Summary
Details
- The United States of America (USA)
Any facility or supplier that meets Part 98 applicability criteria must report.
Facilities and suppliers below thresholds or outside listed source categories are not required to report, but must document applicability determinations because incorrect non-reporting can trigger enforcement.
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What’s Required
GHGRP is a mandatory reporting regulation, not a voluntary registry. Compliance is defined by applicability rules in Part 98 and subpart-specific calculation methods.
1) Determine applicability and reporting status
Entities must assess whether they fall under:
Facility-based source categories (e.g., power generation, refineries, cement, chemicals)
Supplier categories (fuel suppliers, industrial gas suppliers)
CO₂ injection site reporting
Applicability is determined through Part 98 definitions and thresholds, commonly including a 25,000 metric ton CO₂e reporting threshold for many categories, though subpart rules vary.
2) Develop monitoring and calculation systems per subpart
Part 98 includes general provisions and many subparts prescribing methods, such as:
Continuous emissions monitoring system (CEMS) data is used where applicable.
Fuel-based calculations using higher heating values and emission factors.
Mass balance or process-based calculation methods for industrial processes.
Best Available Monitoring Methods (BAMM) in limited cases, as allowed by rule conditions.
Compliance requires matching the correct calculation method to each emissions source within the facility boundary and maintaining documentation of method selection.
3) Annual reporting and electronic submission
Reporters must submit annual reports to EPA via the designated electronic system, covering facility identifiers, emissions totals by gas, and subpart-specific data elements. Late filing and incomplete reports are enforceable violations.
4) Recordkeeping and retention
Facilities must retain records supporting reported data, including monitoring inputs, calibration records, emissions factor sources, and calculation workpapers. Record retention is a compliance obligation separate from reporting because EPA can request records during audits or enforcement actions.
5) Verification posture and internal controls
GHGRP is not structured like EU ETS verification, but audit and enforcement risk effectively requires “audit-grade” internal controls. Many companies use GHGRP as the authoritative source for sustainability reporting, climate targets, and investor disclosures. This increases the governance importance of reconciliation between GHGRP totals and corporate inventories (Scope 1 calculations).
Important Deadlines
Annual reporting cadence: Reports are submitted annually on EPA’s schedule under Part 98 (program operates continuously with annual submissions).
Ongoing updates: EPA periodically updates subparts and guidance; reporters must monitor applicability changes and method updates.
Current Status
In force and actively used as the federal facility-level GHG dataset. EPA continues to maintain program guidance and updates.
Penalties for Non-Compliance
Civil penalties under the Clean Air Act for failure to report, late reporting, or false reporting.
Administrative orders requiring corrective submissions.
Increased scrutiny in related EPA programs where GHGRP data informs permitting or compliance priorities.
False statements can also create broader federal legal exposure beyond environmental penalties.
Examples of Known Violations
Common GHGRP failure modes include:
Failure to report when thresholds were exceeded.
Incorrect facility boundary definition leading to underreporting.
Use of incorrect subpart calculation methodology.
Data quality issues due to uncalibrated meters or missing inputs.
Inability to reproduce calculations due to weak recordkeeping.
These are often discovered during internal audits, acquisitions, or EPA inquiries.
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