Reporting for TRI Facilities

• A facility is required to report if it meets chemical activity thresholds and
  • is either in a covered industry sector and exceeds the employee threshold, or
  • is specifically required to report based a determination by the Administrator under EPCRA 313(b)(2).
    • List of covered industry sectors
    • List of covered chemicals and chemical categories
    • List of facilities required to report under EPCRA 313(b)(2)
    • Guidance on full-time employee determination
• The TRI Threshold Screening Tool can help you determine if your facility is required to report.
• Browse the TRI Reporting Forms and Instructions (RFI) for more details.

How is TRI Reporting Related to Tier II Reporting?

TRI reporting is required under Section 313 of the Emergency Planning and Community Right-to-Know Act (EPCRA). Tier II reporting is required under Section 312 of EPCRA. TRI reporting requirements are separate and distinct from Tier II reporting requirements. Submitting TRI reporting forms does not fulfill a facility's Tier II reporting requirements, or vice versa. For more about what EPCRA requires, see the EPCRA factsheet or quick guide.

Overview of the TRI Reporting Process

The image below summarizes the TRI reporting process. For more detailed information about each step, refer to the TRI Reporting Forms and Instructions.

Reporting Changes for RY 2022

The changes below apply to RY 2022 TRI forms, which are due to EPA by July 1, 2023.

• The Fiscal Year 2020 National Defense Authorization Act (NDAA) added four per- and polyfluoroalkyl substances (PFAS) to the TRI list. These are:
  • perfluorobutane sulfonic acid (375-73-5),
  • potassium perfluorobutane sulfonate (29420-49-3),
  • perfluorobutanesulfonate (45187-15-3), and
  • 2-Propenoic acid, 2-methyl-, hexadecyl ester, polymers with 2-hydroxyethyl methacrylate, γ-ω-perfluoro-C10-16-alkyl acrylate and stearyl methacrylate (203743-03-7)

• Per the requirements of 40 CFR §372.38(a), the de minimis levels for aniline (62-53-3) and acrolein (107-02-8) have been changed from 1.0% to 0.1% since these chemicals are classified as carcinogens due to assessments by the International Agency for Research on Cancer.

• EPA published a final rule to add natural gas processing facilities to the scope of facilities covered by the TRI. This rule expands coverage to include all natural gas processing facilities that receive and refine natural gas. Facilities that primarily recover sulfur from natural gas were already covered by TRI. Facilities primarily engaged in natural gas extraction (e.g., exploration, fracking) are not included in this rule. 

• EPA issued a determination extending TRI reporting requirements for ethylene oxide (EtO) to 29 contract sterilization facilities. This determination also included reporting requirements for ethylene glycol for 16 of these facilities. 

• EPA published a final rule to codify the definition of “parent company” for TRI reporting purposes. The rule clarifies existing requirements to reporting facilities and adds a foreign parent company data element, if applicable. Starting with RY 2022, facilities must enter their parent company information as codified in the following data elements: 
  • Part I, Section 5.1: Highest-level U.S.-based parent company
  • Part I, Section 5.2: Dun & Bradstreet number of highest-level U.S.-based parent company

• EPA published a final rule to adopt 2022 NAICS codes. This final rule updates the NAICS list from 2017 codes to 2022 codes and does not alter the universe of facilities required to report to TRI. As a result of the updates, 54 TRI-covered NAICS codes have changed. Table I of the TRI RFI lists all TRI-covered industry sectors and their corresponding codes.

How Will EPA and Others Use Your Facility's Data?

The TRI data your facility submits are critically important and widely used—not only by EPA, but by public health and policy researchers, educators, local emergency planners, state technical assistance providers, community groups, prospective home buyers, and others.

EPA uses TRI data in many ways and for many purposes. These include:

• assessing trends in chemical waste management,
• evaluating industry progress in improving environmental performance,
• informing pollution prevention technical assistance,
• supporting chemical assessments under the Toxic Substances Control Act, and
• supplementing data in the National Emissions Inventory.

The timely submission of accurate data by your facility enables all of these important uses, and more. To see examples of how TRI data submitted by facilities like yours are being used, visit the TRI in Action webpage.

TRI Training and Guidance Materials

GuideME

Information accessible via GuideME includes reporting instructions, the TRI chemical list, chemical- and industry-specific guidance, policy directives, training materials, questions and answers, and more.

Emissions Factors Guidance

EPA publishes emissions factors that apply to multiple chemicals and processes. Facilities that are subject to TRI reporting requirements may find these emission factors useful for estimating reportable quantities of TRI chemicals.

• AP-42: Compilation of Air Emissions Factors
• Emissions Estimation Tools
• WebFIRE Emissions Factors Database
• Locating and Estimating Air Toxic Emissions Documents