TRI reporting and Form R: who files, the thresholds, and July 1
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.
Need it done for you? We prepare Tier II reports for a fixed price, from $1,250 per facility. TRI Form R from $1,500.
Get a fixed quoteThe three tests
A facility must report for a TRI-listed chemical if all three are true (EPA TRI basics, RY2025; EPA):
- 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).
- Employees: 10 or more full-time employee equivalents (20,000 hours worked in the year).
- Activity threshold: the chemical exceeded a threshold during the year.
Thresholds
| Activity | Threshold (most listed chemicals) |
|---|---|
| Manufactured (including imported) | more than 25,000 lb per year |
| Processed | more than 25,000 lb per year |
| Otherwise used | more 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
- Deadline: July 1 each year, for the previous calendar year (EPA).
- System: TRI-MEweb, through EPA's Central Data Exchange (CDX). The facility's certifying official signs electronically.
- Instructions: EPA publishes annual Reporting Forms and Instructions (RY2025 RFI) with the chemical list, qualifiers and calculation guidance.
- Records: keep supporting documentation for 3 years.
Common mistakes
- Counting only purchases and missing chemicals manufactured as by-products (for example in combustion or wastewater treatment).
- Applying Tier II's "on site at one time" logic to TRI, whose thresholds are annual activity amounts.
- Missing de minimis rules or qualifiers in the chemical list (for example "fume or dust" forms).
- Using Form A for a PBT chemical.
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
- EPA, TRI Reporting Basic Concepts (RY2025)
- EPA, TRI Reporting Forms and Instructions (RY2025)
- EPA, TRI Form A eligibility
- EPA, Reporting for TRI facilities
- 40 CFR 19.4
Related guides
Need it done for you?
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.