On September 12, 2025, U.S. EPA issued a proposed rule to eliminate GHG reporting requirements for all source categories under the Greenhouse Gas Reporting Program (GHGRP), 40 CFR Part 98, except for Petroleum and Natural Gas Systems (Subpart W of Part 98). The Proposed Rule does suspend Subpart W reporting requirements until January 1, 2023, and removes reporting requirements for the Natural Gas Distribution industry segment of Subpart W, consistent with amendments to Clean Air Act (CAA) section 136(g) in July 2025. Following U.S. EPA’s evaluation of the GHGRP, the Agency determined that there is no requirement in the CAA to collect GHG emissions information for industry sectors other than the Subpart W segments (excepting distribution) which are subject to the waste emissions charge under CAA section 136 beginning in 2034.
The GHGRP applies to (i) certain industrial facilities that emit more than 25,000 MTCO2e/year, (ii) upstream suppliers of fossil fuels and industrial GHGs, and (iii) industries that capture and sequester CO2 as a means of reducing CO2 emissions. If finalized, the Proposed Rule would eliminate (or suspend until 2034, in the case of the Subpart W sectors subject to the waste emissions charge) burdensome reporting requirements for approximately 8,200 facilities across several industrial sectors, including but not limited to cement production, electric power generation, electronics manufacturing, ferroalloy production, and solid waste landfills, that are subject to the GHGRP. U.S. EPA noted in the Proposed Rule that it intends to address petitions for reconsideration of Subpart W in a separate action.
A pre-publication version of the Proposed Rule is available here. Once published in the Federal Register, interested parties will have 47 days to submit comments on the Proposed Rule.