On January 3, 2025, the U.S. Environmental Protection Agency (EPA) announced the automatic addition of nine per- and polyfluoroalkyl substances (PFAS) to the list of 196 PFAS already covered by the Toxics Release Inventory (TRI). Under the framework of the Fiscal Year 2020 National Defense Authorization Act (NDAA), the automatic addition of nine PFAS to the TRI list comes upon EPA’s finalization of a toxicity value (for the first eight PFAS listed below) and declassification as nonconfidential business information (for the last PFAS listed below). The added PFAS include:
- Ammonium perfluorodecanoate (PFDA NH4) (3108-42-7)
- Sodium perfluorodecanoate (PFDA-Na) (3830-45-3)
- Perfluoro-3-methoxypropanoic acid (377-73-1)
- 6:2 Fluorotelomer sulfonate acid (27619-97-2)
- 6:2 Fluorotelomer sulfonate anion (425670-75-3)
- 6:2 Fluorotelomer sulfonate potassium salt (59587-38-1)
- 6:2 Fluorotelomer sulfonate ammonium salt (59587-39-2)
- 6:2 Fluorotelomer sulfonate sodium salt (27619-94-9)
- Acetic acid, [(γ-ω-perfluoro-C8-10-alkyl)thio] derivs., Bu esters (3030471-22-5)
Implications
Annual reporting of the quantities of these nine additional PFAS that were released into the environment or managed as waste is required by July 1 of 2026 and annually thereafter, under EPCRA Section 313. This reporting is applicable to facilities in designated industry sectors and federal facilities that manufacture, process, or otherwise use TRI-listed chemicals above set quantities. The reportable data is publicly available online. Supplier notifications are also required for these additional nine PFAS as of January 1, 2025
The nine added PFAS, along with the 196 PFAS already on the TRI reporting list are classified as chemicals of special concern, which removes the use of reporting exemptions that allowed facilities to avoid reporting information on PFAS when those chemicals were used in small concentrations.
If you need help navigating PFAS-related challenges, we are on the PFAS frontlines and ready to assist. Contact our experts Ioana Petrisor PhD, Lori Goetz, or Adam Weissman PE today!