Form A or Form R: which TRI form are you allowed to file?

This page explains what the rules and common practice call for. Every site is different, and what a survey or a filing needs at your facility is something we work out with you after we see it.

The Toxics Release Inventory (TRI) is the annual report on toxic chemical releases that facilities file with EPA. Form R is the full report and Form A is the shorter one.

Form A takes the place of Form R for a given chemical, and it is far more restricted than most facilities assume.

Start here: Form A is not allowed for any chemical on EPA's "chemicals of special concern" list. That list contains the persistent, bioaccumulative and toxic (PBT) chemicals and, since 2023, PFAS, a family of long-lasting synthetic chemicals. For a chemical on the list, Form A is ruled out before you look at anything else, whatever the quantity, so there is no need to check quantities or run any calculations.

One exception is worth knowing before you stop. The list entry for lead excludes lead contained in a stainless steel, brass or bronze alloy. Lead in that form is outside the special-concern listing and keeps the ordinary reporting thresholds of 25,000 and 10,000 pounds. Form A, range reporting (explained below) and the de minimis exemption all remain available for it. EPA's 2023 preamble, the explanation published with the rule, makes the same point by leaving certain cases of lead reporting out of the Form A bar. If you run a brass or bronze shop, check which form your lead is in before you conclude that you are barred.

Checking the special-concern list first saves the rest of the work.

→ Do you have to file a Form R?

The two tests

The formal name of Form A is the Alternate Threshold Certification Statement. To use it you must pass both tests, not one or the other:

The first number is generous: 1,000,000 pounds, against the standard reporting thresholds of 25,000 pounds for manufacturing or processing and 10,000 pounds for otherwise using. The second number is where facilities fail to qualify.

What counts toward the 500 pounds

This is the part people get wrong, because "reportable amount" does not mean "releases."

The annual reportable amount is the combined total of:

• Releases to air, water and land
• Disposal
• Treatment
• Energy recovery (burning waste for its energy value)
• Recycling
• Off-site transfers for any of the above

Recycling and energy recovery are in the total. Consider a shop that uses solvent and recovers and reuses nearly all of it. Its environmental record is excellent, but its reportable amount is still large because the recycled quantity counts. That shop files Form R even though it emits very little.

The most common Form A mistake we see runs like this. A facility adds up its stack and fugitive releases, gets 180 pounds, and files Form A. It also sends 4,000 pounds of spent solvent off-site for reclamation, so the reportable amount was 4,180 pounds and Form A was not allowed.

→ How to calculate releases without monitoring data

Side by side

Same deadline. The rule sets Form A at July 1, the same as Form R, so filing the short form does not buy you time. Facilities miss the date when they treat Form A as the low-priority item in June.

→ Missed the July 1 deadline?

The recordkeeping is the same

Form A saves you effort on the form itself, not on the analysis behind it.

You still have to make the threshold determination against the alternate threshold, and you still have to calculate the annual reportable amount to show it is at or below 500 pounds. That is the same estimate of releases and waste management you would have prepared for a Form R, with records to support it.

EPA can ask for those records, and "We filed Form A because our releases seemed small" is not a record.

The honest accounting: Form A saves you the data entry and keeps your quantities out of public view, but it saves almost none of the underlying analysis. If you chose it to reduce effort, you misjudged what it saves.

Why Form A is barred for chemicals of special concern

The special-concern list contains the PBT chemicals and PFAS, which carry lower reporting thresholds than the standard figures. For these chemicals, the rule removes Form A entirely, and the reasoning is straightforward. The alternate threshold exists to ease the burden where quantities are small relative to the standard thresholds, and at these lower thresholds there is no such relief to give.

Range reporting is not allowed for these chemicals either. Range reporting lets a filer report certain small quantities as a range instead of an estimate. That restriction is older than most summaries suggest:

• For the original PBT chemicals (mercury, PCBs and dioxins), it ended with the 1999 rule on those chemicals (Federal Register, 64 FR 58666), which first applied to RY2000.
• For lead and lead compounds, it ended with the 2001 lead rule (66 FR 4500, January 17, 2001), which first applied to RY2001.

"RY" stands for reporting year, the calendar year a report covers. The Form A bar arrived with the same rules.

The rule of October 31, 2023 (88 FR 74360) changed two things. It added PFAS to the special-concern list, so the existing restrictions on Form A, range reporting and the de minimis exemption now reach every listed PFAS. It also removed the de minimis exemption from the supplier notification rule for all chemicals of special concern. That is the one genuinely new restriction in the rule, and it reaches suppliers who file nothing themselves.

In practice, if you have any PFAS in the facility at all, plan on full Form R reporting with single-number estimates, not ranges.

→ Supplier notification requirements

When Form A is the right filing

Form A is not a trap, and we are not arguing against it. These are the clean cases.

A chemical present in a modest quantity that is consumed in a reaction. The quantity manufactured or processed is well under 1,000,000 pounds, little waste is generated, there are no significant off-site transfers, and nothing is recycled. The reportable amount comes out in the tens of pounds.

A chemical in a blended product that becomes part of what you ship. The processed quantity is real, the releases are genuinely small, and the material leaves as product, not as waste.

In both cases, run the recycling and energy recovery numbers before you decide, because that is the line that changes the answer.

The steps, in order

1. Is the chemical on the special-concern list? If yes, file Form R, and you can stop there, with one check first. If the chemical is lead, confirm whether it is lead contained in a stainless steel, brass or bronze alloy. That form of lead is excluded from the listing, so you go on to step 2.
2. Did you exceed 1,000,000 pounds manufactured, processed or otherwise used? If yes, file Form R.
3. Calculate the annual reportable amount, including recycling, energy recovery, treatment, disposal and all off-site transfers. If it is over 500 pounds, file Form R.
4. Otherwise, you may use Form A. Document your analysis and file by July 1.

Arizona facilities: one more form on the same date

If you are in Arizona, the state Toxic Data Report shares the July 1 deadline (A.R.S. § 49-962(C)). It is tied to your federal reporting, and filing a Form A does not remove the requirement.

The related Pollution Prevention Plan runs on a different schedule. It must be prepared, implemented and maintained. Where the facility uses more than 10,000 pounds a year of a listed toxic substance, the plan itself must be filed (A.R.S. § 49-963(D)), and it is due by December 31 of the following year.

→ Arizona's pollution prevention plan and Toxic Data Report · Our Form R reporting service

Standard caution: chemical lists and reporting thresholds are amended from time to time. Check the current text of EPA's rule before you rely on any of this for a filing decision, and treat this page as general information, not a determination for your facility.