What is the EPA Greenhouse Gas Reporting Program (GHGRP)?
The GHGRP is a U.S. federal reporting programme under 40 CFR Part 98. It applies to owners and operators of U.S. facilities that meet a source-category or emissions test, suppliers listed in Table A-5, and covered CO2 injection sites. The United States reporting guide places this facility- and supplier-level rule alongside other U.S. requirements.
Facilities report direct emissions from covered sources. Suppliers report the CO2e that their covered products would release if used. The programme does not collect purchased-electricity emissions, so a GHGRP filing is not a complete corporate GHG inventory.
Why does the EPA GHGRP matter to you?
You cannot decide applicability from company revenue, headcount, or one group-wide emissions number. Section 98.2 tests the operations at each U.S. facility and the products supplied. Table A-3 facilities report the listed sources without the general 25,000 metric tonne CO2e test. Table A-4 facilities generally combine covered emissions against that threshold.
A facility covered only through general stationary fuel combustion must meet both tests in section 98.2(a)(3): its combustion units must have at least 30 million British thermal units per hour (mmBtu/hour) of combined maximum rated heat input, and those units must emit at least 25,000 metric tonnes CO2e in the calendar year. Once reporting starts, section 98.2(i) normally keeps it going until a stated discontinuation test and notification are completed.
How does the EPA GHGRP work?
First map every Part 98 source category at the facility. Then use the calculation, monitoring, missing-data, and quality-control rules in each applicable subpart. Submit the prior calendar year's report through EPA's electronic Greenhouse Gas Reporting Tool, e-GGRT. The normal deadline is 31 March. Section 98.3(b)(6) moves the Reporting Year 2025 deadline to 30 October 2026.
Section 98.3(c) requires the facility or supplier identity, reporting period, submission date, emissions by gas and source category where applicable, method changes, missing-data use, North American Industry Classification System (NAICS) codes, U.S. parent information, and a designated representative's certification. Section 98.3(g) generally requires at least three years of records, including calculation inputs, annual reports, missing-data records, a written monitoring plan, and instrument checks.
What mistakes should you avoid?
- Applying the 25,000 metric tonne threshold to every source category without checking Tables A-3, A-4, and A-5.
- Combining several worldwide sites into one corporate total instead of testing each U.S. facility and supplier under section 98.2.
- Adding purchased electricity to a facility filing or assuming a corporate inventory method automatically satisfies the applicable Part 98 subpart.
- Treating EPA's September 2025 proposal to remove many reporting obligations as final, or using 31 March for the Reporting Year 2025 deadline.
Does the 25,000 metric tonne threshold apply to every facility?
No. Some Table A-3 source categories report regardless of total annual emissions. Table A-4 facilities and facilities covered only for stationary combustion use specified threshold calculations. Suppliers and CO2 injection sites have separate tests.
Is an EPA GHGRP report the same as a corporate GHG inventory?
No. A facility report covers direct emissions from sources required by Part 98. It excludes purchased-electricity Scope 2 emissions and may omit facilities or activities elsewhere in the corporate group. Supplier reports quantify potential downstream emissions from covered products rather than the supplier's complete footprint.
When can you stop EPA GHGRP reporting?
Section 98.2(i) permits discontinuation in defined cases. Two common tests are reported emissions below 25,000 metric tonnes CO2e for five consecutive years or below 15,000 metric tonnes for three consecutive years, followed by notice to EPA. Temporary shutdown does not by itself end the duty.