Plain answer

For TRI, evaluate each listed PFAS using the reporting year's chemical list and the applicable 100-pound activity threshold. The low-concentration de minimis exemption is unavailable for TRI-listed PFAS beginning with Reporting Year 2024. Trace content still requires an applicability evaluation; its presence alone does not mean every facility must file. Accurate reporting starts with ingredient identity and quantities, followed by a documented accounting of releases and waste management.

Confirm coverage, year, and chemical identity

Confirm the facility's industry and employee coverage, then match CAS numbers and chemical names against the list effective for the year being evaluated. TRI does not cover every substance described as PFAS. The 2025 list contained 205 PFAS; one additional substance, sodium perfluorohexanesulfonate (CAS 82382-12-5), was added for 2026. Track 2026 activities for reports due July 1, 2027.

For each listed PFAS, evaluate manufacture, processing, and otherwise use separately against the 100-pound threshold. Aggregate that chemical across relevant nonexempt products and operations within each activity. Do not substitute pounds of the whole product or a single total-PFAS number for pounds of the individual listed chemical.

Basis: EPA: reporting-year PFAS additions and 100-pound thresholds ↗ · EPA: Reporting Year 2025 TRI forms and instructions ↗

Go beyond an SDS keyword search

TRI-listed PFAS are chemicals of special concern. The de minimis exclusion and Form A option are unavailable, and range reporting is restricted. The removal of de minimis also applies to applicable supplier notifications; the rule does not require every supplier in every situation to issue a notification.

Ask relevant suppliers for reporting-year-specific chemical identities, concentrations or defensible bounds, and applicable EPCRA section 313 notifications. An SDS that omits PFAS, or a statement that no PFAS were intentionally added, does not establish that every listed PFAS is absent. Record the request, response, formulation period, and unresolved data gaps.

Basis: EPA: PFAS chemicals of special concern and supplier notifications ↗

Keep concentration and activity thresholds separate

Illustration: 250,000 pounds of a mixture containing 0.05% of one TRI-listed PFAS represents 125 pounds of that PFAS. If the amount is processed in a nonexempt activity, it exceeds the 100-pound processing threshold even though the concentration is below 0.1%. This is a calculation example, not a facility-specific determination.

Other exemptions can still matter, including the articles exemption when its conditions are satisfied. Document the item's shape or design, function, and releases under normal processing or use. A finished-product label does not establish the exemption. Disposal of an old item also does not, by itself, establish that an annual manufacture, processing, or otherwise-use threshold was exceeded.

Basis: EPA: PFAS chemicals of special concern and supplier notifications ↗ · 40 CFR 372.38: articles and other TRI exemptions ↗ · EPA: Reporting Year 2025 TRI forms and instructions ↗

Estimate releases and transfers with a traceable basis

Once reporting is triggered, reconcile chemical inputs and outputs: product, air, wastewater, sludge, spent media, off-site transfers, recycling, and treatment. Use available measurements and defensible engineering or mass-balance estimates. TRI generally does not mandate new monitoring solely to prepare a report, but the estimate must use the best readily available information.

Select analytical methods for the chemical and matrix being evaluated. A targeted PFAS panel covers its named analytes; a nondetect is bounded by that list and its reporting limits. A total-fluorine result cannot, by itself, allocate pounds among individual TRI-listed PFAS. Document these limits and how supplier information, test results, and estimates were reconciled.

Basis: EPA: TRI estimates and monitoring requirements ↗ · EPA: PFAS analytical methods and sampling research ↗

Do not equate treatment with PFAS destruction

EPA notes that reporting a treatment method applied to a PFAS-containing waste stream does not mean that method destroyed the PFAS. Distinguish capture or transfer to sludge and media from chemical destruction. Support claimed treatment performance and the ultimate disposition rather than assuming a wastewater plant, filter, or disposal vendor removes the reporting obligation.

ACP recommends keeping a calculation file with the annual chemical list, supplier responses, product quantities and inventory adjustments, exemption decisions, activity calculations, release estimates, transfer destinations, and reviewer signoff. If new data changes a prior-year conclusion, evaluate a correction using the requirements for that year.

Basis: EPA: PFAS waste treatment reporting does not establish destruction ↗ · EPA: Reporting Year 2025 TRI forms and instructions ↗

Related PFAS field notes

Practical facility support

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Primary references

Confirm requirements against the current regulation, adopted code edition, authorized state program, and local agency procedures.