EPA’s Proposal to Reconsider Greenhouse Gas Reporting — What’s the Impact?

On September 16, 2025, the agency published a rulemaking in the Federal Register that would roll back much of the Greenhouse Gas Reporting Program (GHGRP) established in 2009. The proposal stems from Executive Order 14192 and amendments to Clean Air Act Section 136, which now restrict EPA’s authority to collect GHG data outside the Waste Emissions Charge (WEC) program. Then, on February 27, 2026, EPA extended the GHG Reporting deadline to October as it continues review of the September proposed rollback. 

If finalized, this rule would eliminate reporting for nearly all industrial source categories and suspend Subpart W reporting for the petroleum and natural gas sector until 2034. For those of us who rely on consistent, high‑quality emissions data to understand environmental performance, this proposal raises both practical and philosophical questions about the future of GHG management in the United States.

Which Industries Would Be Affected?

EPA’s proposal would remove reporting requirements for every source category under 40 CFR Part 98, including:

• Electric power generation

• Electronics manufacturing

• HFC‑22 and HFC‑23 production

• Landfills and wastewater treatment facilities

• Petrochemical production

• And dozens more sectors 

Under this rule, these categories would no longer report GHG emissions after the 2024 reporting year. Subpart W reporters—oil and gas production, processing, transmission, and storage—would see a 10‑year suspension until 2034. For many facilities, this would be the first time in 15 years that GHG reporting is not an annual expectation.

Timing and Regulatory Uncertainty

EPA published the proposed rule in September 2025 and subsequently extended the reporting deadline for 2025 data to October 2026. This creates a unique regulatory window: If the rule is finalized before October 2026, facilities will not be required to report GHG emissions for 2025 or beyond.

This timing matters. Many companies are already deep into data collection for 2025, and the uncertainty around the rule’s finalization may influence whether they continue monitoring or pause efforts until clarity emerges. 

What Is the Impact?

EPA estimates substantial cost savings if facilities stop monitoring and reporting GHG emissions:

• $303 million per year in reduced reporting costs

• $256 million per year in savings for the petroleum and natural gas sector

• $47 million per year for all other industries

These savings assume that facilities will discontinue all GHG monitoring, data collection, and internal assessments—an assumption that may not reflect the reality of corporate sustainability commitments, ESG expectations, or state‑level requirements.

From a reporting burden perspective, EPA is correct: this rule would provide immediate relief in some capacity. But from a data‑integrity and climate‑planning perspective, the consequences are significant.

The GHGRP has been the backbone of:

• National GHG inventories

• Corporate sustainability benchmarking

• Academic and policy research

• State and regional climate programs

A decade‑long gap in publicly available emissions data would reshape how environmental professionals, policymakers, and communities understand industrial emissions trends.

Why This Matters Within Compliance 

While these decisions are up in the air, there is always the possibility that a court stays the delay and reinstates the existing GHG reporting deadline. There is also the possibility that future administrations will reinstate GHG reporting obligations and there could be an expectation for past data reviews. If anything, companies tend to exist on the risk-averse side when it comes to compliance decisions. It is very likely that companies will choose to continue collecting GHG data to minimize the risk associated with potentially missing a reinstated reporting deadline. When it comes to compliance, it is usually better to be safe rather than sorry. 

Why This Matters Beyond Compliance

Even if federal reporting pauses, it is likely that companies will continue tracking GHG emissions. Corporate climate goals, international disclosure frameworks, investor expectations, and state‑level regulations are not going away. And for many facilities, GHG data is already intertwined with air permitting, energy management, and operational planning.

In other words: the need for accurate emissions data doesn’t disappear just because a federal reporting mandate does. 

A Practical Path Forward

At Toolkit, we anticipate that companies will maintain their GHG tracking practices—both to stay aligned with their own sustainability commitments and to remain prepared for future regulatory shifts. The landscape of environmental regulation is cyclical, and history shows that reporting requirements often return in new forms under new administrations.

If your facility needs a streamlined way to track emissions without the administrative headache, Toolkit’s Emissions Tool can help. It centralizes your data, adapts to shifting regulatory expectations, and keeps your team focused on meaningful environmental performance rather than spreadsheet gymnastics. It’s built to reduce risk, improve clarity, and make emissions management something your team can feel confident about.