Client Alert: EPA Proposes Major Rollback of Greenhouse Gas Reporting Requirements

/ KERAMIDA Inc./

The U.S. Environmental Protection Agency (EPA) issued a proposed rule on September 16, 2025, that would significantly scale back the Greenhouse Gas Reporting Program (GHGRP) under 40 CFR Part 98. Under the proposal, reporting obligations for most industries would be eliminated, while reporting for the petroleum and natural gas sector (subpart W) would be suspended until 2034. Notably, the rule would also remove reporting requirements for the Natural Gas Distribution segment entirely. If finalized, these changes would halt greenhouse gas reporting for nearly all sectors for the next decade, with limited requirements returning in 2034.

This proposal represents a major shift in federal greenhouse gas oversight, with wide-ranging implications for companies that have been reporting under the GHGRP for over a decade.

  • The suspension of requirements until 2034 introduces regulatory uncertainty, making it difficult for companies to plan long-term compliance and investment strategies.

  • The loss of standardized federal reporting also creates challenges for sustainability reporting, as businesses may need to rely on internal data systems to maintain credibility in voluntary disclosures.

  • Finally, reduced transparency may heighten investor and customer concerns, as stakeholders increasingly expect consistent and reliable greenhouse gas data when evaluating corporate climate risk.

Importantly, this proposed rule only applies to reporting under 40 CFR 98. Many organizations will still face other requirements to quantify and disclose GHG emissions, such as California Senate Bill 253, as well as customer-driven reporting obligations. Even if a company is no longer covered by GHGRP and not directly subject to SB 253 or current customer requirements, organizations will still need to closely monitor and manage their GHG data to stay prepared for new and evolving regulations, including SB 253–style proposals in New York, New Jersey, Illinois, and Washington.

KERAMIDA’s regulatory team of compliance experts, engineers, and attorneys is available to help you understand how this proposed rule may impact your business and to prepare for potential changes ahead. Please contact us with any questions or to discuss your compliance strategy.