EPCRA Tier II Filing Deadline and State-by-State Reporting Requirements: The Complete Guide 

Summary 

EPCRA Tier II reports are due March 1 every year, covering the chemical inventory your facility held at any point during the prior calendar year. The report goes to three recipients: your State Emergency Response Commission (SERC), your Local Emergency Planning Committee (LEPC), and the fire department with jurisdiction over your facility—not just "the EPA," which is a common misunderstanding. What trips up multi-facility operators isn't the federal rule itself; it's that federal thresholds are a floor, not a ceiling. A long list of states set lower reporting thresholds, add data requirements the federal form doesn't ask for, or run their own filing portals entirely separate from the EPA's software. This guide covers both layers: the federal baseline everyone starts from, and the state-by-state variation that actually determines what you file, where, and when. 

Introduction 

EPCRA Tier II reports are due March 1 every year, covering the chemical inventory your facility held at any point during the prior calendar year. The report goes to three recipients: your State Emergency Response Commission (SERC), your Local Emergency Planning Committee (LEPC), and the fire department with jurisdiction over your facility—not just "the EPA," which is a common misunderstanding. What trips up multi-facility operators isn't the federal rule itself; it's that federal thresholds are a floor, not a ceiling. A long list of states set lower reporting thresholds, add data requirements the federal form doesn't ask for, or run their own filing portals entirely separate from the EPA's software. This guide covers both layers: the federal baseline everyone starts from and the state-by-state variation that actually determines what you file, where, and when. 

Tier I vs. Tier II—What you're filing 

EPCRA Section 312 technically gives facilities a choice between two report formats. A Tier I report is an aggregate summary—it groups your chemical inventory by hazard category (fire hazard, sudden-release hazard, and so on) without naming individual chemicals or exact quantities. A Tier II report is chemical-specific: it lists each hazardous chemical by name, its maximum and average quantity on-site during the year, and precisely where and how it was stored. 

In principle, EPA's own form allows either option, or Tier I satisfies the statute on its own. In practice, that choice has mostly disappeared. Nearly every SERC now requires the more detailed Tier II data as a matter of state rule, regardless of what the federal statute technically permits—which is exactly why "Tier II" has become the default shorthand for this entire reporting obligation, even though EPCRA Section 312 formally offers both options. If you're filing for the first time, plan on Tier II being the expected format unless your state explicitly tells you otherwise. 

The federal baseline: Deadline and thresholds 

1. The March 1 deadline 

The Tier II reporting period is the preceding calendar year, and the report is due March 1 of the following year. EPCRA Section 312(a)(2) sets this as a statutory deadline, which is why EPA’s own guidance is direct about the fact that it cannot grant extensions—the March 1 date isn’t a regulatory choice EPA could relax administratively; it’s written into the statute itself. Miss it, and there’s no federal mechanism to ask for more time, though individual states may have their own late-filing procedures (see the penalties section below). 

2. Federal minimum thresholds 

Two thresholds define who has to report at the federal level, and they hinge on whether the chemical is an “Extremely Hazardous Substance” (EHS): 

• 10,000 pounds: The reporting threshold for any hazardous chemical for which OSHA’s Hazard Communication Standard requires a Safety Data Sheet, if it isn’t separately listed as an EHS. 

• 500 pounds, or the Threshold Planning Quantity (TPQ), whichever is lower: The reporting threshold for chemicals on the EHS list. 

The EHS list and each substance’s TPQ are published in 40 CFR Part 355, Appendices A and B — that’s the definitive source to check a specific chemical against, rather than relying on a secondhand summary, since TPQs vary substance by substance and some fall well under 500 pounds. 

3. Who files, and with whom? 

The filing obligation falls on the owner or operator of any facility subject to EPCRA Section 311 — meaning any facility required to maintain an SDS for a chemical stored above the applicable threshold. The report itself doesn’t go to EPA. It goes to three separate recipients: the SERC (or Tribal Emergency Response Commission, where applicable), the LEPC for the facility district, and the local fire department with jurisdiction. Some states have consolidated this into a single portal submission that automatically routes the data to all three (Kentucky’s Haz connect system is one example, covered below), but the underlying obligation is still to all three parties, and it’s worth confirming your state’s portal actually handles that routing rather than assuming it does. 

