What Is a Toxic Release Inventory (TRI, SARA 313, Form R)?

The Toxic Release Inventory (TRI) is one of the most important environmental reporting requirements for manufacturers and industrial facilities. If your facility uses chemicals above certain thresholds, you may be required to report annually to the EPA.

⚡ In short: TRI (SARA 313) requires facilities to report releases and transfers of 770+ chemicals to the EPA annually. Report if you employ 10+ people, fall under NAICS codes, and manufacture/process/use TRI-listed chemicals above threshold quantities. Deadline: July 1. EPA added 172 PFAS chemicals with lower reporting thresholds.

TRI provides a public database so communities can learn about chemical use in their areas.

⚠️ Why this matters: TRI non-compliance drives EPA penalties of $25,000+ per day of violation plus liability for natural resource damage. Beyond regulatory consequences, non-compliance damages community trust, triggers EPA oversight of related environmental programs, and can surface in Due Diligence reviews for facility sales or financing. Many facilities don’t realize they’re TRI-reportable until EPA shows up.

What Is TRI?

TRI first came into existence in 1986 as part of the Superfund Amendments and Reauthorization Act (SARA) and the Emergency Planning and Community Right-to-Know Act (EPCRA). Its creation was influenced by a catastrophic toxic gas release at a chemical plant in Bhopal, India in 1984 that killed thousands, followed by a serious chemical release at a similar plant in West Virginia in 1985.

The EPA established TRI as a reporting system so the public could learn about chemicals used in their communities. Companies using potentially harmful chemicals above certain thresholds must report their releases annually.

TRI, Form R, and SARA 313: What’s the Difference?

These terms are often used interchangeably, but they refer to different aspects of the same requirement:

SARA 313 refers to Section 313 of SARA, which is the legal authority for TRI reporting. Other SARA reporting requirements include Sections 311 and 312 (Tier II chemical inventory reporting), Section 304 (emergency spill reporting), and Sections 302 and 303 (emergency planning and notification).

Form R is one of the actual forms used to submit TRI data. Because it’s the primary reporting form, people often refer to the entire process as “Form R reporting.”

Who Must Report?

Your company must file TRI reports if it meets all three criteria:

1. Employs 10 or more employees
2. Falls under an identified NAICS code from the 2017 NAICS list
3. Manufactures, processes, or uses a TRI-listed chemical above the allowed threshold

The TRI list includes approximately 770 chemicals identified as having significant effects on the environment or human health. The EPA continually adds chemicals to this list.

Recent Updates: PFAS and Natural Gas Processing

The EPA has significantly expanded TRI reporting in recent years. Over 172 PFAS chemicals have been added to the TRI list, with reporting thresholds for PFAS set significantly lower than for other chemicals. All natural gas processing facilities that receive and refine natural gas are now subject to reporting. Additionally, contract sterilization facilities must estimate their quantities of ethylene oxide and ethylene glycol to determine if they are subject to TRI.

Form R vs. Form A

TRI uses two forms for reporting:

Form R is the standard, detailed reporting form. You begin by using Form R to identify your chemicals. For the remainder of the report, you may continue with Form R or switch to Form A if eligible.

Form A is a shortened form available only if your company meets specific criteria regarding the type of chemical, quantity used, and waste generated. If you don’t meet Form A criteria, you must use Form R.

A separate form (R or A) must be completed for each chemical you manufacture, process, or use in quantities above the threshold.

How Are TRI Reports Submitted?

TRI reports are submitted federally through EPA’s TRI-MEweb website. You will also need to submit copies to your state agency. This information becomes public and is searchable in several online databases.

Annual deadline: July 1 for the prior calendar year’s data.

Don’t Forget Supplier Notifications

Companies that process or manufacture chemicals or chemical mixtures are also required to send annual supplier chemical notifications per EPCRA Section 313. This is a separate obligation from TRI reporting itself.

iSi’s environmental compliance team can determine your facility’s reporting obligations, assess whether the PFAS expansion affects your operation, and manage your annual TRI submission from chemical inventory through EPA submission. Many facilities avoid $25K–$100K+ in penalties simply by getting ahead of this requirement.

Frequently Asked Questions

Q: What is a Toxic Release Inventory (TRI) and who must report?

TRI, established under SARA 313 and EPCRA in 1986, requires facilities to report releases of chemicals to the EPA annually. Facilities must report if they employ 10 or more employees, fall under identified NAICS codes, and manufacture, process, or use any of approximately 770 TRI-listed chemicals above threshold quantities. The EPA expanded TRI significantly in recent years by adding over 172 PFAS chemicals.

Q: What is the difference between Form R and Form A for TRI reporting?

Form R is the comprehensive TRI reporting form required for all facilities. Form A is a shortened form available only to facilities meeting specific criteria regarding chemical type, quantity used, and waste generated. A separate form must be completed for each reportable chemical, and reports are due July 1 annually through EPA’s TRI-MEweb portal.

Q: What are PFAS chemicals and how do they affect TRI reporting?

PFAS (Per- and Polyfluoroalkyl Substances) are over 172 chemicals recently added to the TRI list with lower reporting thresholds than traditional chemicals. Facilities handling per- and polyfluoroalkyl substances in any form must assess whether they exceed PFAS reporting thresholds. This expansion significantly increased reporting obligations for facilities in Kansas, Oklahoma, Missouri, Nebraska, and Texas that manufacture or process fluorinated products.

Q: What happens if a facility exceeds TRI chemical thresholds but fails to report?

Failure to report TRI chemicals above thresholds violates EPCRA and can result in EPA penalties of $25,000 per day of violation plus liability for natural resource damage. Beyond regulatory consequences, TRI non-compliance damages community trust and can trigger regulatory scrutiny of other environmental programs. iSi Environmental helps facilities determine reporting obligations and ensure timely, accurate submissions.

💰 What TRI non-compliance costs: EPA penalties for failure to report run $25,000+ per day of violation. A facility discovering mid-year it’s TRI-reportable faces: back-filing penalties for prior-year failures, daily violation penalties, potential natural resource damage liability, and regulatory scrutiny of related programs. Early assessment and remediation cost a fraction of enforcement action.

Need a TRI applicability review or reporting support? Run the 60-second Compliance Gap check or get a scoped TRI proposal from our team.

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