tracks 205 PFAS under TRI. EPA is finalizing a rule (expected February 2026) to add additional individual PFAS and PFAS categories to TRI, along with criteria for automatic future additions.

EPCRA §313; NDAA FY2020 §7321; EPA TRI PFAS rulemaking (anticipated February 2026); 40 CFR Part 372.

TRI reporting is facility-level, not product-level. Facilities that manufacture, process, or otherwise use reportable PFAS above TRI threshold quantities (typically 100 lbs/year) must file annual TRI reports disclosing quantities released to air, water, and land, as well as quantities transferred off-site for treatment or disposal. Importantly, no de minimis concentration threshold currently applies to PFAS under TRI—this means any amount of a TRI-listed PFAS contributes to the activity threshold calculation.

A semiconductor fabrication facility uses PFAS-containing photoresist and etchant chemicals. The facility processes more than 100 lbs/year of TRI-listed PFAS across its operations. It must file annual TRI reports (Form R or Form A) disclosing PFAS releases and waste management activities, including any PFAS released to air via stack emissions or to water via wastewater discharge.