Two parallel PFAS disclosure initiatives under U.S. federal law are creating unprecedented visibility into the scale of PFAS manufacturing and distribution in the American economy. The Toxics Release Inventory (TRI) program has expanded its list of reportable PFAS to 205 compounds following a January 2025 rulemaking, while the EPA’s TSCA Section 8(a)(7) reporting rule—the most far-reaching PFAS data collection effort ever undertaken—saw its compliance deadline extended to April 2026 to accommodate the enormous scope of the reporting obligation.
TRI: 205 PFAS Now Reportable
The Emergency Planning and Community Right-to-Know Act (EPCRA) Section 313—the legal basis for the TRI program—was amended to add nine additional PFAS compounds effective January 3, 2025, with the rule taking effect on March 21, 2025. This brought the total number of PFAS subject to annual TRI reporting to 205 for the 2025 reporting year. TRI reporting requires facilities in covered industrial sectors—including chemical manufacturing, metal finishing, semiconductor fabrication, and textile treatment—to annually disclose the total quantities of listed PFAS they release to air, water, and land, or transfer off-site for disposal or treatment. The TRI database is publicly accessible, enabling community members, investors, and regulators to identify facilities emitting PFAS and track trends over time.
TSCA 8(a)(7): The Largest PFAS Data Request in History
Under Section 8(a)(7) of the Toxic Substances Control Act, EPA finalized a rule requiring manufacturers (including importers) of any PFAS compound to report extensive data including: chemical identity; production and import volumes by year from 2011 to the present; industrial and consumer uses; disposal and release information; and any available environmental fate and health effects data. The rule covers an estimated 1,462 PFAS compounds and applies to manufacturers and importers who have produced or used these substances at any point in the covered period—including companies that may have exited the PFAS market years ago.
The original compliance deadline was extended to April 2026 in recognition of the complexity of assembling historical data across multiple product lines and supply chain tiers. EPA has indicated that the data collected under the 8(a)(7) rule will inform future risk evaluations and potential regulatory actions under TSCA, including restrictions on uses that are not already addressed by the NPDWR or other existing regulations.
What TSCA 8(a)(7) Data Will Reveal
The TSCA 8(a)(7) disclosure exercise is expected to reveal the production volumes and commercial uses of hundreds of PFAS compounds that have never before been publicly documented at this level of granularity. Short-chain PFAS that have been marketed as replacements for PFOA and PFOS—including PFBS, PFHxA, and GenX (HFPO-DA)—will for the first time have public production volume data associated with them, enabling an assessment of whether the scale of their use warrants additional regulatory scrutiny. The data will also illuminate the geographic distribution of PFAS manufacturing and use, identifying regions where environmental monitoring programs should be prioritized.
Implications for the Water Treatment Industry
The TRI and TSCA 8(a)(7) data programs will substantially expand EPA’s ability to identify PFAS contamination hotspots and will generate significant pressure on facilities to reduce releases. For water treatment technology providers, the release data will create a map of facilities most likely to need industrial process water treatment upgrades—either voluntarily to reduce TRI reporting numbers or in response to forthcoming effluent limit guidelines that EPA has signaled it plans to develop using the TSCA 8(a)(7) dataset. Municipal water utilities downstream of TRI-reporting facilities should conduct source water assessments calibrated to the specific PFAS compounds identified in nearby industrial releases, and should evaluate point-of-entry treatment systems capable of addressing the specific compound profiles present in their source water.