Form A vs Form R: What’s the Difference for TRI Reporting?

A clearer, friendlier explanation of a confusing environmental requirement

Every year, right about the time people start promising themselves they’ll “get ahead of compliance this time,” our inbox fills up with questions about Toxic Release Inventory (or TRI) Reporting. Some folks are brand new to it. Some have been doing this for decades. But the same question shows up over and over: “How do I know whether I’m supposed to file Form A or Form R?”

And honestly, we get it. The names alone feel like someone dumped a bucket of acronyms on the floor and told you to “just figure it out.”

So, let’s walk through this together, in a way that feels like an actual conversation instead of a regulatory lecture. If you get to the end and still feel unsure or you want a hand with this year's TRI reporting, reach out to us anytime here.

Table of Contents

• First Things First: Why Are There Two Forms Anyway?
• Form R: The Full, Detailed, No-Shortcuts Version of TRI Reporting
• Form A: The Simpler TRI Reporting Option (But Only for Certain Situations)
• Why Using the Wrong TRI Reporting Form Can Cause Real Problems
• So Which TRI Reporting Form Do You Actually Need?
• How Much Does TRI Reporting Cost? (with Calculator!)
• How to Get TRI Reporting Help
• Additional TRI Reporting Information

First Things First: Why Are There Two Forms Anyway?

Before jumping into thresholds and requirements, it helps to understand why EPA even created two different forms.

Think of TRI Reporting like filing your taxes. Everyone files something, but not everyone files the same version. Your “form” depends on what you did during the year. TRI works almost the same way.

TRI Reporting is the overall requirement. Form A and Form R are simply the two tools EPA gives you to meet it. One is short. One is long. One is the "standard option". One is only allowed under certain circumstances. Let’s start off by looking at the one most people end up using.

Form R: The Full, Detailed, No-Shortcuts Version of TRI Reporting

Form R is the default form for TRI Reporting. If you do not specifically qualify for Form A, you’re filing Form R. It asks for detailed information about:

• How much of the chemical you used
• Where releases went (air, water, land)
• Waste management and recycling practices
• How the chemical moved through your operation during the year

It’s more work, but it also gives a much fuller picture of what’s going on at your facility. And in some situations, you don’t have a choice.

When Form R Is Required in TRI Reporting

You must file Form R if any of the following apply:

• The chemical is a PBT. PBTs (persistent, bioaccumulative, toxic) always require Form R. Lead is a good example. Because lead is a PBT and appears in cement, concrete plants almost always file Form R for it, for example.
• You used more than 1,000,000 pounds of the chemical. That includes manufacturing, processing, or otherwise using it.
• You released more than 500 pounds total. All releases count. Air. Water. Land. Everything added together.

If you hit one of those triggers, you’re in Form R territory. No wiggle room.

Form A: The Simpler TRI Reporting Option (But Only for Certain Situations)

Form A exists for facilities that use very small amounts of a listed chemical and have very low releases. It’s a shorter, easier form, but EPA is strict about who can use it.

You can use Form A for your TRI reporting only if ALL of the following are true:

• The chemical is not a PBT. If it’s a PBT, Form R is mandatory.
• You manufactured, processed, or used less than 1,000,000 pounds of it during the year.
• Your total releases are 500 pounds or less.

If you meet those requirements, Form A is allowed. If any one of them is not true, you’re filing Form R.

For some facilities, Form A is a lifesaver that cuts the reporting workload significantly. But you need solid documentation to back up the decision.

Why Using the Wrong TRI Reporting Form Can Cause Real Problems

Here’s the part many people miss. TRI Reports are public. Anyone can look them up:

• Your neighbors
• Environmental groups
• State and federal regulators
• Your competitors

That means that filing the wrong form is not just a "harmless paperwork error". It can lead to:

• Regulatory violations
• Fines
• Corrective actions
• A damaged reputation in the community

We have seen facilities get in trouble because someone assumed they qualified for Form A when they didn’t. And once EPA comes knocking, the “I thought it was fine” explanation does not hold up.

So Which TRI Reporting Form Do You Actually Need?

Here is the simplest (and most accurate) way to think about it:

• If it’s a PBT, it’s Form R.
• If you hit one million pounds used, it’s Form R.
• If you exceed 500 pounds of releases, it’s Form R.
• If none of those apply, you may be allowed to file Form A.

And don’t forget, this is per chemical. You can file Form A for one substance and Form R for another in the same year.

How Much Does TRI Reporting Cost?

The honest answer is that TRI Reporting costs can vary a lot from facility to facility. Your final price depends on how many chemicals you use, how many of them cross reporting thresholds, how complex your processes are, and whether you handle the reporting in-house or bring in outside help. Some facilities spend only a few thousand dollars, while others, especially larger or more complex operations, can be looking at significantly more.

If you do end up needing a consultant, make sure to factor that into your budget as well. TRI can get time-consuming fast, and sometimes the most cost-effective choice is letting an expert (like us!) handle the heavy lifting.

To make planning easier, we built a free TRI Reporting cost calculator. It takes about a minute, there’s no email required, and you’ll get a ballpark estimate instantly. Check your TRI Reporting cost below and see where you stand.

Getting Help with TRI Reporting

TRI can feel overwhelming, even if you’ve been doing it for years. The forms change, thresholds shift, chemical lists update, and suddenly you’re second-guessing everything you thought you knew. The good news is that once you understand which form applies and why, the whole process becomes a lot less intimidating.

At RMA, we’ve built a TRI process that takes the guesswork out of all of this. We walk facilities through their chemical inventory, look at how materials are used throughout the year, review release points, track treatment and recycling, and then verify which chemicals actually meet reporting thresholds. From there, we determine whether Form A or Form R applies, prepare the documentation, submit your reports, and keep everything organized so next year is even easier.

Most folks tell us the same thing once we take TRI off their hands: “I should have called you sooner.” And honestly, we get it. No one wants to spend spring buried in spreadsheets and EPA instructions. If you’d rather have a team that does this every year handle the heavy lifting, we’re here and happy to help.

Reach out any time here. Let’s get your TRI Reporting squared away early so you can move on with the rest of your year feeling confident and in control.