US EPA Adds One PFAS to Toxics Release Inventory

The United States Environmental Protection Agency (EPA) has issued a final rule amending the Emergency Planning and Community Right-to-Know Act (EPCRA) regulations to add sodium perfluorohexanesulfonate to the list of toxic chemicals subject to Toxics Release Inventory (TRI) reporting. 

Published in late February 2026 and effective March 30, 2026, this regulatory action requires facilities to track and report releases and waste management activities associated with this specific per- and polyfluoroalkyl substance (PFAS). 

The final rule adds one specific chemical to the TRI list. Industry professionals should verify their inventory against the following chemical details:

The EPA has designated sodium perfluorohexanesulfonate as a "chemical of special concern" (40 CFR 372.28). This designation imposes stricter reporting requirements compared to standard TRI chemicals. Facilities subject to these requirements must adhere to the following compliance standards:

• No De Minimis Exemption: The de minimis exemption, which typically allows facilities to disregard low concentrations of listed chemicals in mixtures, does not apply to this substance.

• Form R Requirement: Facilities generally cannot use Form A (the Alternate Threshold Certification Statement). Reporting must be submitted using the more detailed Form R.

This rule takes effect from March 30, 2026. Facilities in covered industry sectors (including manufacturing, mining, and electric utilities) must begin tracking activities related to sodium perfluorohexanesulfonate immediately to ensure accurate reporting for the current calendar year. (that is January 1, 2026, through December 31, 2026). The first TRI forms for this chemical must be submitted to the EPA by July 1, 2027.

Regulatory Background

This addition is a direct implementation of the statutory requirements set forth in the National Defense Authorization Act for Fiscal Year 2020 (FY 2020 NDAA). Section 7321(c) of the NDAA mandates the automatic addition of certain PFAS to the TRI list when specific triggers occur, such as the finalization of a toxicity value by the EPA Administrator. The EPA recently finalized a toxicity value for sodium perfluorohexanesulfonate, triggering its automatic inclusion in the EPCRA Section 313 list. As this action conforms to a Congressional legislative mandate, the rule was issued without a prior notice and comment period.