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TRI reporting and Form R: who files, the thresholds, and July 1

Published by Vertexium Environmental Solutions LLC · Last updated October 9, 2026

Toxics Release Inventory (TRI) reporting under EPCRA section 313 applies to facilities in covered industries with 10 or more full-time-equivalent employees that manufacture, process or otherwise use a listed chemical above its threshold. Each qualifying chemical needs a Form R (or the shorter Form A, if eligible), filed by July 1 for the previous calendar year in EPA's TRI-MEweb.

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The three tests

A facility must report for a TRI-listed chemical if all three are true (EPA TRI basics, RY2025; EPA):

  1. Industry: the facility's NAICS code is in a TRI-covered sector (manufacturing, metal mining, electric utilities burning coal or oil, hazardous waste treatment, chemical wholesale, petroleum bulk terminals, federal facilities and others).
  2. Employees: 10 or more full-time employee equivalents (20,000 hours worked in the year).
  3. Activity threshold: the chemical exceeded a threshold during the year.

Thresholds

ActivityThreshold (most listed chemicals)
Manufactured (including imported)more than 25,000 lb per year
Processedmore than 25,000 lb per year
Otherwise usedmore than 10,000 lb per year

Persistent, bioaccumulative and toxic (PBT) chemicals such as lead, mercury and dioxins have much lower thresholds (as low as 0.1 gram for dioxin-like compounds). Thresholds are annual amounts, not amounts on site, which is the key difference from Tier II (EPA).

Form R or Form A

Form R is the full report: on-site releases to air, water and land, off-site transfers, waste management quantities and source reduction. Form A is a two-page certification statement you can use instead for a non-PBT chemical when the total annual reportable amount is 500 lb or less and the amount manufactured, processed or otherwise used is 1 million lb or less (EPA, Form A eligibility). PBT chemicals always need Form R.

How and when to file

Common mistakes

Penalties

EPCRA section 325(c)(1) civil penalties also cover section 313. EPA's current maximum is $71,545 per violation (40 CFR 19.4).

Sources

  1. EPA, TRI Reporting Basic Concepts (RY2025)
  2. EPA, TRI Reporting Forms and Instructions (RY2025)
  3. EPA, TRI Form A eligibility
  4. EPA, Reporting for TRI facilities
  5. 40 CFR 19.4

Related guides

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We prepare Tier II reports for a fixed price

From $1,250 per facility (up to 30 chemicals), built in your state's system and ready for your official to certify before March 1. TRI Form R from $1,500.