Who must report under EPA GHGRP?

Facilities that emit 25,000 metric tons CO2e or more per year must report. This covers approximately 8,000 facilities across sectors including power plants, refineries, chemical manufacturers, metals producers, pulp and paper mills, and others. Fuel and industrial gas suppliers above certain thresholds must also report.

How does EPA GHGRP differ from corporate GHG reporting?

EPA GHGRP is facility-level reporting of direct emissions using EPA-specified methodologies. Corporate GHG reporting (GHG Protocol) covers the entire organization across all scopes. Companies may use GHGRP data as inputs to their corporate Scope 1 inventory, but GHGRP doesn't cover Scope 2 or 3.

What happens if my facility exceeds the 25,000 tCO2e threshold?

You must report for the first year your facility meets the threshold, by March 31 of the following year; reports for 2025 are due October 30, 2026. Reporting continues even if emissions later drop, until they stay below 25,000 tCO2e for five consecutive years or below 15,000 tCO2e for three, after which you can notify EPA and stop.

EPA Greenhouse Gas Reporting Program (GHGRP)

Status, September 2026: In September 2025 EPA proposed ending reporting for most source categories and suspending oil and gas (subpart W) reporting until reporting year 2034. In a February 2026 final rule it moved the reporting-year 2025 deadline to October 30, 2026; the rest of the proposal is still pending. Source: EPA.

What Is the EPA GHGRP?

The EPA Greenhouse Gas Reporting Program (40 CFR Part 98), established in 2009, requires large direct emitters of greenhouse gases in the United States to report their emissions annually to the EPA. About 8,000 facilities report each year, and EPA says data from direct emitters and fuel and industrial gas suppliers together cover 85-90% of US GHG emissions.

GHGRP is a facility-level reporting program distinct from corporate sustainability reporting. It provides the US government with comprehensive, standardized emissions data for policy-making, public transparency, and environmental monitoring.

Who It Applies To

Direct emitters (most subparts from C through ZZ):

Facilities emitting 25,000 metric tons CO2e or more per year
Covers more than 40 source categories including: power plants, petroleum refineries, chemical manufacturing, metals production, cement, glass, pulp and paper, waste management

Suppliers (Subparts LL-QQ):

Fuel and industrial gas suppliers above specified thresholds
Suppliers of petroleum products, natural gas, industrial gases, and CO2

Key Requirements

Annual reporting: Submit facility-level GHG emissions data to EPA by March 31 each year (for the prior calendar year); reports for 2025 are due October 30, 2026 instead
Source-specific methodologies: Use EPA-prescribed calculation methods for each source category (Subparts C through ZZ)
Covered greenhouse gases: Report CO2, CH4, N2O, HFCs, PFCs, SF6, and NF3 where applicable
Monitoring and measurement: Use specified monitoring equipment, emission factors, and calculation methodologies
Verification: EPA conducts data quality checks and may request additional documentation
Public reporting: Most GHGRP data is publicly available through EPA's FLIGHT tool

Covered Greenhouse Gases

Carbon dioxide (CO2)
Methane (CH4)
Nitrous oxide (N2O)
Hydrofluorocarbons (HFCs)
Perfluorocarbons (PFCs)
Sulfur hexafluoride (SF6)
Nitrogen trifluoride (NF3)

All reported in metric tons of CO2 equivalent using EPA-specified Global Warming Potentials.

Timeline

2009: EPA GHGRP rule finalized
2010: First year of data collection for most source categories
Annual: Reports due by March 31 for prior calendar year
September 2025: EPA proposes ending reporting for 46 source categories and suspending most oil and gas (subpart W) reporting until reporting year 2034
February 2026: EPA moves the reporting-year 2025 deadline to October 30, 2026; the rest of the proposal is still pending

Compliance Steps

Determine applicability: Calculate whether your facility exceeds the 25,000 tCO2e threshold
Identify source categories: Determine which GHGRP subparts apply to your operations
Implement monitoring: Install required monitoring equipment and establish data collection procedures
Calculate emissions: Apply EPA-specified methodologies for each source category
Submit via e-GGRT: Report through EPA's electronic Greenhouse Gas Reporting Tool
Maintain records: Keep all supporting documentation for at least 3 years
Respond to EPA inquiries: Be prepared to provide additional documentation if EPA requests verification

Penalties

Civil penalties: Up to $124,426 per day per violation under the Clean Air Act, the inflation-adjusted maximum in effect since January 2025 (adjusted periodically)
Criminal penalties: For knowingly violating reporting requirements, falsifying data, or tampering with monitoring equipment
EPA enforcement actions: Compliance orders, consent decrees, and injunctive relief

How Council Fire Can Help

Council Fire helps facilities navigate EPA GHGRP compliance — from applicability assessment and monitoring setup through emissions calculation and reporting. We also integrate GHGRP data with broader corporate GHG inventories. Contact us for EPA GHGRP support.