EPA proposes ending major parts of GHGRP: proposal summary

The U.S. Environmental Protection Agency (EPA) has proposed major changes to the Greenhouse Gas Reporting Program (GHGRP), aiming to ease reporting obligations, cut costs for industry and align with recent amendments to the Clean Air Act.

Last week, the U.S. Environmental Protection Agency (EPA) issued a proposal to reconsider the Greenhouse Gas Reporting Program (GHGRP). The initiative envisages the permanent elimination of reporting obligations for 46 source categories after the 2024 reporting year. According to the proposal, facilities, suppliers and underground injection sites tied to these categories would no longer be required to submit emissions data to the EPA. For the petroleum and natural gas sector, regulated under subpart W, the approach is twofold. The natural gas distribution segment would have its reporting obligations permanently removed after 2024, whereas the remaining nine segments would see reporting suspended until 2034, following amendments introduced by the One Big Beautiful Bill Act. For the 2025 reporting year, no sector would be required to submit data. The EPA also suggested extending the usual reporting deadline from 31 March 2026 to 10 June 2026, provided the rule is finalised in time.

Legal basis and policy context

The GHGRP was initially established under section 114 of the Clean Air Act, introduced through the Fiscal Year 2008 Consolidated Appropriations Act, to ensure large sources and suppliers reported their greenhouse gas emissions across numerous industries. Later reforms added a waste emissions charge under section 136 of the Act, intended to apply from calendar year 2024 onwards for most petroleum and natural gas system segments, excluding natural gas distribution. The legislative landscape changed in July 2025, when the One Big Beautiful Bill Act amended section 136(g) of the Clean Air Act. The revision delayed the effective start of the waste emissions charge until emissions reported for calendar year 2034 and later. This amendment has provided the EPA with the legal justification to suspend reporting obligations for the relevant subpart W segments until 2034.

Scope, sectors affected and timing

The proposed revisions would affect a broad range of industries. Forty-six categories outside subpart W would lose their reporting requirements after the 2024 reporting year. These include stationary fuel combustion, electricity generation, aluminium, cement, glass, iron and steel production, industrial wastewater treatment, landfills, suppliers of petroleum and coal-based fuels, and carbon dioxide injection facilities. Within subpart W, natural gas distribution would be permanently excluded from reporting obligations, while the other nine segments, covering onshore and offshore production, processing, transmission, storage, and LNG facilities, would see obligations suspended until 2034.

Financial and operational implications

The EPA estimates that the proposal will generate substantial financial savings for regulated industries. Annual cost reductions are projected at approximately 303 million US dollars for the period 2025 to 2033. Of this amount, 256 million dollars per year would come from the petroleum and natural gas sector, with natural gas distribution accounting for about three million dollars. The remainder, estimated at 47 million dollars annually, would stem from other industries. Over the full period, total savings are projected to reach between 2.0 and 2.4 billion dollars, depending on the discount rate applied.

Implications for transparency and stakeholders

Currently, the GHGRP covers more than 8,000 facilities and suppliers across forty-seven source categories. If implemented, the proposal would drastically reduce the scope of mandatory emissions reporting. The removal or suspension of obligations may create significant data gaps, limiting visibility of emissions in several key sectors. This reduction in transparency could hinder the ability of investors, communities and regulators to assess environmental performance. The delay in reinstating reporting requirements for most petroleum and natural gas segments until 2034 may also complicate long-term planning for regulated entities. Many stakeholders, particularly those who rely on GHGRP data for voluntary disclosures, ESG reporting or supply chain monitoring, may need to adjust their approaches in the absence of standardised regulatory data.

Key deadlines and next steps

The EPA will initiate a public comment period of forty-seven days following publication of the proposal in the Federal Register, accompanied by a virtual hearing fifteen days after publication. Stakeholders are encouraged to review the official instructions, which will be provided in the Federal Register and on the Agency’s website. If finalised before March 2026, the deadline for 2025 reporting could be extended to 10 June 2026, although no reporting would be required for that year under the proposal. For more information on the proposed rule and how to participate in the comment process, please see the EPA fact sheet.

Conclusion

The EPA’s proposed revisions to the GHGRP would amount to one of the most significant changes in non-financial reporting obligations for greenhouse gases in the United States. The reform prioritises cost reduction and administrative efficiency, projecting multi-billion dollar savings across industries. At the same time, it raises concerns over reduced transparency, diminished data availability and the broader implications for regulatory alignment and ESG disclosure practices. The final rule will be shaped by public comments, possible legal review and the Agency’s interpretation of its statutory authority under the Clean Air Act.