Executive Summary

• In a recent bipartisan letter to the Environmental Protection Agency (EPA), Senators Sheldon Whitehouse (D-RI) and Kevin Cramer (R-ND) urged the agency to reconsider its pending repeal of the Greenhouse Gas Reporting Program (GHGRP).
• EPA’s proposed rule, released in September, would remove all the emissions reporting requirements under the GHGRP, except for those subject to the methane emissions tax starting in 2034 as codified in the One Big Beautiful Bill Act.
• Eliminating this reporting requirement would make it more difficult to enact informed public policy and could further complicate the federal government’s ability to determine eligibility for certain tax credits.

Introduction

In a recent bipartisan letter to the Environmental Protection Agency, Senators Sheldon Whitehouse (D-RI) and Kevin Cramer (R-ND) urged the agency to reconsider its pending repeal of the Greenhouse Gas Reporting Program (GHGRP). The senators highlighted the importance of ensuring sufficient and accurate emissions data gathering, noting: “[W]e support the collection of information that improves the global competitiveness of American industry.”

EPA’s proposed rule, released in September, would remove all the emissions reporting requirements under the GHGRP, except for those subject to the methane emissions tax starting in 2034 as codified in the One Big Beautiful Bill Act (OBBBA). This action is part of the Trump Administration’s broad energy agenda to boost U.S. oil and gas production by declaring a national energy emergency, removing regulating barriers, and expediting permitting approvals for fossil fuel projects. The EPA estimated that the proposed rule would save $303 million per year from 2025–2033, totaling about $2 billion over 10 years for businesses that are required to report to the program

Eliminating this reporting requirement would make it more difficult to enact informed public policy and could further complicate the federal government’s ability to determine eligibility for certain tax credits.

Overview of the GHGRP

The GHGRP, which went into effect in 2009, mandated certain manufacturing facilities to report their GHG emissions annually and follow monitoring, verification, and recordkeeping requirements. It covers GHG emissions from 47 source categories across about 8,000 facilities in the United States and publishes emissions data in October each year.

EPA’s website states that the data collected through the program “can be used by businesses and others to track and compare facilities’ greenhouse gas emissions, identify opportunities to cut pollution, minimize wasted energy, and save money. States, cities, and other communities can use EPA’s greenhouse gas data to find high-emitting facilities in their area, compare emissions between similar facilities, and develop common-sense climate policies.”

Under the program, facilities are required to submit information on their emissions if:

• A facility emits more than 25,000 metric tons of CO_2e annually;
• Supply of certain products would lead to over 25,000 metric tons of CO_2e if those products are released, combusted, or oxidized; or
• A facility receives 25,000 metric tons or more of CO_2e for underground injection, which is the final step in carbon capture and sequestration.

EPA’s Proposal To Cancel the Program

On September 12, 2025, EPA Administrator Lee Zeldin announced a proposed rule to remove the GHGRP’s emissions reporting requirements, except for those subject to the Waste Emissions Charge (WEC). The 2022 Inflation Reduction Act (IRA) set the WEC, a tax on methane emissions, to begin in 2024, but the 2025 OBBBA postponed the implementation of the tax until 2034. This action is part of the Trump Administration’s broad energy agenda to boost U.S. oil and gas production by declaring a national energy emergency, removing regulating barriers, and expediting permitting approvals for fossil fuel projects.

EPA’s press release on its decision to repeal the program states the following:

“Unlike other mandatory information collections under the CAA, the GHGRP is not directly related to a potential regulation and has no material impact on improving human health and the environment. If finalized, the proposal would remove reporting obligations for most large facilities, all fuel and industrial gas suppliers, and CO2 injection sites.”

The EPA estimated that the proposed rule would save $303 million per year from 2025–2033, totaling about $2 billion over 10 years. Of the cost savings, more than 80 percent is associated with a reduced burden on the petroleum and natural gas industry, with the rest benefiting carbon-intensive manufacturing industries.

Implications of Removing the Program

While the EPA’s proposed cancellation of the GHGRP would significantly reduce costs for businesses that are required to report to the program, there are some potential downsides to the action.

Repealing the GHGRP would deprive U.S. policymakers of critical emissions data for designing decarbonization policies. Lawmakers and the federal government rely on economic data such as employment and manufacturing statistics to make important economic policy decisions. Similarly, they depend on the GHGRP’s regularly updated and comparable emissions data to learn about the emissions trajectory of various sectors in the economy. Absent a government accredited repository of emissions data, the private sector would have to fill in the gap. But there are limits in the scope and quality of the data collected by the private sector given constrained resources.

Scrapping the GHGRP would also create challenges for taxpayers to claim the OBBBA’s carbon sequestration tax credits since the program’s emissions data is used to determine eligibility. Although the OBBBA repealed about 60 percent of the IRA’s clean energy tax credits, it retained the carbon oxide sequestration credit. Senators Whitehouse and Cramer’s letter to the EPA stated: “Repealing [the GHGRP reporting requirements] without a clear alternative in place will put existing investments in flux and stymy future American leadership in [Carbon Capture, Utilization, and Storage] deployment.” Other senators have raised this issue. For example, Senator Shelley Moore Capito (R-WV) said in an interview: “If you’re really taking advantage of tax credits, you have to have measurements, and they have to be accessible. That’s unclear at this point.”

Further, rolling back the program would restrict U.S. exporters’ access to facility- and industry-level emissions data, leaving them at a disadvantage as more countries start to adopt carbon border adjustments—a policy that aims to address emissions embedded in internationally traded goods. For example, the European Union (EU) will start to implement its carbon border adjustment mechanism to levy a tax on certain imported goods based on their associated carbon emissions. If the GHGRP is eliminated, U.S. exporters subject to the regulation would need to switch to other credible entities to have their emissions data validated. Some U.S. legislative proposals that have carbon border adjustment components, such as the Clean Competition Act and the Foreign Pollution Fee Act, also rely on the GHGRP to calculate covered goods’ emissions.

Finally, canceling the GHGRP would remove a credible emissions measuring and reporting standard applicable to U.S. liquefied natural gas (LNG) exporters. Oil and gas companies worldwide regularly measure and estimate the GHG emissions associated with their production to comply with different jurisdictions’ emissions regulations. For example, in January 2027 the EU will start enforcing its methane regulation requiring methane monitoring, reporting, and verification on the gas sold to the EU market. Some hope this regulation would exempt U.S. LNG exporters since they are subject to the GHGRP standards. With the GHGRP on the chopping block, however, U.S.LNG exporters would have to incur additional costs to conform to the EU standards.

Looking Forward

It remains to be seen whether congressional opposition is sufficient to motivate the EPA to reconsider its plan. Notably, the agency recently backed down from its Energy Star proposal earlier this year due to the significant criticism from business leaders and members of Congress. If there is more pushback from Congress, businesses, trade associations, and other entities about EPA’s plan to roll back the GHGRP, the agency could rethink its strategy for the program. Rather than canceling almost the entire program, EPA could either scale it back as it originally planned, or make changes to it to better align with the administration’s energy agenda.