How to Complete EPA TRI Form R: Thresholds, Form A, and Penalties

To complete EPA TRI Form R, confirm your facility meets all three reporting criteria, gather the threshold, release, and waste-management data for each covered chemical, enter Part I and Part II in the TRI-MEweb application inside EPA’s Central Data Exchange (CDX), and have your Certifying Official electronically sign and transmit the form by July 1 for the previous calendar year’s activity.¹ A copy also goes to the state or tribal authority where the facility sits, which TRI-MEweb handles automatically for most states.

Confirm You Actually Have to File

Three conditions must all be true before a facility owes a Form R. The facility operates under a TRI-covered NAICS code (manufacturing, metal mining, electric power generation, chemical wholesale distribution, and petroleum bulk stations are on the list, among others).² It has the equivalent of 10 or more full-time employees, calculated as 20,000 or more total work hours in the year across full-time, part-time, and contract workers.³ And it manufactured, processed, or otherwise used a listed chemical above the applicable threshold — 25,000 pounds for manufactured or processed, 10,000 pounds for otherwise used, for most chemicals.⁴ Federal facilities that meet the employee and chemical criteria report regardless of NAICS code.⁵

You file a separate Form R for each chemical that crosses its threshold.

Lower Thresholds for PBT and PFAS Chemicals

Persistent, bioaccumulative, and toxic (PBT) chemicals have three tiered thresholds under 40 CFR 372.28:⁴

100 pounds for chemicals of special concern in Table 1, including lead, lead compounds, mercury, and mercury compounds.
10 pounds for Table 2 chemicals such as certain polycyclic aromatic compounds and aldrin/dieldrin.
0.1 grams for dioxin and dioxin-like compounds, low enough that trace quantities trigger a report.⁶

PFAS are also classified as chemicals of special concern. For reporting year 2026, EPA added sodium perfluorohexanesulfonate (PFHxS-Na, CAS 82382-12-5) effective January 1, 2026. Facilities that manufacture, process, or otherwise use 100 or more pounds during 2026 must file by July 1, 2027.⁷ Because PFAS are chemicals of special concern, the de minimis exemption does not apply, and suppliers must notify downstream TRI-covered facilities of any PFAS present in mixtures or trade-name products regardless of concentration.⁸

Review procurement logs, production records, and waste manifests through the year. A facility that discovers in December it crossed a threshold has only six months to assemble accurate data for the July 1 filing.

Check Exemptions Before You Calculate

Two common exemptions can reduce what counts toward a threshold. Applying one incorrectly is a fast way to draw an enforcement action, so document the reasoning.

The de minimis concentration exemption lets you exclude a TRI chemical present in a mixture at less than 1 percent of the mixture (0.1 percent for chemicals classified as carcinogens by the National Toxicology Program’s Report on Carcinogens, IARC Monographs, or OSHA’s list) when determining whether you hit a threshold.⁹ It does not apply to any PBT chemical listed under 40 CFR 372.28, and it does not apply to PFAS designated as chemicals of special concern.

The article exemption covers a manufactured item formed to a specific shape, whose function depends on that shape, that does not release a toxic chemical under normal processing or use.¹⁰ The moment processing produces a release — grinding metal parts and generating lead dust, for example — the item stops qualifying and those releases must be counted. The article exemption still applies to PFAS-containing items if the item genuinely meets the definition.

Set Up CDX and TRI-MEweb Access Early

All TRI reporting goes through TRI-MEweb inside the EPA’s Central Data Exchange.¹¹ If your facility hasn’t reported before, or the Certifying Official has changed, start well before July 1. The Electronic Signature Agreement approval alone can take up to five business days, and you cannot certify any forms until it clears.

Register for a CDX account and choose a role: Certifying Official (legally signs the data) or Preparer (enters and reviews but cannot certify). Add the TRI-MEweb program role to your profile and associate your facility’s TRI Facility Identification (TRIFID) numbers.

Inside TRI-MEweb, the Certifying Official generates the ESA after entering the facility TRIFIDs, prints it, signs it, and mails the signed copy to:¹²

U.S. Environmental Protection Agency
Attention: TRI Reporting Center
PO Box 10163
Fairfax, VA 22038

An uncertified form is not considered submitted, so build the ESA lead time into your schedule.

What Goes on Form R

Part I: Facility Identification

Part I collects the physical street address, mailing address if different, technical contact name and phone, parent company name and Dun & Bradstreet number, the facility’s primary NAICS code, and latitude/longitude coordinates.¹³ TRI-MEweb carries prior-year data forward automatically, but verify every field. Address and contact errors have triggered data quality flags in past cycles.

Part II: Chemical-Specific Information

File a separate Part II for each chemical that crossed its threshold. The major sections require:

Chemical identity — the exact name, CAS number, and whether you manufactured, processed, or otherwise used it.
Maximum amount on-site — the peak quantity present at any point during the year, reported as a range code.
Releases to the environment — fugitive air emissions, stack or point-source air emissions, discharges to surface water, underground injection, and releases to land such as landfills or surface impoundments.¹⁴
Off-site transfers — quantities sent to publicly owned treatment works (POTWs) and other off-site facilities for recycling, energy recovery, treatment, or disposal.⁵
On-site waste management — quantities recycled, treated, or combusted for energy recovery at your own facility.
Source reduction and pollution prevention activities undertaken during the year.

Estimation Methods

Direct monitoring is the gold standard. Most facilities also use engineering estimates, published emission factors, and mass-balance calculations. The form asks you to identify the estimation method for each release figure, so keep methodology notes with the underlying data. If you used a factor from EPA’s AP-42 database or a permit-specific model, record the factor, the production parameter you multiplied it by, and the source.

