TRI Form R for semiconductor and electronics plants

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 toxic chemical release report filed with EPA. Form R is the full report and Form A is the shorter alternative.

Semiconductor manufacturing is one of the few industries with its own EPA guidance document for TRI reporting. The guide exists (EPCRA Section 313 Industry Guidance for Semiconductor Manufacturing), but we could not confirm a cover date for the current version from a primary source, so we will not cite one. Before you rely on it, check EPA's TRI guidance page to see which edition is in force.

The guide exists because the chemicals in a semiconductor fabrication plant (a “fab”) are unusually hard to inventory. Material moves through wet benches, gas cabinets, gas treatment units, scrubbers and wastewater treatment, and along the way the same chemical can be manufactured, processed and otherwise used at different points. The threshold determination depends on classifying each of those activities correctly.

→ Do you have to file a Form R?

Where the reportable quantities come from

The classification question that decides whether you file. The rule sorts what you do with a chemical into three activity categories:

• Process means preparing a chemical, after it is manufactured, for distribution in commerce. EPA's TRI training materials place use as a reactant to make another substance or product squarely under process.
• Otherwise use is the catch-all for everything else. It covers processing aids, manufacturing aids and ancillary uses, none of which are incorporated into a product you ship or become part of it.
• Manufacture covers a chemical created in a reaction, whether or not you intended to produce it.

The risk lies in the thresholds. The reporting threshold is 10,000 lb for otherwise use and 25,000 lb for manufacture and process. If you classify an ancillary use as “process”, you can appear to be below a threshold you actually crossed.

Fabs face one more complication under the general rule. An etching or cleaning chemical that is consumed in the tool but never enters the product you ship is an ancillary use, not processing, even though a reaction is involved. The test is whether the chemical becomes part of what leaves your gate, not whether it reacted.

The recycling trap

Fabs recycle and reclaim heavily, and that works against Form A.

To use Form A, your annual reportable amount must not exceed 500 lb, and that total includes recycling and energy recovery, not only releases. A fab that recovers nearly all of its solvent has a small emissions number and a large reportable amount.

The rule also bars Form A entirely for any chemical on EPA's list of “chemicals of special concern”. That list covers every persistent, bioaccumulative and toxic (PBT) chemical, and it also covers every one of the per- and polyfluoroalkyl substances (PFAS).

PFAS is the live issue in this industry. Fluorinated surfactants and polymers have historically been present in photolithography and etch. Where PFAS is present, Form A is unavailable at any quantity, and range reporting is barred as well.

→ Form A or Form R · → How to calculate releases without monitoring data

Arizona's fab build-out, and where the work actually lands

Arizona now hosts the largest semiconductor plant construction program in the country.

TSMC Arizona, north Phoenix. As of July 2026, the total announced investment is $265 billion, covering 10 fabs, two advanced packaging plants and an R&D center. That fab count comes from the Arizona Commerce Authority's July 16, 2026 announcement, while TSMC's own site describes a smaller fab count at the same investment figure. Fab 1 has been in volume production of N4 chips since late 2024, with more than 3,500 employees.

Intel, Ocotillo campus in Chandler, including Fab 52 on the 18A process.

Amkor Technology, Peoria. This $7 billion advanced packaging and test campus broke ground on October 6, 2025. Production is expected in early 2028, with as many as 3,000 jobs at full build-out. Today it is a construction site, not an operating plant.

The fabs themselves have large in-house EHS (environmental, health and safety) teams. They are not the market for outside help with TRI reporting, and we are not pretending otherwise. The work lands on the Tier-2 and Tier-3 suppliers, the companies further down the supply chain:

• Chemical blenders
• Gas suppliers
• Parts cleaners
• Precision machining shops
• Coating and plating operations
• Makers of consumables
• Specialty fabricators

Many are in SIC codes 20 through 39 (SIC is an older system of industry classification codes) and crossed a reporting threshold in the last 3 years without noticing.

→ Our work for semiconductor and electronics manufacturers

Supplier notification when you sell to a fab

If you supply a formulated chemical product to a fab and you are in SIC codes 20 through 39, the rule requires you to send a written notice, called a supplier notification. It goes with the first shipment of each calendar year, and it must give:

• A statement that the product contains a chemical subject to TRI reporting (a “Section 313 chemical”)
• The name and CAS number of each one
• The percent by weight

That obligation applies whether or not you file a Form R yourself. The October 31, 2023 rule (88 FR 74360) also changed the notification requirement, so that there is now no minimum concentration for PBT chemicals or for PFAS. A trace is enough to trigger the notice, even when the chemical is properly absent from your safety data sheet.

→ Supplier notification rules

What TSMC's supplier standards say

TSMC's Supplier Sustainability Standards v3.0, dated July 6, 2026:

• Suppliers with factories or chemical analysis labs that must obtain environmental permits under local regulations “should acquire ISO 14001 certification and maintain its validity” (§C.M.1.3). ISO 14001 is the international standard for environmental management systems.
• Suppliers with factories that have more than 30 production workers, and contractors doing high-risk work for TSMC, “should obtain ISO 45001 certification” (§B.M.1.3). ISO 45001 is the international standard for occupational health and safety management systems.

Both provisions are conditional. They are triggered by permit status, headcount or risk level and do not apply to every supplier, so read them against your own situation. A supplier with no lab that triggers a permit is not within the stated terms, and neither is one with fewer than 30 production workers and no high-risk contract work.

Even so, a supplier trying to hold its place on an approved vendor list will feel a real practical effect, and the direction of travel is clear.

→ ISO 14001 consulting · → ISO 45001 consulting · → Running both as one integrated system

Arizona's state filing on the same date

Form R is due July 1. Arizona facilities that file a Form R or Form A also owe a state Toxic Data Report by the same deadline (A.R.S. § 49-962(C)), filed through myDEQ, the state's online portal. It is a separate filing with separate content, and filing Form A does not remove the obligation.

The Pollution Prevention Plan is the related requirement, and it has its own date. You must prepare the plan, implement it and maintain it, and its annual progress report goes in the Toxic Data Report. A facility that uses more than 10,000 lb/yr of a listed toxic substance must file the plan by December 31 of the following year (A.R.S. § 49-963(D)). The plan is not due on July 1.

→ Arizona's Pollution Prevention Plan and Toxic Data Report · → Missed the July 1 deadline?

Air monitoring and noise surveys while we are on site

A fab supplier that crosses a reporting threshold almost always has workplace air and noise obligations tied to the same chemicals and equipment:

• Acid mist on wet benches and plating lines
• Solvent vapor
• Metals in packaging and bonding
• Noise from vacuum pumps, chillers and compressed air, which a shop focused on its cleanroom tends to discount

Covering those on the same trip costs much less than two separate visits, and the results also feed your ISO 45001 work if you are heading in that direction.

→ Acid mist monitoring · → Solvent air monitoring · → Noise surveys

A caution: whether you have to file depends on your own facility's throughput and on how each chemical use is classified. This page is general information, not a threshold determination for your facility. The chemical lists are also revised, so check the current text of the federal rule.