EPA February 2025 update: nine PFAS automatically added to TRI (effective Jan 3, 2025) and related supplier-notification clarification proposed

EPA’s EPCRA/TRI communications describe (1) an automatic addition of nine PFAS to the Toxics Release Inventory (TRI) as of January 3, 2025 under the FY2020 NDAA mechanism, expanding the set of PFAS subject to TRI reporting, and (2) an associated EPA proposal (referenced in the update) intended to clarify when supplier notifications must begin for PFAS automatically added to TRI. Compliance teams at TRI-covered facilities and upstream suppliers should reassess TRI applicability for newly added PFAS, update chemical inventories, and plan for applicable reporting/supplier-notification timing (including Reporting Year 2025 forms due July 1, 2026 as referenced).