The U.S. Environmental Protection Agency (EPA) has proposed a major rollback of its Greenhouse Gas Reporting Program (GHGRP), a regulation that has required thousands of facilities to measure and report their emissions for more than 15 years. If finalized, the rule would significantly scale back federal greenhouse gas reporting, with only limited requirements remaining for certain oil and gas operations.
This development represents one of the most consequential shifts in U.S. climate policy since the reporting program was first introduced in 2009. To understand the potential implications, it’s important to review how the program came to be, what the proposed changes would do, and the arguments on both sides of the debate.
Background: How the GHGRP Came to Be
Federal agencies such as the EPA cannot act without authorization from Congress. This authority, called “enabling legislation,” defines the boundaries of what an agency can do. For greenhouse gas emissions, EPA pointed to the Clean Air Act (CAA) as its primary legal authority.
When EPA created the Mandatory Greenhouse Gas Reporting Rule in 2009, it cited two provisions of the CAA:
- Section 114(b)(1): allows EPA to require owners or operators of emission sources to keep records and submit reports.
- Section 307(d)(1)(U): grants discretion to the Administrator to promulgate additional regulations.
The agency’s actions were also influenced by the FY2008 Consolidated Appropriations Act, which instructed EPA to develop a mandatory reporting program for greenhouse gas emissions across all major sectors. However, EPA did not rely directly on this appropriation for its authority.
A crucial precursor was the 2009 Endangerment Finding, in which EPA determined that greenhouse gases threatened public health and welfare. This finding was made under CAA Section 202(a), focused on motor vehicle emissions, but it had broad implications. Importantly, EPA considered global as well as domestic impacts when making its determination—a first for the agency.
With this foundation, EPA established reporting requirements for facilities that emitted more than 25,000 metric tons of carbon dioxide equivalent (MTCO2e) annually. Over time, the rule expanded to cover a wide range of sectors, from fossil fuel suppliers to large industrial emitters. Today, more than 8,000 facilities report greenhouse gas emissions under the program.
Summary of the Proposed Change
On September 16, 2025, EPA published a proposed rule (90 FR 44591) that would eliminate greenhouse gas reporting obligations for nearly all categories. The key provisions include:
- Removal of most reporting requirements: All categories except Petroleum and Natural Gas Systems (40 CFR 98, Subpart W) would no longer be required to report.
- Reduction within Subpart W: The Natural Gas Distribution segment would be removed entirely, and reporting for other segments would be postponed until 2034.
- Extended deadline: The deadline for submitting 2025 reporting year data would shift from March 31, 2026, to June 10, 2026, to avoid requiring facilities to submit data that may no longer be necessary.
EPA explained that these changes are intended to align with Executive Order 14192, “Unleashing Prosperity Through Deregulation,” which directs agencies to reduce unnecessary burdens.
The agency also noted that the legal basis for the GHGRP has weakened in light of recent developments:
- The Supreme Court’s decision in Loper Bright Enterprises v. Raimondo (2024) eliminated the “Chevron doctrine,” which had given agencies deference when interpreting ambiguous laws.
- EPA’s August 2025 proposal to reverse the 2009 Endangerment Finding removed the determination that greenhouse gases pose a threat to public health and welfare. Without this finding, EPA argued it lacks clear statutory authority to mandate reporting.
One exception remains: certain oil and gas facilities covered by Subpart W will continue reporting because they are tied to the Waste Emissions Charge (WEC), created by the Inflation Reduction Act. However, a Congressional resolution in early 2025 substantially limited the WEC’s effectiveness.
Arguments for Keeping the GHGRP
Supporters of the reporting rule point to several reasons why it should remain in place.