Why state requirements diverge So much 

EPCRA sets off a federal floor, not a federal ceiling, and EPA has been explicit that states retain the authority to go beyond it. The preamble to EPA's own rulemaking on state flexibility describes exactly this—states are free to establish stricter reporting thresholds, require additional data elements, and administer their own systems, so long as they don't fall below what EPCRA requires. On top of that, most states layer their own fire-code and emergency-response frameworks over the federal chemical-inventory rule, since Tier II data feeds directly into local fire departments for pre-planning. The result is that a single federal explainer genuinely isn't sufficient for anyone operating in more than one state—the federal thresholds tell you the minimum, but the state rule tells you what you actually have to file.

Where states diverge from the federal floor 

The five examples below aren't the only states with variations, but they illustrate the different ways divergence shows up — lower thresholds, no upper tier at all, unusual filing windows, entirely separate hazardous-substance lists, and, in Nevada's case, a completely different regulatory framework layered on top of EPCRA. 

• California 

California doesn't use a standalone Tier II form at all. Instead, the Tier II obligation is folded into the state's Hazardous Materials Business Plan (HMBP), filed through the California Environmental Reporting System (CERS). The state's reportable quantities are dramatically lower than the federal 10,000-pound threshold: 500 pounds for solids, 55 gallons for liquids, and 200 cubic feet for compressed gases, with extremely hazardous substances still governed by the federal TPQ, which is lower. On top of the chemical inventory, California's HMBP requires an emergency response plan, employee training documentation, and an annotated site map showing storage areas, access points, and emergency shutoffs—none of which the federal Tier II form asks for. 

• Louisiana 

Louisiana applies a flat 500-pound threshold to any hazardous chemical, with no equivalent to the federal 10,000-pound general tier at all. Extremely hazardous substances follow the same rule as elsewhere—500 pounds or the TPQ, whichever is lower—but for ordinary OSHA-hazardous chemicals, Louisiana simply doesn't recognize the higher federal threshold. Reports go to the Louisiana State Police's Right-to-Know unit, and the state's online filing window typically opens in January and runs through the March 1 deadline. Louisiana does not accept submissions made through Tier 2 Submit, Tier II Manager, or E-Plan—facilities must file directly through the state's own Tier II Inventory Filing website. 

• Vermont 

Vermont sets an even lower general threshold—10000 pounds, or the TPQ if lower—for most substances—while carving out a specific 10,000-pound threshold for petroleum products. Vermont is also one of the few states with a genuinely different filing calendar rather than a single due date: the state's Community Right-to-Know Program requires facilities to submit between January 1 and March 1 for the preceding calendar year, using EPA's Tier2 Submit software. 

• New Jersey 

New Jersey runs its own Environmental Hazardous Substance (EHS) list, separate from the federal EHS list, and its own reporting threshold structure: 500 pounds where no state-specific Reporting quantity is listed for a substance on that list, or 10,000 pounds for anything not on the state list. Facilities don't file the federal Tier II form or use Tier 2 Submit—New Jersey requires submission through its own eCRTK Survey system, referred to as the Community Right to Know Survey, which functions as the state's substitute for the federal form rather than a supplement to it. 

• Nevada (Clark County) 

Nevada is the outlier that doesn't fit the "lower threshold" pattern at all. Statewide, Nevada uses its own "Nevada Online Hazardous Materials Reporting System," administered jointly by the State Fire Marshal and the State Emergency Response Commission. Clark County administers its hazardous materials reporting under the International Fire Code (IFC) rather than EPCRA thresholds, structured as a State Fire Marshal operating permit. IFC material-class thresholds range from essentially zero up to 500 pounds depending on hazard category, and no blanket exemptions apply once a material falls into one of the IFC categories. This is worth calling out explicitly because it's easy to assume "EPCRA thresholds" apply uniformly within a state—Nevada shows that even a single jurisdiction can run a structurally different system layered on top of, rather than derived from, the federal framework. 

The 50-state filing portal reference table 

The table below is meant to be used before you start your filing, not after — check your state's system and any fee here first, so you're not discovering mid-filing that your state doesn't accept the federal software. This version is built directly from EPA's own "State Tier II Reporting Requirements and Procedures" page rather than left as a placeholder — 15 states in the earlier draft had the wrong system named (Alaska, Arkansas, Connecticut, Delaware, Illinois, Indiana, Iowa, Maryland, Massachusetts, Michigan, Minnesota, Mississippi, Missouri, Montana, New Hampshire, South Carolina, Washington, and Wisconsin all changed). Fee figures remain genuinely sparse — EPA's own reference only states a fee for a handful of states — so most fee cells now read "Not stated / confirm with SERC" instead of a guessed number. A handful of systems account for most states: E-Plan is the most widely used multi-state portal, followed by Tier2 Submit (EPA's own downloadable software, still accepted directly by many SERCs), Tier II Manager, and a set of state-built systems including California's CERS, Texas's STEERS, New Jersey's eCRTK Survey, and Pennsylvania's PATTS. A smaller group of states — Nebraska, Kansas, Utah, and Wyoming — run their own standalone portals outside any of the shared systems. 

