Everything You Need to Know About Toxic Release Inventory (TRI) Reporting

TRI Reporting 101: Your Complete Guide to Toxic Release Inventory Reports

What is TRI Reporting? How much does it cost? Who’s required to file… and what happens if you get it wrong or forget to report?

If you’re asking those questions, you’re not alone. TRI reporting is one of the most complex and widely misunderstood federal environmental reporting requirements. Between dense EPA guidance, complicated chemical thresholds, and stiff penalties, it’s no wonder so many businesses find themselves unsure if (or how) it applies.

That’s exactly why we put this guide together. We're breaking down what TRI Reporting is, who it applies to, how the process works, and how to avoid the most common (and costly) mistakes - all in plain, straightforward language. Whether you’re navigating TRI for the first time or just want to sanity-check your current approach, this article will help you understand what’s required and how to get it right.

Still have questions after reading? That’s what we’re here for. Reach out to chat with a TRI reporting expert, no pressure, just real answers. Let’s get into it.

Table of Contents

• What is TRI reporting, really?
• Who actually needs to file a TRI report?
• What chemicals are required to be reported?
• Who do I submit my TRI report to?
• TRI vs. Tier II Reporting
• Can I handle TRI reporting myself?
• RMA's TRI Reporting Process
• How much does TRI reporting cost?
• How long does TRI reporting take?
• What happens if I don’t file or I get it wrong?
• How to Get TRI Reporting Help

What Is TRI Reporting, Really?

TRI, or Toxic Release Inventory Reporting, falls under the federal Emergency Planning and Community Right-to-Know Act (EPCRA), and it's all about what chemicals (and how much of them) are released into the environment (and how).

In plain terms, TRI Reporting is how your facility tells the EPA how much of certain toxic chemicals you’re using, managing, releasing, or disposing of over the course of a year through air, water, land, and other pathways. It’s meant to give the public, policymakers, and watchdog groups insight into industrial pollution, and it plays a big role in environmental transparency across the U.S.

The reporting requirement kicks in when a facility manufactures, processes, or otherwise uses listed toxic chemicals above certain thresholds. These aren’t just obscure industrial compounds - common TRI chemicals include things like methanol, toluene, lead, nitrates, and ammonia. If you exceed the thresholds and meet the other criteria, you’re required to report. TRI reports are due to the EPA every year by July 1st.

To make things more confusing, TRI Reporting goes by several names: Section 313 Reporting. Form R Reporting. Toxic Release Inventory. You might even hear it lumped in under general “EPCRA” reporting, but TRI has its own unique rules, systems, and filing process.

Who Actually Needs to File a TRI Report?

More businesses are subject to TRI Reporting than you might think, and many don’t realize it until they’ve already missed a filing deadline or received a compliance notice. Here’s the short answer... you must file a TRI Report if your facility:

• Falls under a covered NAICS code (mostly industrial like manufacturing, metal mining, electric utilities, chemical distribution, and select commercial operations)
• Has 10 or more full-time employees
• Manufactures, processes, or otherwise uses TRI-listed chemicals above established threshold quantities (typically 25,000 pounds for processing/manufacturing, or 10,000 pounds for otherwise use)

Common examples of industries that often exceed TRI thresholds include:

• Chemical manufacturers and processors
• Metal fabricators and finishers
• Plastics and resins production
• Electric utilities and energy producers
• Concrete, asphalt, and aggregate operations
• Warehousing and distribution centers
• Food and beverage manufacturing
• Large-scale printing or industrial laundry services

But it’s not just major industrial players. Many mid-sized and even small facilities unknowingly hit TRI thresholds through routine use of solvents, fuels, degreasers, refrigerants, or process chemicals.

Not sure whether you’re required to report? We can help you figure it out! Reach out to chat with one of our TRI compliance experts, or check out this article: What NAICS codes are subject to TRI reporting?

What Chemicals are Required to be Reported?

One of the most common mistakes in TRI Reporting is assuming you're only required to report obvious, standalone chemicals. In reality, many reportable substances are hidden inside the materials you use every day.

You might not have drums labeled “Toluene” or “Lead Compound,” but if your paint, solvent, degreaser, or metal parts contain them, and you use enough over the course of the year, you may be required to report.

It’s not about the product name. It’s about what’s inside. Think of it like baking bread: it’s not the bread that’s reportable, it’s the yeast inside. Same with TRI. It’s the ingredient-level chemicals that count.