- Transparency and Accountability
The GHGRP has provided consistent, publicly available data on greenhouse gas emissions from major U.S. facilities. This information is widely used by policymakers, researchers, and advocacy groups to track progress and identify trends. - Foundation for Climate Policy
The program has been a cornerstone for climate-related regulation and planning. Without it, federal and state governments may lack reliable data for designing policies or meeting international commitments. - Corporate Responsibility and Investor Demands
Many companies use GHGRP data in their own environmental, social, and governance (ESG) reports. Investors increasingly expect standardized, verified emissions data, and the federal program has offered a trusted baseline. - Long-Term Planning and Certainty
The rule provides a consistent framework that helps companies prepare for potential future regulations, regardless of changes in political leadership. Eliminating it could create uncertainty. - Global Competitiveness
International markets, including the European Union, are implementing carbon border adjustments and other climate-related trade policies. Having a federal reporting system helps U.S. companies demonstrate compliance and remain competitive.
Arguments Against Keeping the GHGRP
On the other side, critics argue that the GHGRP is unnecessary or even harmful.
- Regulatory Burden and Cost
Facilities spend time and resources on monitoring, data management, and reporting. Smaller emitters may see the costs as disproportionate to the benefits. - Questionable Legal Authority
With the reversal of the Endangerment Finding and the loss of Chevron deference, EPA’s legal foundation for the rule is weaker. Opponents argue that Congress, not EPA, should decide whether greenhouse gas reporting should continue. - Redundancy with Voluntary Reporting
Many large companies already disclose emissions through voluntary frameworks such as CDP or sustainability reports, and upcoming SEC climate disclosure rules may cover much of the same ground. Critics say duplicative reporting adds little value. - Economic Growth Through Deregulation
Supporters of the rollback view it as part of a broader effort to reduce regulatory “red tape,” improve efficiency, and strengthen U.S. competitiveness. - Debate Over Global Impacts
Some argue that EPA’s original reliance on global impacts to justify domestic regulation stretched its statutory authority. The rollback is seen as correcting that overreach.
Potential Economic Impacts
The economic consequences of eliminating the GHGRP could be both positive and negative, depending on perspective.
- Cost Savings: Companies would save on compliance costs, particularly those in energy-intensive industries. For facilities operating on thin margins, these savings could be meaningful.
- Reduced Transparency Risks: Without standardized federal data, investors and trading partners may view U.S. companies as less transparent. This could increase financing costs or complicate participation in international supply chains.
- Market Uncertainty: Some companies may face pressure from state governments, customers, or investors to continue reporting voluntarily, leading to a patchwork of requirements.
- Innovation and Carbon Markets: Critics of the rollback worry that without federal reporting, the development of carbon markets and emissions-reduction technologies could be slowed, reducing opportunities for innovation.
Impacts on EHS and Industrial Companies
For environmental, health, and safety (EHS) leaders and industrial operators, the proposed changes raise important questions:
- Operational Shifts: Companies may scale back emissions monitoring and reporting systems if federal requirements disappear. This could reduce internal visibility into emissions trends.
- Voluntary vs. Mandatory Reporting: Facilities will need to decide whether to continue collecting and disclosing data voluntarily, particularly if investors or state regulators expect it.
- Risk Management: Reduced federal oversight may shift accountability toward state regulators, NGOs, or investors. Companies could face reputational risks if they appear to be reducing transparency.
- Strategic Planning: For organizations that use emissions data to benchmark efficiency or justify investments in cleaner technology, the absence of a federal program could make long-term planning more difficult.
Conclusion
The EPA’s proposal to roll back the Greenhouse Gas Reporting Program marks a significant turning point in U.S. environmental regulation. Supporters see it as a necessary correction—reducing costs, addressing legal vulnerabilities, and restoring congressional authority. Opponents warn that it would undermine transparency, climate policy, and corporate accountability at a time when global pressures for emissions reporting are only increasing.
For EHS leaders and industrial companies, the most immediate task is to assess how the rollback could affect compliance strategies, investor expectations, and long-term planning. Even if the federal reporting program is dismantled, the demand for greenhouse gas data is unlikely to disappear. Companies that proactively manage and disclose their emissions may still find themselves better positioned in an uncertain regulatory and market landscape.
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