What’s New With Tier II Reporting (And What to Watch Next)

Tier II reporting changes rarely announce themselves in obvious ways. More often, they show up as a new required field, a portal update, or a system rule that didn’t exist last year.

For Reporting Year (RY) 2025, those changes are coming from multiple directions — state software updates, portal changes, and early signals from federal agencies. Knowing where those updates are — and which ones apply to your facilities — is key to submitting accurate, on-time reports.

Here’s a high-level look at what’s new and what compliance teams should be watching next.

Tier2 Submit Updates for RY2025

The EPA’s Tier2 Submit software for RY2025 includes several state-specific updates that affect how facilities report chemical inventory data.

New required fields apply to parts of New England. As a result, some facilities will see data requirements that were not present in prior years.

These changes highlight a critical step in the reporting process: always download and use the correct version of Tier2 Submit for the current reporting year. Using outdated software can lead to missing fields and incomplete submissions.

Oregon’s Tier II Portal Changes

Oregon has made several updates to its Tier II portal that affect both facility details and chemical reporting.

Recent changes include limits on NAICS code entries, a new required description of business activity, and closer alignment with the state’s Master Chemical List. Some hazard, fertilizer, and pesticide data now auto-populate from the list. At the same time, chemicals removed from the list must also be removed from facility reports.

For facilities with changing inventories, these updates may require more than a simple year-over-year rollover.

Potential Federal Tier II Form Changes

The EPA is also reviewing possible updates to the federal Tier II form. These changes aim to align the form with revised OSHA hazard categories.

If adopted, the updates could take effect as early as Reporting Year 2026. While details are still under review, facilities should begin paying attention now. Future hazard classification changes may affect how information is reported.

California’s CERS NextGen Transition

California is preparing for a major system update with the transition to CERS NextGen. Use of the new system will be mandatory beginning January 1, 2027.

Although that date is still ahead, the impact will be significant. Chemical inventory data will not carry over from the current system. Facilities will need to re-enter inventory information manually. Other changes include visible HMBP due dates, removal of the Emergency Response Plan template, and new timelines for submitting test results.

Seven years of historical data will transfer to the new system. The state also plans to provide training resources ahead of the launch. Even so, early preparation will be important.

MFA Expansion and State Fee Updates

Beyond reporting changes, several states have introduced updates that affect system access and submission logistics.

More Tier II Manager states now require multi-factor authentication. Keeping user account information current is essential to avoid access issues during reporting season. Missouri has also reinstated Tier II reporting fees, including back payments for prior years and ongoing annual fees.

These updates do not change what facilities report. But they can affect whether teams are able to submit on time.

Staying Ahead of Tier II Change

When Tier II requirements shift, the risk is not missing a headline update. It’s missing how small changes affect your specific facilities, systems, and timelines.

The Tier II Guide helps teams move from awareness to readiness by breaking down:

• Which updates apply in each state.
• What needs action now versus what to plan for later.
• Where system changes can create submission or access issues.
• How to stay prepared as requirements continue to evolve.
  

If Tier II reporting is part of your role, having clear guidance — not just updates — makes compliance easier to manage.

Download the Tier II Guide to stay informed, prepared, and confident in every submission.