So how do you know what to report? TRI compliance comes down to three things:

1. Is it on the EPA’s TRI list?
   Over 770 chemicals are covered, including methanol, ammonia, lead compounds, glycol ethers, and many more that we can't cover here!
2. How are you using it?
   TRI has thresholds based on:
   • Manufacture: 25,000 lbs/year
   • Process: 25,000 lbs/year
   • Otherwise use: 10,000 lbs/year
     (Some highly toxic chemicals like lead have much lower thresholds, as low as 100 lbs.)
3. Are you over the threshold?
   You’ll need to:
   • Check SDSs or supplier data
   • Calculate how much of the TRI chemical is in your materials
   • Track usage, emissions, and disposal across all departments

This is where most facilities slip up: they track products, not ingredients. And the EPA doesn’t accept guesses. If you miss something, you're still liable. If you're already scratching your head, no worries - we can help you figure it out, reach out here.  Or for more reading, check out: What do I need to report for TRI reporting?

Who Do I Submit My TRI Report To? 

All TRI reports are submitted electronically through the EPA’s Central Data Exchange (CDX) system using the TRI-MEweb platform. That’s the federal side, and it’s where the majority of your reporting activity will happen. However, some states have their own additional requirements.

While your report always goes to the EPA, some states:

• Require duplicate submissions or uploads to their own state database
• Expect additional forms or certifications
• Charge state-level TRI filing fees
• Request supplemental information or retention documentation
• Have their own compliance contacts who may follow up

Take New Jersey, for example: facilities must submit to the EPA through TRI-MEweb and provide additional detail to the NJDEP. In other states, the EPA submission is sufficient. It all depends on your location. What is consistent? The deadline: July 1st.

TRI vs Tier II Reporting: What’s the Difference?

TRI and Tier II Reporting are often confused, and while they both fall under EPCRA, they serve very different purposes.

TRI Reporting (Toxics Release Inventory) is about what your facility releases into the environment. It’s submitted to the EPA and focuses on toxic chemical usage, waste management, and environmental releases. It’s mainly for larger facilities that manufacture, process, or otherwise use certain chemicals above defined thresholds.

Tier II Reporting, on the other hand, is about what you store on-site. It’s designed for emergency preparedness and helps local responders (like fire departments and LEPCs) know what hazardous materials are present in case of a fire, spill, or other emergency.

Both are annual reports, both are federally driven, and both have to do with comparing your materials on-site to listed thresholds... but they go to different agencies, involve different systems, and are triggered by very different activities. Depending on what you do and what materials you handle, you may need to file one, both, or neither.

Still unsure which applies to your operation? Let’s figure it out together, or check out this article: Is Tier II the same as TRI Reporting?

Can I Handle TRI Reporting Myself?

It’s a fair question… and the honest answer is: maybe.

If you’re detail-oriented, familiar with EPA guidance, and have solid records of your chemical usage and waste management practices, you can handle TRI Reporting internally. Some facilities (mostly those with straightforward operations and limited chemical use) do manage it on their own. There's no specific certification or credentials you need to file a report.

But whether you should handle it in-house depends on a few critical factors:

• How many TRI-listed chemicals do you use, process, or generate as byproducts? Each chemical has its own threshold and reporting triggers, and some may be present in mixtures or intermediate steps you didn’t expect.
• Are you comfortable quantifying environmental releases and pathways? This is where TRI gets tricky. You’ll need to calculate how much of each reportable chemical is:
  • Released to air (fugitive vs. stack emissions)
  • Discharged to water
  • Disposed of on-site or off-site
  • Sent for treatment, recycling, or energy recovery
  • Managed through other waste pathways

These numbers aren’t estimated by guesswork, they require data-backed calculations, mass balance methods, and in some cases emission factors, monitoring data, or engineering estimates. For many facilities, this is the most time-consuming and risk-sensitive part of the report.

• Do you understand the EPA’s TRI-MEweb system? It’s the official platform for filing, and it’s far from intuitive for first-timers. Expect a learning curve.
• Are your inventory and usage records complete and auditable? The EPA expects you to retain documentation for every number you submit (including calculations, assumptions, and supporting data).
• Do you have time for it? Between materials inventories, threshold determinations, release quantification, and submission formatting, even a “simple” TRI report can take significant time, especially if your facility hasn’t filed before.

