On GHG, U.S. EPA Rolls Back Reporting but Not Paperwork 

The Trump administration has promised industry less paperwork and fewer regulatory hurdles, a promise that has shaped the current U.S. Environmental Protection Agency (EPA) and underlies every chemical-related Congressional debate.

But for companies seeking relief from federal greenhouse gas reporting, the deregulatory fervor can sometimes create more paperwork than before, not less. Companies may have to recreate or replace the federal dataset they use to navigate tax credits, export markets, and state requirements.

Apprehension over creating a new dataset and the hurdles that could pose runs through industry comments on an EPA proposal to dismantle much of its Greenhouse Gas Reporting Program (GHGRP). The agency has now given companies until March 10, 2027, to submit their 2025 reports, extending an October 30, 2026, deadline while it considers a wide rollback of reporting requirements. The October 14, 2026, interim final rule only changed the reporting deadline. It is unclear how long the reporting requirements themselves will remain in place.

In its November 3, 2025, comments, a coalition including the U.S. Chamber of Commerce, American Chemistry Council, American Petroleum Institute, and American Gas Association expressed unease about the breadth of the proposed rollback of the GHGRP.

“While we recognize the importance of reducing unnecessary regulatory burdens,” they wrote, “we believe that maintaining the GHGRP - with targeted improvements as referenced below - strikes a prudent balance.”

More Time, But an Unresolved Decision

The EPA cited time constraints as the reason for the delay, saying it needs time to consider its planned reporting rollback and prepare its electronic Greenhouse Gas Reporting Tool (e-GGRT). The agency noted in the Federal Register that it cannot prepare the electronic reporting tool in time for the October 30, 2026.

The rollback itself, proposed in September 2025, would remove reporting obligations for most source categories, including ammonia, nitric acid, hydrogen, petrochemical, and fluorinated gas production. Natural gas distribution reporting would also end, while requirements for other petroleum and natural gas segments would be suspended until reporting year 2034. If finalized as proposed, industries would not submit 2025 reports.

The EPA estimated annual savings of $303 million, but the agency's rationale reaches beyond cost. The EPA said Clean Air Act Section 114(a)(1) should require “a closer nexus between continuous reporting obligations and an underlying statutory purpose,” which would represent a “change from prior GHGRP rulemakings.” Under this interpretation, much of the existing program exceeds the agency's information collection authority.

Industry Wants Relief and Reliable Data

Some of the companies subject to those requirements urged the agency to preserve the program. The need for standardization of data, and the fear of a chaotic patchwork of state laws, appeared in many of the proposal's public comments.

Asked by 3E about the delay and the program's future, Aaron Padilla, vice president of corporate policy at the American Petroleum Institute, emphasized transparency alongside reducing administrative burdens.

“Our industry has a long record of working constructively with EPA to advance emissions data transparency and remains committed to improving data quality without unnecessary red tape,” Padilla said. “We will continue to work on policies and solutions for GHG reporting to ensure America leads the world in innovation and energy production.”

ExxonMobil’s November 2025 submission was more explicit. It asked the EPA to maintain mandatory reporting “as a bulwark against a proliferation of new burdens from states and localities.”

The company also described a practical limit to deregulation: Businesses already use GHGRP methods for other purposes.

“Many companies, including ExxonMobil, have embedded GHGRP protocols and calculations into data collection and reporting systems that will continue for other purposes,” it wrote. Eliminating the federal requirement, it argued, could therefore yield limited savings while increasing complexity.

Tax credits make that dependence particularly consequential. ExxonMobil warned that dedicated geological carbon storage projects use GHGRP Subpart RR reporting to substantiate Section 45Q credits, while certain hydrogen emissions calculations depend on Subpart W data for Section 45V. It asked the EPA to retain relevant reporting pathways until acceptable alternatives were available.

The Business Roundtable likewise urged coordination with the U.S. Department of the Treasury before changing requirements linked to credits. “Timing is of the essence to ensure the left hand is aware of the right hand's actions,” it wrote.

The EPA acknowledged those dependencies in its proposal but said the information “could be provided in different, more efficient, ways.” It also anticipated that other programs would need administrative revisions. For chemical companies investing in carbon capture or hydrogen, the issue is whether replacement verification arrangements would be ready when federal reporting requirements change.

What Would Replace the Federal System?

State air agencies raised a parallel concern: Losing federal reporting could shift work onto governments and businesses.

The National Association of Clean Air Agencies warned in November 2025 that states would need to develop calculation methods, verification procedures, and electronic systems.

“Businesses required to report under different state programs may also need to make duplicative investments to develop internal reporting infrastructure for different programs in different states,” the association wrote.

Its submission identified specific dependencies. Iowa uses federal facility data in its greenhouse gas inventory, including emissions from ammonia and urea production. Minnesota uses GHGRP information for sectors including hydrogen production and electronics manufacturing. Those examples show why companies should examine how state programs use their federal submissions when assessing the consequences of a rollback.

Environmental Defense Fund senior attorney Edwin LaMair told 3E that the delay itself forces data users to consider replacements.

“Stakeholders who want that data will have to develop alternative approaches or find other sources, instead of having access to the same standardized dataset,” he said.

LaMair also disputed the EPA's explanation about its reporting tool, saying the agency normally makes it available by March 31. His objection concerns which reporting years a future rollback would reach.

“Changes to the reporting program should apply prospectively,” he said. “2025 has already passed, and companies should have gathered the necessary information to report their 2025 emissions in early 2026.”

The group intends to continue opposing efforts to delay and undermine the program, LaMair added, without specifying whether it would bring a new challenge to this extension.

The comments continued into 2026. In a February 27, 2026, filing, the Environmental Defense Fund and four other environmental groups linked GHGRP data to congressional direction for a study comparing the emissions intensity of U.S. and foreign goods affected by European carbon border rules.

“Accurate, verifiable data on American industrial emissions is essential to demonstrating whether U.S. goods are produced with lower carbon intensities than competitors,” they wrote.

The industry coalition offered possible compromises, including voluntary certification under EPA standards if mandatory reporting were rescinded. It also sought an orderly transition, stating: “Providing a one-year or longer transition period for any affected industry segments would allow companies to adjust their compliance systems and develop alternative data sources where necessary.”

Companies should watch which reporting categories the EPA retains, whether it allows verified voluntary submissions, and how any changes interact with tax and state requirements.

For now, March 10, 2027, is the filing deadline. Comments on the extension are due November 30, 2026, and should reference docket EPA-HQ-OAR-2025-0186, through the Federal eRulemaking portal, email, or mail to the following address:

U.S. Environmental Protection Agency
EPA Docket Center
Docket ID No. EPA-HQ-OAR-2025-0186
Mail Code 28221T
1200 Pennsylvania Avenue NW
Washington, DC 20460

The agency identifies the online portal as its preferred method.