EPA Adds More PFAS to Toxics Reporting List
The EPA has finalized the addition of more per- and polyfluoroalkyl substances (PFAS) to its Toxics Release Inventory, effective for the 2026 reporting year. This means manufacturers using these 'forever chemicals' in coatings and materials must now track and report a much wider range of substances. The move tightens compliance even as other PFAS rules were recently rolled back.
This expansion of the Toxics Release Inventory (TRI) is not a discretionary EPA action but an automatic process mandated by the National Defense Authorization Act (NDAA) of 2020. The law requires the EPA to add PFAS to the list if they meet certain triggers, such as the finalization of a toxicity value. The latest rule adds sodium perfluorohexanesulfonate (PFHxS-Na), bringing the total number of PFAS on the TRI to 206. Listing on the TRI triggers significant compliance obligations. PFAS are designated as "chemicals of special concern," which lowers the reporting threshold to just 100 pounds per year for manufacturing, processing, or otherwise using the substance. This is a fraction of the 10,000 or 25,000-pound thresholds for most other chemicals, demanding far more meticulous tracking from manufacturers. This latest addition for the 2026 reporting year follows the addition of nine PFAS for the 2025 reporting year and seven for 2024, illustrating the steady, congressionally-mandated expansion of regulatory oversight. Facilities must report releases of these chemicals to air, water, and land, and the data is made publicly available. The tightening of TRI reporting contrasts with recent EPA actions on other PFAS regulations. In September 2025, the agency filed a motion to vacate the national drinking water standards for four PFAS (GenX, PFHxS, PFNA, and PFBS) and earlier delayed compliance deadlines for PFOA and PFOS, creating a conflicting and uncertain regulatory environment for manufacturers. Beyond the TRI, manufacturers face a separate, more daunting task with the one-time PFAS reporting rule under the Toxic Substances Control Act (TSCA). This rule requires companies to report detailed data on all PFAS manufactured or imported since 2011, forcing a deep and complex audit of decade-old supply chain records. The challenge is magnified by the deep integration of PFAS in global supply chains. Recent data from over 4.5 million supplier declarations revealed that more than 80% of manufacturers have PFAS in their supply chains. The complexity grows as many suppliers, particularly those in lower tiers, may be unaware they are using PFAS, making full traceability a significant hurdle for internal audit and compliance teams. This evolving U.S. regulatory landscape, which adds substances incrementally, stands in contrast to the more
