Annual Air Emissions Inventory Reports (Due March to June 2026, State-Specific)
What is the annual air emissions inventory report?
Facilities that operate under air permits are typically required to submit an annual emissions inventory detailing the pollutants released from their operations during the previous year. These reports capture emissions of criteria air pollutants, such as nitrogen oxides (NOx), sulfur dioxide (SO₂), particulate matter (PM), and volatile organic compounds (VOC), as well as hazardous air pollutants (HAP).
Environmental agencies use this data to track regional air quality trends, update the National Emissions Inventory maintained by the Environmental Protection Agency, and assess fees.
When is the emissions inventory report due in 2026?
While deadlines vary by state, most jurisdictions require the report to be submitted between March 1 and June 30 each year, covering emissions from the previous calendar year. That means most facilities will be reporting their 2025 emissions data during the second quarter of 2026.
Some states allow submissions later in the spring, but aiming for early April helps ensure sufficient time for data verification and corrections.
Which facilities must submit emissions inventory reports?
Facilities operating under state-issued air permits, particularly Title V permits, are typically required to submit these reports. This often includes power plants, large manufacturing operations, refineries, chemical facilities, and other major emission sources.
In many states, the report also forms the basis for annual emissions-based fees, which means accuracy is critical.
How should companies prepare for the reporting deadline?
Preparation usually starts with gathering operational data from the previous year. Fuel usage, production volumes, and continuous emissions monitoring data are data that may be required to calculate annual emissions.
Facilities should also confirm submission procedures in advance, since many states require electronic reporting through dedicated environmental reporting systems.
DOT Hazardous Materials Registration (Due June 30, 2026)
What is the DOT hazardous materials registration requirement?
Companies that ship certain hazardous materials must register annually with the Pipeline and Hazardous Materials Safety Administration, part of the U.S. Department of Transportation.
The registration helps regulators track organizations involved in transporting higher-risk hazardous materials and supports national hazardous materials safety programs.
When is the 2026 hazmat registration deadline?
Organizations must submit their registration or renewal before July 1, 2026, or before engaging in any of the activities requiring registration, whichever is later to remain compliant for the 2026–2027 registration year. Registrations typically open months earlier, allowing companies to complete the process well before the deadline.
Submitting early can help avoid delays or system issues that sometimes occur as the deadline approaches.
Which organizations need to register?
Registration is generally required for companies that ship hazardous materials in quantities that require placarding during transport. This includes bulk shipments of flammable liquids, explosives, toxic inhalation hazards, and certain hazardous waste.
Many manufacturers, chemical companies, laboratories, and waste management organizations fall within this requirement.
What happens if a company fails to register?
Failing to register for the DOT Hazardous Materials program carries potentially severe legal and operational consequences. Carriers may refuse shipments to avoid their own liability, and regulators may impose full-scale DOT audits or significant penalties.
For those reasons, many EHS teams treat this as a routine annual compliance task to complete early each summer.
EPA Toxic Release Inventory Reporting (Due July 1, 2026)
What is the Toxic Release Inventory (TRI)?
The Toxic Release Inventory is a federal reporting program that tracks how certain toxic chemicals are managed by industrial facilities. Under Section 313 of the Emergency Planning and Community Right-to-Know Act (EPCRA), qualifying facilities must report releases and waste management activities involving listed TRI chemicals.
The purpose of the TRI program is to track the management of certain toxic chemicals that may pose a threat to human health and the environment. Data from TRI reporting helps support informed decision-making by companies, government agencies, non-governmental organizations, and the public.
When are TRI reports due?
TRI reports must be submitted by July 1 each year, covering the previous calendar year’s activities. In 2026, facilities will report chemical releases and waste management data from 2025.
Because the data becomes publicly accessible, organizations should carefully review submissions before finalizing them.
Which facilities must file TRI reports?
Facilities generally must report if they operate in certain industry sectors, employ at least ten full-time employees, and manufacture, process, or otherwise use TRI chemicals in excess of the reporting thresholds of 25,000 pounds per year (lb/yr) for the manufacture and process categories or 10,000 lb/yr for the otherwise use category.
Common reportable substances include solvents, acids, metals such as lead or mercury, and various industrial chemicals used in manufacturing processes.
Are PFAS included in TRI reporting?
Yes. In recent years, EPA has expanded the TRI chemical list to include more than 200 per- and polyfluoroalkyl substances (PFAS). All TRI-listed PFAS are designated as ""chemicals of special concern,"" which strictly mandates a low reporting threshold of 100 pounds and eliminates the de minimis exemption.
Because the list continues to grow, facilities should review updates each year to determine whether any newly listed chemicals apply to their operations.
California Climate Disclosure (SB 253), Reports Due August 10, 2026
What is California’s SB 253 climate disclosure law?