Frankly, we find that most facilities are not equipped to handle TRI reporting (correctly and efficiently) in-house. That’s why many facilities outsource. A qualified TRI reporting partner (like us!) will:

• Take stock of your materials and the chemicals within them
• Confirm whether you actually meet the reporting thresholds
• Analyze your usage and waste records
• Quantify releases by media and treatment pathways
• Prepare the TRI-MEweb submission and assist you in submitting it

Bottom line: If your chemical usage is minimal, your records are clean, and you're comfortable quantifying releases and navigating EPA systems, go for it. But if you're unsure (or don’t have time to risk mistakes), we can handle it for you.

Still thinking of going it alone? Check out these 8 common TRI reporting mistakes before you do!

Thinking About Outsourcing Your TRI Reporting? Here’s How We Do It.

If you’re considering outsourcing your TRI Reporting, here’s what it looks like when you work with RMA.

We start by getting to know your facility - not just your chemical list, but how you actually use, manage, and dispose of those materials. That includes a visit to your site, reviewing purchase records, SDSs, usage logs, and waste profiles. We dig into process flows, emission points, and treatment methods to understand the full picture of where your TRI-listed chemicals go, and how much gets released, transferred, recycled, or treated.

From there, we:

• Confirm whether you meet reporting thresholds
• Identify which chemicals and release pathways are reportable
• Quantify your releases across all required media (air, water, land, off-site)
• Prepare your Form R (or Form A, if eligible) in TRI-MEweb
• Help you to submit the report to the EPA (and your state, if required)

But here’s where we’re different:

• We don’t outsource your report prep to junior analysts or offshore freelancers
• We don’t use automated tools that “guess” release amounts or default to averages
• And we never treat your report like a checkbox exercise

Every TRI report we file is prepared by experienced environmental compliance professionals who understand the science behind the numbers... and the consequences of getting them wrong. We know what EPA reviewers look for, what common errors get flagged, and how to prepare a defensible, clean report that reduces your risk of enforcement.

What you get isn’t just a submission. You get peace of mind that your report reflects your actual operations, complies with federal and (if applicable) state requirements, and stands up to scrutiny - all backed by a team that’s been doing this for decades and genuinely cares about your compliance.

Want to learn more about our TRI reporting process and whether we’re a good fit for your team? Contact us here, we’re happy to talk it through, no pressure.

How Much Does TRI Reporting Actually Cost?

Like most things in environmental compliance, the honest answer is: it depends. But here’s a realistic ballpark.

For most facilities, TRI Reporting costs between $2,500 and $8,500 when working with a qualified consultant. That range covers everything from threshold evaluations and chemical usage analysis to quantifying release pathways, preparing Form R reports, and submitting through the EPA’s TRI-MEweb system.

Where you fall in that range depends on several key factors:

• How many TRI-listed chemicals are in use, and how complex is their tracking?
• How many facilities do you need to report for?
• Do you need full release calculations across multiple media (air, water, off-site)?
• Is this your first time filing, or a continuation from prior years?
• Are there gaps or errors in previous TRI submissions that need to be addressed?
• How close are you to the July 1st deadline? (Rush fees may apply in June)

The biggest cost drivers? Collecting information and quantifying releases. This process takes time, especially if there are multiple processes, emission points, or disposal pathways to evaluate. If your records are clean and your chemical usage is straightforward, reporting can be very manageable. But if you’re pulling usage data from invoices, spreadsheets, or across departments, or reporting for the very first time - expect more work (and cost) to get it right.

What about future years? Unlike permits that require regular upkeep, TRI Reporting is an annual report, so once your systems are in place and a consultant understands your operation, it’s usually faster and more cost-effective in years two and beyond. That said, major operational changes (like new chemicals, process changes, or enforcement actions) may require additional work.

Bottom line: This is a once-a-year compliance project, but it’s a high-stakes one, and mistakes can trigger financial penalties or worse. The earlier you start, the smoother (and cheaper) it tends to be. For a deeper breakdown, check out our guide: How Much Does TRI Reporting Cost?

How long does TRI reporting take?

It's an important question - and the honest answer is: usually 4 to 8 weeks, depending on your complexity and how early you start.

TRI Reporting isn’t something you knock out in a weekend. Between investigating your setup, threshold evaluations, release quantification, documentation, and EPA system prep, it’s a multi-step process that takes time, especially if this is your first year reporting or your data is spread across multiple systems.

