The U.S. Environmental Protection Agency (EPA) announced on January 3, 2025, the automatic addition of nine per- and polyfluoroalkyl substances (PFAS) to the list of chemicals covered by the Toxics Release Inventory (TRI).
TRI data is reported to EPA annually by facilities in designated industry sectors and federal facilities that manufacture, process, or otherwise use TRI-listed chemicals above set quantities. The data include quantities of such chemicals that were released into the environment or otherwise managed as waste.
Information collected through TRI allows communities to learn how facilities in their area are managing listed chemicals. The data collected is available online and helps to support informed decision-making by companies, government agencies, non-governmental organizations and the public.
Adding new chemicals to the TRI advances the Biden-Harris Administration’s environmental justice commitments by improving accountability and transparency for families, workers, and communities across the country.
“EPA continues to make strides in getting information on PFAS into the Toxics Release Inventory so the public can see if these chemicals are being released into their communities,” said Assistant Administrator for the Office of Chemical Safety and Pollution Prevention Michal Freedhoff in a press release. “People have a right to know when facilities in their backyards are releasing toxic chemicals into the environment and with today’s action, we are providing important information about nine more.”
These nine PFAS were added to the TRI list pursuant to the Fiscal Year 2020 National Defense Authorization Act (NDAA), which provides the framework for the automatic addition of PFAS to TRI each year in response to specified EPA activities involving such PFAS. For TRI Reporting Year 2025 (reporting forms due by July 1, 2026), reporting is required for these nine additional PFAS, bringing the total PFAS subject to TRI reporting to 205.
Nine PFAS added to TRI list
The 2020 NDAA includes a provision that automatically adds PFAS to the TRI list upon the Agency’s finalization of a toxicity value. The nine PFAS were automatically added for Reporting Year 2025 due to EPA having finalized a toxicity value during 2024 and whose identity is not claimed as confidential business information. These nine PFAS are:
- Ammonium perfluorodecanoate (PFDA NH4) (3108-42-7)
- Sodium perfluorodecanoate (PFDA-Na) (3830-45-3)
- Perfluoro-3-methoxypropanoic acid (377-73-1)
- 6:2 Fluorotelomer sulfonate acid (27619-97-2)
- 6:2 Fluorotelomer sulfonate anion (425670-75-3)
- 6:2 Fluorotelomer sulfonate potassium salt (59587-38-1)
- 6:2 Fluorotelomer sulfonate ammonium salt (59587-39-2)
- 6:2 Fluorotelomer sulfonate sodium salt (27619-94-9)
- Acetic acid, [(γ-ω-perfluoro-C8-10-alkyl)thio] derivs., Bu esters (3030471-22-5)
Addition of PFAS no longer claimed as confidential business information
Under NDAA section 7321(e), EPA must review CBI claims before adding a PFAS to the TRI list if the chemical identity is subject to a claim of protection from disclosure under 5 U.S.C. 552(a). EPA previously identified Acetic acid, [(γ-ω-perfluoro-C8-10-alkyl)thio] derivs., Bu esters for addition to the TRI list based on the NDAA’s provision to include specific PFAS upon the NDAA’s enactment. However, due to CBI claims related to its identity, this PFAS was not added to the TRI list at that time. The identity of this chemical was subsequently declassified in an update to the Toxic Substances Control Act Inventory in May 2024. Because its identity is no longer confidential, it was added to the TRI list.
As of January 1, 2025, facilities that are subject to reporting requirements for these chemicals should begin tracking their activities involving these PFAS as required by Section 313 of the Emergency Planning and Community Right-to-Know Act. Reporting forms will be due by July 1, 2026.
These nine newly added PFAS, along with the previous 196 TRI-listed PFAS, are also subject to EPA’s action in October 2023 to classify all PFAS subject to TRI reporting as chemicals of special concern. Among other impacts, this removes the use of a reporting exemption that allowed facilities to avoid reporting information on PFAS when those chemicals were used in small concentrations.
