On June 22, 2026, EPA published a final rule updating the hazardous chemical inventory reporting requirements under EPCRA Sections 311 and 312. If you file Tier II reports, this one matters. But the timeline gives you room to prepare, and there’s very little you need to do right now.

Here’s what changed, when it takes effect, and how Encamp is handling it on your behalf.

What Actually Changed

The rule aligns EPCRA’s hazard categories at 40 CFR Part 370 with OSHA’s 2024 Hazard Communication Standard (29 CFR 1910.1200), which OSHA updated to match the latest revision of the UN’s Globally Harmonized System (GHS). In plain terms: the rule lines up the hazard categories you use on your Tier II form with the categories already on your Safety Data Sheets.

The core changes:

• New hazard categories. EPCRA is adopting OSHA’s hazard classes and categories directly. This includes refinements like expanded acute toxicity (inhalation) categories covering vapors, gases, and dusts/mists, and a codified definition for combustible dust.
• SDS terminology. The rule formally drops “Material Safety Data Sheet (MSDS)” in favor of “Safety Data Sheet (SDS).” Same document, consistent language.
• Direct SDS-to-Tier II data flow. Because the categories now match, hazard data can transfer more cleanly from your SDSs to your Tier II form, which should reduce discrepancies and reporting confusion over time.

The intent behind all of this is better information for first responders and communities, plus a smoother reporting process for facilities.

The Timeline, and Why There’s No Fire Drill

The rule is effective August 21, 2026, but the compliance dates are further out:

• January 1, 2028 – SDS submissions under Section 311 must use the new hazard categories.
• March 1, 2028 – The first Tier II forms using the new categories are due, covering the 2027 reporting year (RY2027).

So while the effective date lands this summer, your first Tier II filing under the new categories isn’t due until the 2028 reporting deadline.

Watch for Updated SDSs From Your Manufacturers

Here’s a practical detail worth flagging early. Because this rule ties EPCRA hazard categories to OSHA’s HazCom Standard, the flow of accurate data starts upstream with your chemical manufacturers and suppliers.

As manufacturers bring their Safety Data Sheets into conformity with the 2024 OSHA standard, they’ll be issuing updated SDSs with revised hazard classifications. Those updated SDSs are the source of truth for the new hazard categories that will eventually populate your Tier II report.

What that means for you:

• Expect a wave of revised SDSs from your suppliers over the coming reporting cycles as they update to the new classifications, if they haven’t already.
• Get those updated SDSs into your chemical catalog as you receive them. Keeping your catalog current with the latest SDS versions is the single most valuable thing you can do now to make the eventual transition painless.
• Accurate SDS data upstream makes reporting downstream easy. Once the categories line up between your SDSs and your Tier II form, the data transfer is far cleaner and there’s much less room for discrepancy.

You don’t need to re-file or re-classify anything today. Just make a habit of capturing updated SDSs as they arrive so your catalog is ready when states begin adopting the new categories.

What Encamp Customers Need to Do Right Now: Essentially Nothing

We know the effective date can look alarming when it hits your inbox. A few customers have already asked. The short answer: you don’t need to take action today.

Here’s our approach:

• We’ll update our chemical catalog to reflect the new categories, but deliberately, in step with the state portals. If we push updates before states are ready to receive the new data, that data has nowhere to go. We won’t get ahead of the portals.
• We don’t expect most states to adopt changes this reporting year. Because compliance is tied to RY2027, state-level implementation is likely to lag. We’re monitoring adoption state by state.
• We’ll communicate crosswalks and any required actions as states adopt. When a state moves to the new categories, we’ll send you the crosswalk mapping old categories to new, along with anything specific you need to do to stay compliant.

In other words, we’re tracking this so you don’t have to. As the regulatory picture develops between now and the 2028 deadline, we’ll keep you informed with concrete, timely guidance rather than a premature scramble.

Questions?

If you have questions about how the new hazard categories affect your specific facilities or chemical inventory, reach out to your Customer Success contact. We’ll continue posting updates here as state adoption progresses.

References and Resources

The Rule and Regulations

• Final Rule, “EPCRA Hazardous Chemical Inventory Reporting Requirements: Conformity with the 2024 OSHA Hazard Communication Standard” (91 FR 37022, June 22, 2026): https://www.federalregister.gov/documents/2026/06/22/2026-12426/epcra-hazardous-chemical-inventory-reporting-requirements-conformity-with-the-2024-osha-hazard
• EPCRA Sections 311/312 regulations, 40 CFR Part 370: https://www.ecfr.gov/current/title-40/chapter-I/subchapter-J/part-370
• OSHA Hazard Communication Standard, 29 CFR 1910.1200: https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.1200

EPA Guidance and the Hazard Category Crosswalk

• EPA reporting guidance, “Revisions to Hazard Categories and Reporting Guidance”: https://www.epa.gov/epcra/epcra-hazardous-chemical-inventory-reporting-revisions-hazard-categories-and-reporting
• 2027 EPCRA Hazard Categories and OSHA Hazard Category Crosswalk (May 2026, XLSX): https://www.epa.gov/system/files/documents/2026-05/2027-epcra-hazard-categories-and-osha-hazard-category-crosswalk_may-2026_0.xlsx
• Tier II Form and instructions (final draft): https://www.epa.gov/epcra/tier-ii-forms-and-instructions

OSHA HazCom Resources

• OSHA Hazard Communication overview: https://www.osha.gov/hazcom
• OSHA HazCom rulemaking (2024 final rule): https://www.osha.gov/hazcom/rulemaking