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California Facilities Face New Federal PFAS TRI Reporting Requirements 

March 28, 2025

Quick Facts:

• A facility is required to report under the Toxic Release Inventory (TRI) Program if it meets chemical activity thresholds and is either a covered industry sector (based on NAICS code) and exceeds the employee threshold, or specifically required to report based on a determination by the Administrator under the Emergency Planning and Community Right-to-Know Act (EPCRA) 313(b)(2).
• The United States Environmental Protection Agency (U.S. EPA) designated per- and polyfluoroalkyl substances (PFAS) “chemicals of special concern,” effective for Reporting Year (RY) 2024, which has a report due date of July 1, 2025.
• Effective for RY2024, de minimis exemption is no longer available for PFAS—even trace amounts of PFAS must now be assessed and reported by July 1, 2025.
• The addition of nine new PFAS chemicals for RY2025 is postponed until March 21, 2025, or later, but TRI PFAS reporting requirements for previously listed PFAS remain unchanged.
• California industries most impacted include industrial processing, manufacturing, mining, electric utilities, hazardous waste treatment, and petroleum terminals.

TRI Reporting Requirements

• Belonging to a covered industry sector, and then exceeding the employee threshold; or
• Specifically required to report, based on a determination by the Administrator under EPCRA 313(b)(2).

To determine whether a facility is covered under the TRI Program, the facility needs to verify whether its primary NAICS code is included under the list of 400 TRI-Covered NAICS Codes. Once verified, the facility determines whether it has at least ten full-time employees or equivalent. If the facility meets both the covered industry sector and the employee threshold, an assessment of chemical activity for TRI-listed chemicals is needed to determine whether TRI reporting is required.

1. Manufacturing;
2. Processing; and
3. Otherwise use.

Each category is assigned a different limit for each TRI-Listed Chemicals.

In general, the TRI reporting thresholds are 25,000 pounds (lbs) each for manufacturing and processing and 10,000 lbs for otherwise use. However, some of the TRI-Listed Chemicals are designated as “chemicals of special concern.” This includes Persistent Bioaccumulative Toxics (PBT) chemicals, which are assigned a much lower reporting threshold.

PFAS TRI Background

Beginning with RY2024, PFAS are designated as “chemicals of special concern.” Given the designation, many facilities that were not previously subject to TRI reporting yet meet both (a) the covered industry sector and (b) the employee threshold, will now be required to submit a TRI reporting of their PFAS releases. This change follows the elimination of the de minimis exemption, which had previously allowed facilities to omit reporting PFAS if they were found to be in small concentration, below the de minimis exemption. As a result, businesses must now track, assess, and report even a small concentration of PFAS, significantly expanding compliance requirements.  

Understanding these PFAS TRI updates, and the new impacts they impose on covered industry sectors, will be crucial for ensuring your facility is compliant.​ Facilities are advised to begin tracking PFAS usage and manufacturing activities starting January 1, 2024, to ensure readiness for the first reporting deadline, which is set for July 1, 2025. ​ In California, industries such as manufacturing, mining, utilities, and petroleum are among those most impacted. 

For RY2025, nine new PFAS chemicals will be added to the EPA TRI list, bringing the total to 205 PFAS chemicals. However, the EPA has delayed the effective date for the addition of these nine new chemicals until later in the year. While this postponement does not eliminate the reporting requirement for these new chemicals, it does provide facilities additional time to prepare.  

Three Actions Facility Operators Should Take Now

Yorke Engineering LLC has assisted over 2,000 clients in California with environmental, health, safety compliance, engineering, and permitting issues. If you would like help with your TRI reporting or PFAS education, please contact us at the link below.  

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