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Updates: EPA is delaying the effective date of the published rule to March 21, 2025, in a response to the memorandum of January 20, 2025, from President Donald J. Trump, entitled “Regulatory Freeze Pending Review."
The memorandum instructed the heads of Executive Departments and Agencies to consider delaying the effective date by sixty days for any rules published in the Federal Register but not yet in effect, to review potential questions of fact, law, and policy.
On January 6, 2025, the U.S. Environmental Protection Agency (EPA) announced the automatic addition of nine per- and polyfluoroalkyl substances (PFAS) to the list of chemicals covered by the Toxic Release Inventory (TRI). This final rules is effective on February 5, 2025.
The nine PFAS were added for Reporting Year 2025 due to EPA having finalized a toxicity value during 2024 and whose identity is not claimed as confidential business information. The total PFAS subject to TRI reporting is now increased to 205. These nine PFAS are:
| CAS No. | Chemical Name | Triggering Activity |
| 377-73-1 | Perfluoro-3-methoxypropanoic acid | Final Toxicity Value |
| 3108-42-7 | Ammonium perfluorodecanoate (PFDA NH4) | Final Toxicity Value |
| 3830-45-3 | Sodium perfluorodecanoate (PFDA-Na) | Final Toxicity Value |
| 27619-97-2 | 6:2 Fluorotelomer sulfonate acid | Final Toxicity Value |
| 425670-75-3 | 6:2 Fluorotelomer sulfonate anion | Final Toxicity Value |
| 59587-38-1 | 6:2 Fluorotelomer sulfonate potassium salt | Final Toxicity Value |
| 59587-39-2 | 6:2 Fluorotelomer sulfonate ammonium salt | Final Toxicity Value |
| 27619-94-9 | 6:2 Fluorotelomer sulfonate sodium salt | Final Toxicity Value |
| 3030471-22-5 | Acetic acid, [(γ-ω-perfluoro-C8-10-alkyl)thio] derivs., Bu esters | CBI Declassification |
Facilities in TRI-covered industry sectors must report if they meet chemical activity thresholds of 100 pounds. The reporting data include quantities of such chemicals that were released into the environment or otherwise managed as waste.
The reporting deadline for these nine additional PFAS is July 1, 2026. Facilities subject to reporting requirements should begin tracking and collecting data on these chemicals during 2025.
Background
On December 20, 2019, the National Defense Authorization Act for Fiscal Year 2020 (NDAA) was signed into law (PL 116-92). Among other provisions, section 7321(c) identifies certain regulatory activities that automatically add PFAS or classes of PFAS to the TRI list of reportable chemicals. Specifically, PFAS or classes of PFAS are added to the TRI list of reportable chemicals beginning January 1 of the calendar year.
In addition, under section 7321(e), EPA must review CBI claims before PFAS are added to the TRI list. Certain PFAS that met the criteria for addition but were subject to a claim of protection from disclosure are not added to the list until their identities are published on the non-confidential portion of the TSCA Inventory.