Fees vary by state and sometimes by filing method within the same state. As one illustration, Alabama charges $25 per year for facilities that file through E-Plan but nothing for facilities using Tier 2 Submit directly, while Tennessee charges a flat $25-per-facility fee through E-Plan. Utah and Washington explicitly charge no state fee. Given how often portal assignments, fees, and deadlines change, treat the specific figures below as a starting point to verify against your state's current SERC page rather than a final answer—this is exactly the kind of detail state agencies update without much notice. 

Rows marked "Not stated / confirm with SERC" reflect states where a fee figure wasn't published on EPA's or the state's own reporting page as of this review — confirm directly with the state's SERC before filing. North Dakota and Oregon don't name a specific electronic filing system on EPA's state-by-state page either; contact the SERC directly for current filing instructions. 

Late filing and penalty exposure 

Kentucky is a useful concrete example of how state-level penalties work: under KRS 39E.990(2), the Kentucky Emergency Response Commission assesses a one-time $250 late fee per facility for reports submitted after March 1—a fixed, predictable state-level cost. That’s on top of, not instead of, federal EPCRA exposure. EPCRA Section 325(c) and 40 CFR 372.18 set a statutory civil penalty of up to $25,000 per day per violation for Section 312 noncompliance, and that figure is adjusted periodically for inflation under the Federal Civil Penalties Inflation Adjustment Act. Because the current inflation-adjusted maximum changes from year to year — and 2026 saw an unusual disruption to the normal adjustment cycle—check the current figure directly in 40 CFR 19.4 rather than relying on a number quoted elsewhere; this is a case where citing a stale figure would understate real exposure. The practical takeaway either way: a missed deadline is rarely just a state processing fee — it’s a state fee plus a live, if rarely maximized, federal enforcement risk on top of it. 

Building a repeatable multi-state filing process 

For operators managing more than one facility across state lines, an annual scramble gets more expensive every year it's repeated. Four things make it repeatable: 

• Maintain one master chemical inventory tied to current SDS hazard classifications: Your Tier II data should be traced directly back to the hazard classifications on file for each SDS—if those go out of sync, your filings will too. 

• Map each facility to its specific state threshold and filing system: Use the Section 6 table as a starting checklist, not a final answer, and confirm each facility's assignment against its state's current SERC page. 

• Calendar the January review of your state-by-state data, not just the March 1 deadline. By the time the deadline is close, there's no runway left to catch a changed portal or fee. 

• Track state-specific extras—site maps, emergency response plans, and training documentation—as their own line of items: Separate from the main chemical inventory, so they don't get missed when the inventory itself looks complete. 

Facilities managing this across multiple sites often reach a point where spreadsheet tracking breaks down — CloudSDS's multi-facility Tier II report generation pulls from a single chemical inventory to produce state-specific filings, which is worth a look if you're at that scale. 

If you're already keeping your SDS hazard classifications current for HazCom purposes, that same inventory is the foundation for Tier II reporting — the two obligations should be running off the same underlying data, not maintained separately. 

Frequently asked questions 

1. Do I file Tier I or Tier II? 

Technically it satisfies EPCRA Section 312, but in practice nearly every state now requires the more detailed Tier II format as a matter of state rule. Unless your SERC explicitly tells you otherwise, plan on filing Tier II. 

2. What happens if I miss the March 1 deadline? 

EPA cannot grant extensions, since the deadline is set by statute. Beyond that, exposure is state-specific—some states assess a fixed late fee (Kentucky's is $250 per facility), and federal EPCRA civil penalties of up to a statutory maximum per day, adjusted for inflation, apply on top of any state fee. 

3. Do thresholds apply per chemical, per facility, or per company? 

Per chemical, per facility. Each hazardous chemical is evaluated against the threshold separately, based on the maximum amount present at that specific facility at any one time during the reporting year—not aggregated across a company's other locations. 

4. Are Extremely Hazardous Substance thresholds different from the general 10,000-pound threshold, and where do I find the EHS list? 

Yes. EHS chemicals are reportable at 500 pounds or the chemical's Threshold Planning Quantity, whichever is lower—which for some substances is well under 500 pounds. The list and each substance's TPQ are published in 40 CFR Part 355, Appendices A and B. 