Here’s what affects the timeline:

• How soon can we get boots on the ground for a site visit?
• How organized and complete is your chemical usage data?
• How many TRI-listed chemicals and release points are involved?
• Do you have supporting records for all manufacturing, processing, or “otherwise use” activity?
• Do you have air, water, land, and off-site disposal releases... or just one or two?
• How quickly can your internal team provide the needed data?
• Is this a new filing, or a continuation of prior-year reports?

TRI season typically runs April through July 1st, and by May, most qualified consultants are already deep in processing data and getting together submissions for clients who have been on the books for months. If you wait until early June to start gathering records or asking for help, you’re already late... and any missing data, misclassified chemicals, or unresolved waste streams can cause serious delays.

And keep this in mind: There are no extensions for TRI. The July 1st deadline is federally enforced, and missing it can trigger formal Notices of Violation, not to mention the risk of scrutiny if your facility is flagged for further review.

So while the actual report prep might be pretty quick once the data is ready, the whole project often takes 1–2 months when you factor in:

• Scheduling a site visit
• Data gathering
• Release calculations
• Threshold analysis
• TRI-MEweb entry
• State-specific follow-ups (if applicable)

Best move? Start early. Even if you’re not sure whether you meet the thresholds, or you just want a second set of eyes on your chemical list, reach out sooner rather than later. TRI is not the place to roll the dice on a last-minute submission. For more info, read: How long does TRI reporting take?

What Happens If I Don’t File or I Get It Wrong?

If your facility exceeds TRI thresholds and fails to file (or files inaccurately) you’re in violation of federal law under EPCRA Section 313. And while it might feel like just another no-big-deal reporting form, the EPA doesn’t see it that way.

TRI Reporting is about protecting the public from pollution and maintaining environmental transparency. When facilities underreport, misclassify, or skip their obligations, the EPA treats it as a serious compliance breach - one that can carry steep financial penalties and long-term consequences.

How steep? Up to $71,545 per violation, per day. Really. We’ve seen facilities rack up six-figure enforcement actions, especially if there was a serious release that caused harm to human health or the environment that wasn't disclosed. To see how quickly those fines add up, you can try our environmental violation calculator here.

TRI enforcement can be triggered by:

• A complaint or tip from a former employee or community member
• A random EPA or state inspection
• A discrepancy in your air, water, or waste permits
• A spill, release, or emergency that raises red flags
• A public data comparison (e.g., discharging but no TRI report)
• An NGO or watchdog group combing through online databases

And once you're flagged, the scrutiny doesn't stop at TRI, it often expands to your other environmental permits, waste records, and reporting history. Not to mention the harm to your company's reputation. If your facility is named in a public enforcement action, those records stay online. We’ve seen cases where missed TRI filings turned into local headlines, damaged business relationships, and triggered more frequent inspections in the future.

How RMA Helps You File TRI Reports Without the Guesswork

If you’re staring down TRI Reporting and not sure where to start, you’re not alone. For some facilities, it’s possible to manage in-house... if you’ve got clean records, the right expertise, and plenty of time to work through the EPA’s process. But for many, the fastest and safest route is partnering with a team that does this year after year for a variety of facilities across the United States.

Whether it’s your first time filing, your report involves complex release calculations, or you just need help cleaning up or verifying last year’s submission, we can meet you where you are. We support facilities of all sizes - from single-site manufacturers to multi-facility operators managing dozens of chemicals across multiple states.

Here’s what our TRI process looks like:

• Review your chemical usage, process flows, and waste handling practices
• Evaluate whether you meet reporting thresholds based on use, manufacturing, or processing
• Identify all TRI-listed chemicals, activity types, and media-specific releases
• Quantify releases across air, water, land, and off-site disposal
• Prepare and validate Form R (or Form A) submissions in TRI-MEweb
• Assist you in submitting to the EPA (and state agencies if required)
• Provide full documentation for audit readiness

If you’re in a state with its own quirks (like New Jersey’s supplemental forms or additional state requirements) we handle those too.

Most importantly, this isn’t just data entry for us. You’ll work with experienced environmental compliance consultants who understand the regulations, the systems, and the science behind your report. We ask the right questions, document the right details, and build reports that are accurate, complete, and defensible.

Whether you need full-service reporting or just a second set of eyes, we’re here to make TRI compliance easier, faster, and more accurate so you can focus on running your operation, not decoding EPA spreadsheets.

Ready to get started? Not sure whether you even need to file? Whatever your situation, let’s talk. No pressure, no charge, just clarity (finally!).