The US Environmental Protection Agency's (EPA) Toxic Release Inventory (TRI) reporting is a familiar annual obligation for facilities handling chemicals. But as the EPA expands the list of reportable substances to 206 per- and polyfluoroalkyl substance (PFAS) chemicals (as of February 2026), the “business as usual” approach needs revisiting (learn more in EPA announces PFAS reporting changes).
For many organizations, the consideration of PFAS has introduced new TRI exposure that isn't immediately visible. This isn’t because teams aren't paying attention, but because PFAS enter operations in ways that traditional TRI processes weren't designed to catch.
Why PFAS changes the TRI risk profile
TRI data is publicly disclosed and routinely analyzed by regulators, community groups, non-governmental organizations (NGOs), and investors and often long after reporting deadlines have passed. PFAS amplifies this exposure.
- Lower reporting thresholds: Even small quantities (100 pounds) can trigger obligations.
- Removal of the de minimis exemption: As a “chemical of special concern,” reporting is now required regardless of concentration, whereas it previously wasn't triggered below 1% (or 0.1% for PFOA).
- Expanded chemical lists: Increasing applicability across a wider range of industrial processes.
- Unintentional presence: Unlike legacy TRI chemicals, PFAS are frequently not manufactured or intentionally used on-site, yet may still require reporting.
The data uncertainty this creates is significant, particularly where PFAS are present unintentionally or as trace constituents.
Where applicability is commonly missed
Being unaware of where PFAS may be entering operations is a pressing challenge for environmental, health, and safety (EHS) teams. Three blind spots appear repeatedly.
1. Trace and impurity presence
PFAS can arrive as manufacturing impurities, residuals from raw materials, or additives in coatings, lubricants, and treatment agents. These sources aren't always clearly identified in safety data sheets (SDS), making reliance on supplier documentation alone an unreliable basis for TRI determinations.
2. Articles versus chemicals misinterpretation
Facilities sometimes assume PFAS-containing articles are excluded from TRI consideration without fully evaluating processing activities, releases, or waste generation.
3. Fragmented internal ownership
PFAS applicability decisions sit at the intersection of EHS, procurement, operations, and legal. When no single function owns the determination, critical information often doesn't surface in time to support accurate reporting, increasing overall business risk management concerns.
How can EHS teams tackle these three challenges?
Since SDSs often omit PFAS below certain thresholds or hide them as “proprietary,” reliance on them is no longer sufficient for TRI compliance. The answer lies in going beyond standard documentation and targeting PFAS exposure at the source.
- Send PFAS-specific questionnaires: Don't wait for a revised SDS. Send formal inquiries to vendors asking specifically about the presence of any PFAS on the TRI list regardless of concentration.
- Audit technical data sheets (TDSs): Often, performance characteristics mentioned in a TDS (e.g., “water-resistant,” “non-stick,” “high-temperature stability”) are red flags for PFAS that aren't listed on the SDS.
- Target high-risk consumables: Focus on operational PFAS like specialized lubricants, hydraulic fluids, surfactants, and firefighting foams, which are frequently used in small volumes that still hit the 100-pound threshold.
Thresholds are only the beginning
Regulatory scrutiny is highly focused—not only on whether a facility crossed a reporting threshold, but on how that determination was made. Consistency year over year, documented assumptions, and alignment between reported data and operational reality are all under closer examination.
For PFAS specifically, this matters because analytical data is often limited, estimates rely heavily on engineering judgment, and supplier transparency varies widely. In that environment, data defensibility and a cohesive risk management strategy are as important as numerical accuracy. Facilities that cannot clearly explain why a chemical was deemed non-reportable are vulnerable to enforcement or data challenges well after submission.
From annual reporting to ongoing readiness
As PFAS reshapes TRI expectations, many organizations are reassessing how they approach compliance. This includes:
- Periodic screening of chemicals and suppliers.
- Clear internal criteria for TRI applicability decisions.
- Early alignment between Emergency Planning and Community Right-to-Know Act (EPCRA), TRI, and sustainability reporting efforts.
- Integration of PFAS into enterprise risk management programs.
The central question is no longer “Can we submit our TRI report on time?” but “Would our TRI determinations withstand scrutiny?”. With the EPA already proposing to designate nine specific PFAS as hazardous constituents under the Resource Conservation and Recovery Act (RCRA) and additional substances likely to follow, that question is only going to become more pressing.
Reviewing your TRI approach ahead of the next cycle? Download our TRI compliance checklist.