5. Does this state comparison table get updated, and how often? 

Yes. This page is maintained as a reference asset rather than a dated annual post—see the "last reviewed" date at the top, which is updated on a recurring basis ahead of each March 1 deadline. State portals, fees, and thresholds do change, so always cross-check your specific state's current SERC page before filing. 

The bottom line 

Every Tier II filing rests on two layers: the federal floor (March 1, the 10,000-lb/500-lb-or-TPQ split, filed with your SERC, LEPC, and fire department) and your state's specific rules on top of it, which can mean a lower threshold, an entirely different portal, or a different filing window altogether. The federal layer barely changes year to year; the state layer is where the real risk of an outdated filing hides. For readers operating specifically in Alabama or California, the single-state deep dives on this site cover those two states in full detail—this guide is the map to check before you land on either one. 

References: 

Federal (EPA) sources 

• EPA—Are there Tier II deadline extensions? — https://www.epa.gov/epcra/are-there-tier-ii-deadline-extensions 

• EPA – Tier II Forms and Instructions — https://www.epa.gov/epcra/tier-ii-forms-and-instructions 

• EPA – State Tier II Reporting Requirements and Procedures — https://www.epa.gov/epcra/state-tier-ii-reporting-requirements-and-procedures 

• eCFR – 40 CFR Part 355, Appendices A & B (EHS list and TPQs) — https://www.ecfr.gov/current/title-40/chapter-I/subchapter-A/part-355 

• eCFR – 40 CFR § 19.4 (current statutory civil monetary penalties, incl. EPCRA) — https://www.ecfr.gov/current/title-40/chapter-I/subchapter-A/part-19/section-19.4 

• Cornell Law – 40 CFR § 372.18 (EPCRA §325(c) penalty basis, $25,000/day statutory reference) — https://www.law.cornell.edu/cfr/text/40/372.18 

• EPA – Electronic Submission of Tier II Inventory Information — https://epa.gov/epcra/electronic-submission-tier-ii-inventory-information 

California 

• Kern County, CA – HMBP/CERS thresholds — https://www.kernpublichealth.com/permitting-compliance/unified-program-agency-upa/hazardous-materials-business-plan-california-environmental-reporting-system-cers 

• ACTenviro – California HMBP Requirements — https://www.actenviro.com/california-hmbp-requirements-have-changed/ 

• Citadel EHS – CERS March 1, 2026 deadline overview — https://citadelehs.com/2026/02/26/california-environmental-reporting-system-cers-what-businesses-need-to-know-before-the-march-1-2026-deadline/ 

Louisiana 

• Calcasieu Parish Police Jury – Tier II Reporting — https://www.calcasieu.gov/services/emergency-preparedness/tier-ii-reporting 

• Louisiana State Police – RTK Law Summary (PDF) — https://lsp.org/media/pc5de3cc/rtk_law_summary-8212025.pdf 

• Louisiana State Police – Tier Two Instructions (PDF) — https://lsp.org/media/s24pd1h2/tier-ii-filing-instructions.pdf 

Vermont & Kentucky 

• EPA – State Tier II Reporting Requirements and Procedures (Vermont/Kentucky entries) — https://www.epa.gov/epcra/state-tier-ii-reporting-requirements-and-procedures 

New Jersey 

• Encamp – New Jersey Tier II Reporting — https://encamp.com/tier-ii-reporting/new-jersey/ 

• NJDEP – Community Right to Know Survey overview (PDF) — https://cwm.unitar.org/publications/publications/cbl/prtr/pdf/cat7/crtk_index.pdf 

• NJ Admin. Code 7:1G-3.1 — https://regulations.justia.com/states/new-jersey/title-7/chapter-1g/subchapter-3/section-7-1g-3-1 

Nevada (Clark County) 

• US Compliance – Hazardous Material Storage Reports with Non-Federal Thresholds — https://www.uscompliance.com/blog/hazardous-material-storage-reports-with-non-federal-thresholds/ 

Penalty/inflation-adjustment context 

• Federal Register – No Adjustment to Civil Monetary Penalty Amounts (2026) — https://www.federalregister.gov/documents/2026/07/07/2026-13629/no-adjustment-to-civil-monetary-penalty-amounts 

• Federal Register – Civil Monetary Penalty Inflation Adjustment (Jan. 2025 EPCRA §325(d)(1) reference) — https://www.federalregister.gov/documents/2025/01/08/2025-00206/civil-monetary-penalty-inflation-adjustment