On September 12, 2025, the U.S. Environmental Protection Agency (EPA) issued a proposed rule to permanently eliminate most reporting obligations under the Greenhouse Gas Reporting Program (GHGRP).  

The action would relieve compliance responsibilities for 46 source categories and significantly scale back reporting under Subpart W of the petroleum and natural gas systems. EPA estimates the proposal could save regulated industries up to $2.4 billion over the next decade. 

This Delve outlines the scope of EPA’s proposed rule, background, and what comes next for affected facilities. 

Summary of Action 

EPA’s proposal would permanently remove reporting obligations for 46 source categories, including facilities in industries such as electricity generation, petroleum refining, cement, iron and steel, electronics manufacturing, and municipal solid waste landfills.  

The natural gas distribution segment would be permanently eliminated for Subpart W, which covers petroleum and natural gas systems. Reporting requirements for nine other segments, including onshore and offshore production, natural gas processing, transmission, storage, and Liquefied Natural Gas facilities, would be suspended until reporting year 2034. 

To allow time for final rulemaking, EPA has also proposed extending the final reporting deadline for 2024 data from March 31, 2026, to June 10, 2026. If finalized, these changes mean that facilities would not be required to submit reports for 2025 data. 

Economic Impacts 

EPA estimates the proposed changes will save $303 million annually from 2025 through 2033. Over ten years, the total savings are expected to range from $2 billion using a 7 percent discount rate to $2.4 billion using a 3 percent discount rate. Most of these savings would come from the petroleum and natural gas sectors, which account for $256 million annually, including $3 million from the natural gas distribution segment. Other industries are projected to see an additional $47 million in annual savings. 

Affected Source Categories 

The 46 source categories proposed for permanent removal include the following: 

• Electricity generation 

• Petroleum refineries 

• Cement, iron and steel, aluminum, glass, lead, zinc, lime, and ammonia production 

• Electronics manufacturing, fluorinated gas production, hydrogen production, nitric acid production, pulp and paper manufacturing, and more 

• Suppliers of coal-based liquid fuels, petroleum products, industrial GHGs, natural gas, and CO₂ 

• Municipal solid waste landfills, industrial waste landfills, manure management, and industrial wastewater treatment 

• CO₂ injection and sequestration facilities, including enhanced oil recovery sites 

See EPA’s fact sheet for the full list of categories. 

Next Steps for Your Facility 

1. Continue Preparing 2025 Data: Until the final rule is published, facilities should proceed with preparing and submitting 2025 GHG data as usual. 

2. Monitor EPA Announcements: Stay informed about the finalization of the proposed rule. Details will be published in the Federal Register and on the EPA's website. 

3. Assess Impact on Reporting and Data Collection Requirements: Evaluate how the proposed changes may affect your facility's reporting obligations and the required collection of data for 2025. 

4. Engage in Public Comment Period: Once the public comment period opens, consider participating to provide feedback on the proposed changes. 

If you have questions about how this proposal may affect your operations, reach out to Trihydro’s Air Quality Compliance Specialists for guidance and support.