Publications

EPA Expands PFAS TRI Reporting: PFHxS-Na Now Subject to Disclosure Requirements

October 13, 2025 Perspectives

On October 7, 2025, EPA announced the addition of sodium perfluorohexanesulfonate (PFHxS-Na) to the Toxics Release Inventory (TRI), effective January 1, 2026. The listing follows EPA’s finalization of a toxicity value for PFHxS through its Integrated Risk Information System (IRIS) review, which triggers automatic inclusion under Section 7321 of the 2020 National Defense Authorization Act (NDAA). With this action, the number of PFAS subject to TRI reporting increases to 206. Facilities that manufacture, process, or otherwise use PFHxS-Na above reporting thresholds will be required to begin data collection in 2026, with their first TRI reports due July 1, 2027.

EPA highlighted that TRI reporting is intended to enhance transparency and provide communities, states, and regulators with information on PFAS releases and waste management practices. Because PFHxS-Na is classified as a “chemical of special concern,” regulated entities will face heightened reporting obligations, including the loss of de minimis exemptions and Form A eligibility. This addition builds on recent TRI expansions in 2024 and 2025 (see 1/9/2024, 10/8/2024, and 1/3/2025 posts below). Entities with PFAS in their operations should prepare now to identify uses, assess reporting obligations, and anticipate increased scrutiny as TRI reporting and other PFAS regulatory frameworks continue to evolve.