Why It Matters
A policy choice awaits lawmakers as the Environmental Protection Agency (EPA) reconsiders the program's future, according to a new report from the Congressional Research Service, "The U.S. Greenhouse Gas Reporting Program: Overview and Considerations for Congress." The program was created in 2009 after Congress directed EPA to establish mandatory economy-wide greenhouse-gas reporting, using authority under Clean Air Act Section 114. EPA says the program’s data represent 85 Percent to 90 Percent of annual U.S. greenhouse-gas emissions, giving the reporting system a role in how policymakers describe and regulate emissions. The tension is between reducing compliance costs for reporting entities and preserving a federal dataset used for standards, incentives, inventories, enforcement, and public access.
EPA has proposed removing most reporting obligations, while the report identifies congressional questions about whether existing statutory authority adequately supports the program as implemented. For Congress, the decision is whether to retain, modify, or address the relevant authorities through legislation and oversight of EPA’s reconsideration.
The Big Picture
The reporting framework reaches direct-emitting facilities, suppliers of fuels and industrial gases, and facilities that inject carbon dioxide underground for geologic sequestration or enhanced oil recovery. For most direct-emitting facilities and suppliers, reporting generally applies at 25,000 metric tons of carbon-dioxide equivalent per year, although some source categories have no threshold and carbon-dioxide injection facilities report regardless of the amount injected. Covered entities began submitting data in 2011, and approximately 8,000 facilities, suppliers, and injection facilities reported under the program in 2023. Those submissions use source-specific regulatory methodologies, verification procedures, and recordkeeping requirements to report annual quantities for gases including carbon dioxide, methane, nitrous oxide, hydrofluorocarbons, sulfur hexafluoride, perfluorinated compounds, and other fluorinated gases.
The resulting records include annual emissions estimates, facility-level industry and location information, and supplier-level quantities of fuels and industrial gases, with public disclosure generally limited by confidential-business-information protections. In 2023, 7,544 direct-emitting facilities reported 2.58 billion metric tons of carbon-dioxide equivalent, while 995 suppliers and 81 carbon-dioxide injection facilities also submitted information.
In March 2025, EPA announced that it would reconsider the GHGRP, and in September 2025, it issued a proposed rule to permanently remove reporting obligations for 46 of the program’s 47 source categories. For the petroleum and natural-gas supply chain, the proposal would permanently remove the natural-gas-distribution segment and suspend reporting for nine other segments until reporting year 2034. EPA estimated approximately $303 million in annualized savings across all source categories, including approximately $256 million associated with the petroleum and natural-gas provisions. The agency’s 2025 proposed rule asserted that Section 114 does not authorize continued economy-wide data collection and that the data are not needed to carry out the Clean Air Act.
The Bottom Line
The next policy question is not simply whether reporting continues, but which uses of standardized emissions information Congress wants to preserve in law. Existing congressional proposals show several possible directions, including adding cryptocurrency mining as a source category, creating voluntary scope 3 guidance, and narrowing methane reporting for certain smaller facilities. Another proposal would require covered domestic industries to report information for carbon-intensity baselines supporting a U.S. carbon border charge. The data also support implementation of the methane Waste Emissions Charge, hydrofluorocarbon phasedown requirements, and tax credits tied to carbon sequestration, clean electricity, and clean hydrogen.
Congress can signal support or opposition through resolutions and can examine EPA’s implementation through oversight, while stakeholder comments have reflected different views about the program’s benefits and costs.
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