Covered facilities complete the EPA’s TRI reporting form by submitting either Form R or the shorter Form A through TRI-MEweb, the EPA’s online reporting software, by July 1 for the previous calendar year’s data. Reporting year 2025 data is due July 1, 2026.1US EPA. Toxics Release Inventory (TRI) Program The program operates under Section 313 of the Emergency Planning and Community Right-to-Know Act and discloses toxic chemical releases and waste management to the public.2eCFR. 40 CFR 372.30 – Reporting Requirements and Schedule for Reporting
Confirm Your Facility Has to File
A facility is covered when three tests are all met in the same calendar year. Miss any one and you are not required to file that year.3eCFR. 40 CFR Part 372 Subpart B – Reporting Requirements – Section 372.22
- The facility has the equivalent of 10 or more full-time employees, measured as 20,000 or more total hours worked during the year (employees and contractors combined).3eCFR. 40 CFR Part 372 Subpart B – Reporting Requirements – Section 372.22
- The facility operates under a covered NAICS code. The list at 40 CFR 372.23 spans most of manufacturing (NAICS 311–339) plus metal mining, coal mining, coal- or oil-fired electric utilities, RCRA hazardous waste facilities, chemical wholesalers, petroleum bulk stations, and contract solvent recovery.4eCFR. 40 CFR 372.23 – SIC and NAICS Codes to Which This Part Applies
- The facility manufactures or processes more than 25,000 pounds of a listed toxic chemical, or otherwise uses more than 10,000 pounds, during the year.5eCFR. 40 CFR 372.25 – Thresholds for Reporting
Persistent bioaccumulative toxics carry far lower activity thresholds — 100 pounds, 10 pounds, or as little as 0.1 grams depending on the chemical.6eCFR. 40 CFR Part 372 – Section 372.28 Lower Thresholds for Chemicals of Special Concern Check the current list before you assume a low-volume chemical is safe from reporting.
Before running the threshold math, apply the exemptions at 40 CFR 372.38. They work chemical by chemical, not facility-wide, and can pull quantities out of the calculation entirely. The main ones cover de minimis concentrations in mixtures (below 1 percent, or 0.1 percent for carcinogens), chemicals locked into finished articles, laboratory activities under a technically qualified individual’s supervision, structural components of the facility, janitorial and grounds maintenance and personal-use items, process water and intake air, and coal extraction at mining-classified facilities.7eCFR. 40 CFR 372.38 – Exemptions One important carve-out: the de minimis exemption does not apply to PFAS, so any amount of a listed PFAS chemical in a mixture counts. Misapplying an exemption can push you into a late filing later, so document the reasoning at the time you make the call.
Choose Between Form R and Form A
Most facilities file Form R for each threshold-exceeding chemical. Form A is a shorter certification statement available only when a specific chemical’s footprint is small.
You can use Form A for a chemical when two things are true: the total annual reportable amount for that chemical is 500 pounds or less (combining on-site releases, disposal, treatment, recycling, energy recovery, and off-site transfers for those purposes), and the facility did not manufacture, process, or otherwise use more than one million pounds of that chemical during the year.8eCFR. 40 CFR 372.27 – Alternate Threshold and Certification Instead of detailed release data, a senior management official certifies that the facility stayed within those alternate thresholds.9eCFR. 40 CFR 372.95 – Alternate Threshold Certification and Instructions
Form R is longer. Part I collects facility identification, reporting year, any trade secret status, the certification signature, and parent company information. Part II holds the chemical-specific data across eight sections: chemical identity (CAS number and name), activities and uses, maximum amount on-site during the year, on-site releases to air (stack and fugitive), water, land, and underground injection, off-site transfers to publicly owned treatment works and other destinations, on-site waste treatment and recovery, and source reduction activities.10FedCenter. EPA Toxic Chemical Release Inventory Reporting Form R File a separate Form R for each chemical over threshold. Five chemicals means five forms.
Get Access to TRI-MEweb
All TRI submissions go through TRI-MEweb, which runs on the EPA’s Central Data Exchange (CDX). You need a CDX account with the right role before you can file.11United States Environmental Protection Agency. Electronic Submission of TRI Reporting Forms
Preparer or Certifying Official
A Preparer can enter and edit form data but cannot submit. A Certifying Official can do everything a preparer does and also certify and transmit the finished forms to the EPA and the state agency. The certifying official must have authority at the facility, typically a president, plant manager, or chief of operations, or the facility’s legal representative.12U.S. Environmental Protection Agency. TRI-MEweb Reference Guide – How to Add Role, Add Facility, and Generate an ESA
Electronic Signature Agreement
Every certifying official has to complete an Electronic Signature Agreement (ESA) before submitting anything. The fast path is electronic identity verification through LexisNexis during CDX registration; pass, and the ESA is signed online instantly. If verification fails, you print, sign, and mail the paper ESA, and the EPA takes up to five business days to process it after receipt.12U.S. Environmental Protection Agency. TRI-MEweb Reference Guide – How to Add Role, Add Facility, and Generate an ESA Do not register in late June. A paper ESA still in processing on July 1 means you cannot submit on time.
Complete and Transmit the Form
Once the ESA is approved, the certifying official logs into CDX at cdx.epa.gov and launches TRI-MEweb. The software walks through each section of Form R or Form A and runs validation checks as you enter data. When a form is complete, the certifying official certifies and transmits it, and TRI-MEweb sends the report to the EPA and the appropriate state environmental agency at the same time.11United States Environmental Protection Agency. Electronic Submission of TRI Reporting Forms
The system generates an electronic receipt with a tracking number and timestamp on transmission. Keep it. That receipt is your proof of timely filing.
After submission, the EPA runs automated data quality checks that flag large year-over-year swings in release quantities, inconsistencies between reported VOC use and air emissions, data that conflicts with other EPA program reports, and forms that were transmitted but never formally certified.13US EPA. TRI Data Quality If something is flagged, you will be notified and may need to go back in to correct the record.
Revise or Withdraw a Filed Report
Errors happen: a wrong CAS number, an off release estimate, or a form filed for a chemical that was actually below threshold. For reporting years 2005 onward, revisions and withdrawals go through TRI-MEweb.14Federal Register. Electronic Reporting of Toxics Release Inventory Data
To revise, open the original submission in TRI-MEweb, update the relevant fields, and resubmit. The system keeps both the original and the revision. There is no penalty for voluntary corrections, and the EPA encourages facilities to fix errors rather than leave inaccurate data in the public database.
To withdraw a form entirely, submit a withdrawal request including the TRI facility identification number, reporting year, chemical name, contact information, and the specific reason. A full withdrawal fits situations where the form should never have been filed at all: the chemical was actually below threshold, an exemption applied, or the chemical was removed from the TRI list. Send a copy to the state agency if it requires one.
Keep the Supporting Records
Every filer must keep supporting records for three years from the submission date, including the data used to calculate release estimates, threshold determinations, and any documentation supporting a Form A alternate threshold certification.15eCFR. 40 CFR 372.10 – Recordkeeping Many environmental managers hold records longer, because enforcement actions and citizen inquiries can surface after the minimum retention window closes.
What Non-Compliance Costs
Failing to report, filing late, or submitting inaccurate data can draw civil penalties of up to $71,545 per day per violation under the current inflation adjustment.16eCFR. 40 CFR 19.4 – Statutory Civil Monetary Penalties, as Adjusted for Inflation Each unreported chemical at a facility is a separate violation, and the per-day count runs from the original due date. TRI data is also public, so gaps and inconsistencies attract attention from community groups and state regulators on their own timeline.