EPA Adds Additional PFAS to the Toxics Release Inventory
- Georgie Whitehouse
- Nov 24, 2025
- 3 min read
An Introduction to PFAS
In a significant move for chemical compliance and reporting, the EPA has announced the automatic addition of a new per-and-polyfluoroalkyl substance (PFAS) to the Toxics Release Inventory (TRI). This step reinforces the increasing regulatory attention on PFAS chemicals and signals important changes for companies in affected sectors.
Which PFAS Has Been Added by EPA?
The substance newly added is sodium perfluorohexanesulfonate (PFHxS-Na), CASRN 82382-12-5.
This addition is the result of the EPA finalizing the toxicity value in 2025 for “IRIS Toxicological Review of Perfluorohexanesulfonic Acid (PFHxS, CASRN 335-46-4) and Related Salts.”
Previously, the TRI list already included PFHxS and some of its salts — however, PFHxS-Na was not on the list. With this update, PFHxS-Na will become a reportable chemical under TRI as of January 1, 2026.
Once that date passes, affected facilities must track activities involving PFHxS-Na and report accordingly under Section 313 of the Emergency Planning and Community Right‑to‑Know Act (EPCRA). Reports will be due by July 1, 2027 for the 2026 activities.
With this addition, the total number of PFAS chemicals subject to TRI reporting will be 206.
Why This Matters for Compliance
1. Expanded Reporting Scope for PFAS
Businesses that manufacture, process or otherwise use PFHxS-Na (above threshold quantities) now fall under TRI reporting obligations. If your organisation handles PFAS, you’ll need to determine whether PFHxS-Na is in use and whether it triggers reporting.
2. Data Transparency & Public Accountability
The TRI data (released annually) includes quantities of these chemicals released into the environment or otherwise managed as waste.
That means local communities, regulators and NGOs will have additional visibility into PFAS usage and releases, increasing reputational risk for non-compliance or poor management.
3. Upstream Impacts on Supply Chain and Risk Management
If you are a downstream user, supplier or service provider in sectors affected by PFAS, this change may ripple through. Consider reviewing your supply chain and raw material inventories to identify PFHxS-Na or products containing it.
4. Timing & Preparation
Although the effective date is January 1, 2026, now is the time to get ready. Facilities should begin tracking PFHxS-Na activities ahead of time, establish processes, data flows, and internal controls so that reporting by July 1, 2027 will proceed smoothly.
What Should Companies Be Doing Now?
Inventory assessment: Identify whether PFHxS-Na is manufactured, processed or used in your operations. Include salts and related compounds as relevant.
Threshold assessment: Determine if your quantities trigger TRI Section 313 thresholds.
Data systems readiness: Ensure that your data-capture and reporting systems can handle tracking of PFHxS-Na starting 2026.
Documentation & training: Update internal procedures, train relevant personnel (environmental, health & safety, regulatory) about the new chemical and its reporting implications.
Supplier/supply-chain engagement: Reach out to suppliers/users downstream to clarify whether PFHxS-Na is present in materials or products, so you’re not caught unaware.
Public-stakeholder communications: If appropriate (especially for companies with community-interest or high visibility), prepare messaging about your monitoring and controls of PFAS substances to stay ahead of stakeholder concerns.
Why the EPA Is Taking This Action
The automatic addition of PFHxS-Na is mandated by the FY 2020 National Defense Authorization Act (NDAA) under its PFAS provisions.
The EPA’s action supports its “Permitting Reform, Cooperative Federalism, and Cross-Agency Partnership” initiative; part of what the EPA labels its “Powering the Great American Comeback” framework.
By adding PFHxS-Na to the TRI list, the EPA is enhancing transparency and oversight of PFAS chemicals: a class of chemicals that has been under increasing scrutiny because of potential environmental and health concerns.
What’s Next for GoCompliance Clients
For GoCompliance users and other firms in affected industries (chemical manufacturing, plastics, electronics, aerospace, automotive, coatings, etc.), this update signals the need to review and bolster your chemical compliance strategies:
Use GoCompliance’s regulatory-watch tools to monitor further PFAS additions or regulatory developments.
Update your internal chemical management systems to include PFHxS-Na and ensure your risk assessments cover PFAS broadly.
Leverage GoCompliance training modules to educate workforce and contractors on PFAS-specific compliance requirements.
Build or enhance data-tracking dashboards to integrate new TRI chemical requirements and mapping of potential releases or waste management.
Stay ahead of compliance deadlines: Start now so when January 2026 arrives you’re already prepared.
Conclusion
The EPA’s decision to add PFHxS-Na to the TRI underscores how PFAS regulatory pressure continues to mount, for both environmental authorities and companies.
At GoCompliance, we view this as an operational and compliance inflection point: organisations that get ahead of the change will be better positioned to manage risk, stay out of trouble, and communicate proactively.
If you’d like help mapping your PFAS inventory, establishing reporting processes, or training your team, reach out to GoCompliance and we’ll get started.