Summary
Cut through the green tape
We don't push agendas. At Net Zero Compare, we cut through the hype and fear to deliver the straightforward facts you need for making informed decisions on green products and services. Whether motivated by compliance, customer demands, or a real passion for the environment, you’re welcome here. We provide reliable information—why you seek it is not our concern.
Details
- The United States of America
Facilities that emit 25,000 metric tons or more of carbon dioxide (CO₂)-equivalent per year.
Deep dive
Background
The Greenhouse Gas Reporting Program (GHGRP) is an initiative by the Environmental Protection Agency (EPA) in the United States aimed at tracking and managing greenhouse gas (GHG) emissions from major sources across the country. Established in 2009 under the Clean Air Act and last amended in 2024, the GHGRP builds upon earlier EPA programs such as the Acid Rain Program (1990), which targeted reductions in sulphur dioxide (SO2) and nitrogen oxides (NOX) in the power sector, and the Climate Leaders Program (2002), which sought to assist companies in the development and implementation of Greenhouse Gas (GHG) reduction strategies. Unlike its predecessors, the GHGRP mandates large emitters to report annually on several other types of greenhouse gases, ensuring greater transparency and accountability in the fight against climate change. The program serves as a foundation for policymaking and regulation by providing accurate data on national emissions trends. The EPA publishes all GHG emissions data not eligible for confidential treatment on a publicly accessible data tool.
Reporting Requirements
The GHGRP mandates affected companies to monitor, measure, and report their greenhouse gas emissions using EPA-approved methodologies. All reports are made through the EPA’s Electronic Greenhouse Gas Reporting Tool (e-GGRT). The program provides specific methods for calculating emissions, including direct measurement using continuous emissions monitoring systems (CEMS) and engineering calculations using fuel consumption. The choice of calculation method may depend on existing environmental monitoring systems and other relevant factors. The emission calculation method used by a reporter can change from year to year (or within the same year, if required), provided they comply with the requirements for the selected method. The GHGRP mandates reporting at the facility level and specifies different reporting requirements for direct GHG emitters and suppliers (for whom emissions do not occur at their facility but are spread out across the country), and for importers and exporters of specific GHGs. Each facility must submit its annual GHG emissions report for a given calendar year by March 31 of the following year (e.g. the report for the year 2024 is due by March 31, 2025). All reports submitted to the EPA undergo internal verification.
Penalties for noncompliance
Companies subject to the Greenhouse Gas Reporting Program (GHGRP) that fail to submit accurate and timely reports, or fail to submit their annual reports altogether, may face enforcement actions under the 1991 Clean Air Act Stationary Source Civil Penalty Policy. The EPA enforces GHGRP regulations through various means, including administrative compliance orders, administrative penalty orders, civil lawsuits, or criminal prosecutions. In March 2022, the EPA issued 14 Notices of Violation (NOV) to companies for failing to meet their hydrofluorocarbon (HFC) reporting obligations under the GHGRP. These violations were primarily committed by HFC importers that submitted their reports late, thereby undermining the integrity of the reporting program. In a subsequent round of enforcement announced in March 2023, the EPA imposed significant financial penalties on several companies. IGas Companies was fined $382,473, Harp USA, Inc. received a penalty of $275,000, and Artsen Chemical America, LLC was fined $247,601.
Enforcement Outlook
Challenges
The Greenhouse Gas Reporting Program (GHGRP) faces opposition from some industry groups and Republican-led states, who argue that certain reporting mandates exceed the EPA’s statutory authority. This aligns with broader opposition to federal environmental regulations, particularly in Republican-led states. Future litigation could influence the scope and enforcement of GHGRP requirements, potentially affecting the EPA’s ability to mandate comprehensive greenhouse gas emissions reporting.
Current Status
The GHGRP is in force and remains a key component of the EPA’s climate strategy, with recent enhancements aimed at improving data accuracy and transparency. In 2024, the EPA finalized updates to global warming potentials (GWPs) and expanded the program to include new source categories, such as geologic sequestration and ceramics manufacturing. In 2024, the EPA also issued a new Strategic Civil-Criminal Enforcement Policy aimed at promoting "optimal enforcement" by improving consistency and fairness through coordinated efforts. However, in March 2025, EPA Administrator Lee Zeldin announced the EPA is reconsidering the GHGRP, citing concerns about regulatory burdens on businesses. This move is part of a broader scaling down of environmental regulations under the Trump administration. The reconsideration includes evaluating the program's scope and potential modifications to reporting requirements.
Resources
