The U.S. Environmental Protection Agency has proposed adding 16 individual PFAS chemicals and 15 PFAS categories representing more than 100 individual substances to the Toxics Release Inventory, while simultaneously releasing proposals to modify existing PFAS reporting requirements that have imposed a nearly billion-dollar compliance burden on industry, according to EPA announcements.
New TRI Reporting Requirements Target Over 100 PFAS Chemicals
The EPA's October 2024 proposal would significantly expand public access to information about per- and polyfluoroalkyl substances by adding 16 individual PFAS and 15 PFAS categories to the Toxics Release Inventory, according to EPA press releases. These chemicals would be designated as chemicals of special concern, requiring more robust reporting requirements including reporting even for small concentrations.
The expansion builds on existing PFAS reporting requirements established under the National Defense Authorization Act for Fiscal Year 2020, which created a framework for adding PFAS to the TRI annually, according to Hklaw analysis. Since the NDAA's implementation, the number of TRI-listed PFAS chemicals has grown from 172 individual chemicals initially to 196 individual chemicals reportable for reporting year 2024, with a reporting deadline of July 1, 2025, Hklaw reported.
"With this rule, EPA would be able to collect data on how more than a hundred PFAS are released into the environment through Toxics Release Inventory reporting requirements," said Assistant Administrator for the Office of Chemical Safety and Pollution Prevention Michal Freedhoff, according to EPA statements. "This information will help EPA and communities better understand how PFAS are being used and managed across the country."
Parallel Effort to Address Implementation Challenges
While expanding TRI requirements, the EPA simultaneously released a separate proposal on November 10, 2025, aimed at making existing PFAS reporting regulations under the Toxic Substances Control Act more practical and implementable, according to EPA announcements. This proposal addresses significant challenges that have emerged from the Biden Administration's finalized one-time PFAS reporting and recordkeeping regulation under TSCA section 8(a)(7).
The existing TSCA rule requires manufacturers and importers of PFAS used in any year between 2011-2022 to report data to EPA related to exposure and existing environmental and health effects, according to EPA documentation. However, implementation has been plagued by significant IT system failures and administrative delays, representing what critics describe as poor regulatory design that unnecessarily burdens small businesses while failing to achieve meaningful environmental outcomes, EPA sources acknowledged.
Health and Environmental Justification for Enhanced Oversight
The expanded reporting requirements target a class of chemicals that pose significant public health concerns. PFAS are a group of more than 14,000 human-made substances that are resistant to heat, water, and oil, making them useful in consumer, commercial, and industrial products but also persistent in the environment, according to Waterboards documentation.
The health implications are substantial: PFAS have been found in the blood serum of nearly all people tested in several national studies, according to Waterboards research. Exposure to PFAS may result in adverse health effects including developmental effects to fetuses during pregnancy, cancer, liver effects, immune effects, and thyroid effects, Waterboards reported. The PFAS being proposed for TRI addition are specifically linked to health outcomes such as cancer, according to EPA findings.
EPA's broader PFAS regulatory efforts have shown measurable impact. The agency's first-ever national drinking water standard for PFAS, finalized in April 2024, will reduce PFAS exposure for approximately 100 million people, according to EPA estimates.
Regulatory Framework and Compliance Requirements
The TRI program operates under established legal frameworks dating back decades. The Emergency Planning and Community Right-to-Know Act, established in 1986, created the foundation for toxics reporting, while Section 313 of EPCRA specifically created the Toxics Release Inventory program, according to Hklaw analysis. The Pollution Prevention Act of 1990 further refined the program to collect data on industry waste generation and progress toward sustainable waste management.
Under current requirements, facilities must complete and submit a toxic chemical release inventory form (Form R) annually for applicable chemicals manufactured and used above applicable threshold quantities, which for PFAS is set at 100 pounds for manufacture, processing and other uses, according to regulatory documentation. Mandated reporters must also provide descriptions of ongoing measures to reduce sources of pollution, Hklaw noted.
PFAS compounds are automatically added to the upcoming fiscal year's TRI enforcement list if specific conditions are met, including when the EPA Administrator finalizes a toxicity value for the PFAS or class of PFAS before January 1 of the upcoming reporting period, according to Hklaw analysis.
Industry Impact and Implementation Concerns
The regulatory burden on industry has been substantial. The existing TSCA reporting rule exemplifies what critics call regulatory overreach by imposing a nearly billion-dollar compliance burden on industry without establishing clear frameworks for utilizing collected data or demonstrating advancement of environmental protection goals, according to EPA acknowledgments.
Small businesses and importers face particular challenges with implementation standards that have proven problematic, evidenced by the significant IT system failures and administrative delays that have characterized the program's rollout, EPA sources confirmed. The November 2025 proposal to modify TSCA requirements represents EPA's attempt to address these practical implementation issues while maintaining the ability to obtain important use and safety information on PFAS.
Environmental Justice and Public Access Goals
The expanded TRI requirements align with broader Biden-Harris Administration environmental justice commitments and the Administration's cancer prevention goals under the Biden Cancer Moonshot initiative, according to EPA statements. The TRI program allows individuals, researchers, and other actors to track and analyze chemical trends, providing communities with data to identify sources of pollution and ways facilities can eliminate or reduce such pollution.
InsideEPA reporting indicates that EPA's approach reflects ongoing tensions between environmental protection goals and industry compliance capabilities, as the agency attempts to balance comprehensive chemical oversight with practical regulatory implementation. The dual approach of expanding reporting requirements while simultaneously addressing implementation challenges demonstrates EPA's recognition that effective environmental protection requires both robust data collection and workable compliance frameworks.