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ARTICLE · 11 DECEMBER 2025

U.S. EPA Proposes Major Rollback Of Federal Climate Disclosure Requirements

Jones Day
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On September 16, 2025, the U.S. Environmental Protection Agency ("EPA") proposed a sweeping rollback of the Greenhouse Gas Reporting Program ("GHGRP") under 40 C.F.R. Part 98.

United StatesEnvironment
Daniella Einik
Daniella Einik
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Jane Borthwick Story
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Tyler Larsen
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On September 16, 2025, the U.S. Environmental Protection Agency ("EPA") proposed a sweeping rollback of the Greenhouse Gas Reporting Program ("GHGRP") under 40 C.F.R. Part 98. Comments were due November 3, 2025. If finalized, reporting under the GHGRP for all non-subpart W sectors and the natural gas distribution industry will end. Reporting will be paused until 2034 for the other subpart W industries, which include offshore and onshore petroleum and natural gas production, onshore natural gas processing and transmission compression, underground natural gas storage, and liquefied natural gas storage, among others.

The GHGRP stems from the Fiscal Year (FY) 2008 Consolidated Appropriations Act, in which Congress provided $3,500,000 to develop and publish a rule "to require mandatory reporting of greenhouse gas emissions above appropriate thresholds in all sectors of the economy." In 2009, EPA issued the "Mandatory Reporting of Greenhouse Gas" rule to fulfill the

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