What Happened
The U.S. Environmental Protection Agency (EPA) announced a proposal to end the Greenhouse Gas Reporting Program (GHGRP), citing high compliance costs and limited regulatory value. EPA estimates that eliminating the program could save U.S. businesses up to $2.4 billion annually.
Who's Impacted
The GHGRP currently requires more than 8,000 facilities and suppliers across 47 source categories to report greenhouse gas (GHG) emissions data. If finalized, the proposal would remove reporting obligations for all sectors except petroleum and natural gas systems. Even within that sector, reporting for natural gas distribution would end permanently, while reporting for other segments would be deferred until 2034.
Key Details
- Statutory basis: EPA asserts that Clean Air Act section 114(a) does not require broad GHG emissions data collection beyond the petroleum and natural gas category subject to the Waste Emissions Charge (a fee on methane emissions established by the Inflation Reduction Act, which Congress later postponed until 2034).
- Rationale: EPA argues the Greenhouse Gas Reporting Program "is not directly related to a potential regulation" and that its elimination would reduce regulatory "red tape" without harming human health or the environment.
- Process: EPA initiated a public comment period. The Greenhouse Gas Reporting Program remains in effect until a final rule is issued.
- Policy alignment: The proposal is part of the Trump administration's regulatory reform agenda, which aims to reduce regulatory compliance costs and streamline agency functions.
Implications for Industry
- Reduced reporting costs. Many companies could save hundreds of thousands of dollars annually on compliance activities.
- Data gaps. Investors, communities, and regulators may face less GHG emissions data, complicating ESG reporting, benchmarking, and policy/rule development. This also could complicate U.S. efforts to respond to international trade requirements or tariffs, such as the EU's Carbon Border Adjustment Mechanism.
- Regulatory compliance. Some federal regulatory provisions provide for the use of data reported under these rules; examples are the section 45Q carbon capture and storage credit (which EPA discusses in its proposal) and the section 45V clean hydrogen tax credit. Businesses will need to work with regulators to identify alternative ways to demonstrate eligibility in the absence of GHG reporting data.
- Voluntary and indirect requirements. Companies that rely on Greenhouse Gas Reporting Program data for voluntary disclosure, disclosure to value chain partners, or other reporting may need to identify alternative approaches, or continue collecting the same information but not reporting it to EPA.
- U.S. state, and international rules. Certain state and international jurisdictions will continue to require GHG reporting, creating a patchwork of requirements. Six states (California, Colorado, Illinois, New Jersey, New York, and Oregon) now require GHG reporting or are phasing in such requirements. California's requirements are especially broad, including new requirements beginning in 2026 that apply to companies doing business in the state that meet certain revenue thresholds and cover Scope 1, 2, and 3 emissions. Companies reporting under the EU Corporate Sustainability Reporting Directive (CSRD) will likewise still need to collect and maintain certain GHG emissions data.
- Regulatory uncertainty. Environmental groups and states may challenge the rule, potentially delaying or altering implementation. A future administration could also reinstate GHG reporting under the same or a similar rule.
- Strategic considerations. Companies may wish to submit comments, reassess internal emissions monitoring and data collection, and prepare for possible divergence between federal and state programs.
Next Steps
EPA's Federal Register announcement includes instructions for submitting comments, which are due by November 3, 2025. Businesses should consider engaging in the comment process and evaluating how change may affect compliance strategies, voluntary reporting, and stakeholder expectations.
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