The Climate Corporate Data Accountability Act requires large companies doing business in California to disclose their greenhouse gas emissions annually.
The rule is administered by the California Air Resources Board and represents one of the first mandatory climate disclosure programs in the United States.
When do companies need to begin reporting?
The first reporting deadline is August 10, 2026. Companies will submit their Scope 1 and Scope 2 greenhouse gas emissions covering fiscal year 2025. These disclosures will be published publicly, making them visible to investors, regulators, and the broader public.
Which companies are covered by the law?
The requirement applies primarily to companies generating more than $1 billion in annual revenue that conduct business in California.
Although the rule targets large organizations, many smaller companies may still be affected as suppliers begin requesting emissions data to support their own reporting obligations.
What preparation steps should companies take now?
Organizations should begin establishing greenhouse gas inventories if they have not already done so. That includes collecting energy consumption data, defining organizational boundaries, and identifying emission sources.
Because the rule requires independent verification, companies may also need to engage third-party auditors to review and validate their emissions calculations.
California Workplace Violence Prevention (SB 553)
What does California’s workplace violence law require?
California’s SB 553 requires most employers with at least ten employees at a worksite to implement a written Workplace Violence Prevention Plan.
The rule also mandates employee training, recordkeeping, and the maintenance of a workplace violence incident log.
When did the law take effect?
The law became enforceable July 1, 2024. By that date, covered employers were required to have their prevention plans and training programs in place.
By 2026, regulators expect organizations to demonstrate that these programs are fully implemented and functioning.
Which employers are covered?
The rule applies to most non-healthcare workplaces across California, including offices, warehouses, manufacturing facilities, and retail environments.
Healthcare settings are generally subject to separate workplace violence prevention regulations that already existed before SB 553.
Are additional regulatory updates expected?
Yes. California regulators are expected to adopt a formal workplace violence prevention regulation for general industry by December 31, 2026. This rulemaking process may clarify enforcement expectations and further refine employer responsibilities.
EPA PFAS Reporting Rule (Due October 13, 2026)
What is the PFAS reporting rule?
The Environmental Protection Agency has introduced a one-time reporting requirement for companies that manufactured or imported PFAS chemicals under the Toxic Substances Control Act.
The rule requires organizations to disclose PFAS production and use information covering activities dating back to 2011.
When is the reporting deadline?
Companies must submit their PFAS reports by October 13, 2026. The deadline was extended from earlier proposals to allow additional time for data collection.
Because the report covers more than a decade of activity, many organizations are already conducting internal reviews and supplier outreach.
Which companies are affected?
The rule applies broadly to organizations that manufactured, imported, or used PFAS in manufacturing processes. This includes chemical manufacturers as well as companies importing products that contain PFAS-based coatings or materials.
Industries ranging from electronics and aerospace to apparel and packaging may find themselves subject to the reporting requirement.
Why is the PFAS report such a large undertaking?
Unlike typical annual reporting programs, this rule requires companies to review fifteen years of historical activity. That means digging through old purchasing records, safety data sheets, and supplier documentation.
The information collected will help regulators better understand how PFAS chemicals have been used across industries and may inform future regulatory actions.
What are the potential impacts of the proposed regulation revision?
EPA is currently finalizing the November 2025 proposed revision to the PFAS 8(a)(7) rule. This finalization will shift the start of the reporting window from April 13, 2026, to 60 days following the effective date of the regulation revision and shorten the reporting window from six months to three.
The rule also narrows the scope of reporting by allowing for de minimis, imported articles, research and development, and byproducts, impurities, and non-isolated intermediate exemptions.
OSHA Hazard Communication Standard Updates (Employer Deadline November 20, 2026)
What changes were made to the Hazard Communication Standard?
The Occupational Safety and Health Administration (OSHA) updated its Hazard Communication Standard to align with the Globally Harmonized System Revision 7.
The update introduces new hazard classifications and labeling elements intended to improve consistency in chemical hazard communication.
When must employers comply?
Employers who are handling pure substances must update their workplace hazard communication programs by November 20, 2026. Employers who are handling chemical mixtures have a compliance deadline of May 19, 2028.
Manufacturers and importers have earlier deadlines to update chemical labels and safety data sheets (by May 2026 for substances and November 2027 for mixtures).
What changes will employers need to make?
Organizations should ensure all chemical labels reflect the updated classification criteria and that safety data sheets are current. Written hazard communication programs and employee training materials may also require updates.
Employees should understand any new hazard symbols or label language that appear under the revised system.
Why is this update important for compliance?
Hazard Communication consistently ranks among the most frequently cited standards during OSHA inspections. Updating labeling systems, training materials, and documentation before the deadline helps reduce the risk of citations while ensuring workers have accurate chemical safety information.
