EPCRA Tier II Reporting Deadline – March 1, 2026

Courtesy of EMA Regulatory Counsel Jeff Leiter and Jorge Roman

Pursuant to Section 312 of the Emergency Preparedness and Community Right-to-Know Act (EPCRA), Tier II chemical inventory reports for calendar year 2025 must be filed with the State Emergency Response Commission (SERC), Local Emergency Planning Committee (LEPC) and local fire department by March 1, 2026.

FUELIowa members may file chemical inventory reports here using the portal provided by the Iowa Department of Natural Resources. The staff contact listed as handling Iowa’s chemical inventory reporting is Simon Stecker, 515-783-7346 or iowa.epcra@dnr.iowa.gov. 

Since 1987, EPCRA requires covered facilities, including those operated by fuel marketers, to report each year on chemicals, including petroleum products, present at the facilities during the previous calendar year in quantities equal to or greater than established threshold quantities (discussed below). The information contained in the Tier II reports is used by state and local governments to respond to emergencies and address risks associated with stored hazardous chemicals.

Minimum Threshold Reporting Trigger

General Rule –– Covered chemicals are those chemicals for which Safety Data Sheets (SDS) are required under OSHA’s Hazard Communication Standard (29 CFR §1910.1200). Accordingly, facilities that store more than 10,000 pounds of a hazardous chemical at any point during the previous calendar year must file an EPCRA Tier II report. The 10,000 pounds compliance threshold is calculated by aggregating the maximum quantity of the hazardous chemical present onsite across all storage containers, including aboveground and underground storage tanks and portable skid tanks.

• Note: Under the regulation, the actual quantity stored is the trigger, not the storage capacity.
• Note: The household product exemption does not apply to heating oil stored for distribution or used for heating in business buildings.

Retail Fuel Threshold –– Retail gasoline facilities with 75,000 gallons or less of underground gasoline storage capacity and 100,000 gallons or less of underground diesel fuel storage capacity are exempt from EPCRA Tier II reporting requirements, provided that the underground storage tanks were in full compliance with Federal or State UST regulations at all times during the previous year. Cardlock fueling facilities are also subject to the retail fueling facilities exception, with the same storage capacity limits above.

The following gallons-to-pounds conversion chart below can be used to determine the 10,000-pound reporting trigger applicable to storage facilities other than retail gasoline and diesel fuel stations: