Are You Subject to EPA’s Greenhouse Gas Reporting Program (GHGRP)? We Can Help!

The Environmental Protection Agency (EPA) regulates the emission of greenhouse gases (GHG) that trap heat in the atmosphere via 40 CFR Part 98 and requires annual reporting through EPA’s electronic GHG Reporting Tool (e-GGRT) by March 31 each year with information from the previous calendar year.

Who is required to report GHG emissions?

Applicability is based on specific industry sources emitting carbon dioxide equivalents (expressed as CO2e) and/or, for some general industry source categories, facility-wide CO2e emissions.  The GHG Reporting Program (GHGRP) applies to listed facilities that emit GHGs, certain suppliers of fossil fuels, industrial GHG emissions sources, products containing GHGs, and facilities that inject CO2 underground.  Reporting is at the facility level, except for natural gas distribution companies that report at the state level and certain suppliers that may report at the corporate level (e.g., importers and exporters of industrial GHGs).

Primary Greenhouse Gases:

  • Carbon dioxide
  • Methane
  • Nitrous oxide
  • Fluorinate gases

Facilities and suppliers subject to the rule must comply with the General Provisions in 40 CFR Part 98, Subpart A and the provisions of all other applicable subparts of 40 CFR Part 98 as it relates to their specific industry.  In addition, facilities may be subject only to direct emitter subparts, only to supplier subparts, or to both.

How do I determine if my facility is required to comply with the GHGRP?

For most manufacturing operations, the applicable reporting category would be stationary combustion sources burning natural gas, #2 fuel oil, wood products, coal, etc.  If the combined total CO2e are >25,000 metric tons per year, then reporting could be required.  Each facility can use the following flow chart adapted from EPA’s Fact Sheet, as well as tables in the EPA Fact Sheet that explain eligibility and applicability criteria, to determine their reporting requirements.

Where can I calculate GHG emissions?

If your facility is in a categorical source (from Tables 1-3 in the EPA’s Fact Sheet) or has stationary combustion sources, calculate emissions using EPA’s Applicability Tool.  Obtain the quantities and types of fuel burned annually to properly calculate CO2e.

In Table 5 of EPA’s Fact Sheet, there are examples of how applicability criteria apply to different types of facilities.  Note that all stationary combustion sources must be aggregated at the facility to calculate properly.  For reference, in general, your facility will need to burn at least 2,000,000 gallons of diesel fuel annually to be subject to the GHGRP.  However, it is highly recommended that each facility calculates their fuel usage using the Applicability Tool.  To do so, follow these steps:

  1. Select “Run the Applicability Tool.”
  2. Accept the disclaimer.
  3. Select Reporting Year 2022 and ‘Continue’.
  4. Select “Stationary Fuel Combustion Sources” and “Continue.”
  5. Select “Unsure” and “Go to Calculator.”
  6. Select all of your “Fuel Types” and “Continue.”
  7. Add the “Annual Amount Combusted” in gallons and “Calculate”.  See example below.

Where can I find more information?

Companies who think they may be subject to these requirements or those that have more interest can review the following additional resources:

Overview of GHGs

Resources by Subpart for GHG Reporting

GHG Reporting Program

If you are uncertain whether these requirements apply to your company, or have determined that your firm is required to comply with the GHGRP and need assistance with reporting, please contact Amy Spann at or Brooke Sinclair at

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