One-time events count. A spill that sent a TRI chemical into soil is a release to land; evaporative losses from a cleanup are fugitive air emissions.¹⁴ EPA’s definition of “release” covers any entry of a chemical into the environment, so anomalies belong in the totals.

Validate, Certify, and Transmit

TRI-MEweb runs validation checks before it will let you transmit. The system flags large year-over-year swings in release quantities without explanation, volatile organic chemicals on site paired with implausibly low air-release numbers, and identical quantities repeated across multiple form sections for more than two years.¹⁵ Fix flagged items before transmitting. EPA reviews the same patterns during post-submission audits.

The Certifying Official reviews the completed form, certifies it electronically, and transmits it through CDX. The system generates an electronic receipt; save it as proof of timely filing. The July 1 deadline covers the preceding calendar year, and a copy must reach the state or tribal authority where the facility sits.¹ TRI-MEweb handles state transmission for most states through the TRI Data Exchange. Check whether your state requires a separate submission or charges a processing fee.

Watch your CDX inbox after you submit. EPA occasionally sends follow-up data quality notices on outlier values, and a prompt response keeps a routine inquiry from becoming an enforcement matter.

Form A: When You Can File the Short Version

Not every reportable chemical requires the full Form R. If the combined total of releases, disposal, treatment, recycling, and energy recovery for a chemical does not exceed 500 pounds for the year, you may qualify to file the shorter Form A certification statement. To qualify, the chemical must also not be manufactured or processed above one million pounds, and it must not be a PBT chemical listed in 40 CFR 372.28.¹⁶

Form A requires facility identification, chemical identity, and a certification that you meet the alternate threshold conditions. Same July 1 deadline, same CDX submission process, same three-year recordkeeping duty. Document how you determined eligibility, because EPA may audit the alternate-threshold calculation.

Trade Secret Claims

A facility may withhold the specific chemical identity if it qualifies as a trade secret under 40 CFR Part 350, but the process is demanding. You submit four documents simultaneously with your regular report:¹⁷

An unsanitized Form R with the actual chemical name and CAS number, sent to EPA.
A sanitized Form R replacing the chemical identity with a generic category name, sent to your state emergency response commission (SERC), local emergency planning committee (LEPC), and local fire department.
An unsanitized substantiation form answering six justification questions, sent to EPA.
A sanitized substantiation form with the generic category name, sent to local authorities.

Mail the claim package to: EPCRA Trade Secrets, c/o CGI Federal, Inc., 12601 Fair Lakes Circle, Fairfax, VA 22033. Sending the unsanitized version to local authorities invalidates the claim entirely. A separate set of substantiation forms is required for each chemical claimed.

Corrections, Recordkeeping, and Penalties

You can revise submissions through TRI-MEweb for any reporting year from 1991 through the current year. Each revision requires a reason code — new monitoring data, new emission factors, new chemical concentration data, recalculations, or other reasons — and the revised form goes to both EPA and the applicable state or tribal authority. EPA may still pursue enforcement for errors that resulted from ignoring readily available data, omitting a major emission source, serious math or transcription mistakes, or failing to keep records showing how a release estimate was derived. Filing a revision does not immunize you from penalties for the original mistake. If a form was filed for a chemical you were never required to report, request a withdrawal through TRI-MEweb rather than a revision.

Every facility that files a Form R or Form A must retain supporting documentation for three years from the submission date:¹⁸

Threshold determination calculations for each chemical.
Documentation supporting any claimed exemption.
The work behind every release and off-site transfer estimate, including the estimation method used.
Waste manifests and receipts for off-site transfers.
Treatment methods, efficiency estimates, influent concentration ranges, and operating data behind those figures.

Missing July 1 or submitting materially inaccurate data can trigger civil penalties of up to $71,545 per day per violation under EPA’s current inflation-adjusted penalty schedule.¹⁹ Each chemical for which you failed to file or filed inaccurately counts as a separate violation. If your numbers change dramatically from the prior year because a new production line started or a remediation project generated one-time releases, explain the change in the form’s comments section. An unexplained spike is a red flag; a documented one is just data.

1
US EPA. Reporting for TRI Facilities
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US EPA. TRI-Covered Industry Sectors
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US EPA. TRI Threshold Screening Tool
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eCFR. 40 CFR Part 372 Subpart B – Reporting Requirements
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DENIX. Emergency Planning and Community Right-to-Know Act/Toxics Release Inventory
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US EPA. Chemical Profiles
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Lion Technology. EPA Adds PFHxS-Na to Toxics Release Inventory (TRI)
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US EPA. EPA Proposes Rule to Clarify Supplier Notification Requirements for TRI-Listed PFAS
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eCFR. 40 CFR 372.38 – Exemptions
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US EPA. Articles Exemption Clarification Proposed Rule
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US EPA. Electronic Submission of TRI Reporting Forms
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US EPA. TRI-MEweb Reference Guide 2 – How to Add Role, Add Facility
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Environmental Protection Agency. EPA TRI Form R
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US EPA. Common TRI Terms
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US EPA. TRI Data Quality
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eCFR. 40 CFR 372.27 – Alternate Threshold
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US EPA. Instructions for Completing the EPCRA Trade Secret Substantiation Form
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eCFR. 40 CFR 372.10 – Recordkeeping
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eCFR. 40 CFR 19.4 – Statutory Civil Monetary Penalties, as Adjusted for Inflation, and Tables