Insight
Flight risk: the implications of a US emissions reporting rollback
*Please note that this report only includes an Excel data file if this is indicated in "What's included" below
Report summary
In September 2025, The US Environmental Protection Agency's (EPA) proposed elimination of its Greenhouse Gas Reporting Program (GHGRP). While touted as a US$2.4 billion cost saving, the reality is starkly different. This insight covers three critical impacts of losing the GHGRP: Transparency loss: 77% of US oil and gas production will lose federal reporting coverage, creating a patchwork of inconsistent state programs. Trade barriers: Without verifiable emissions data, imports from the US face challenges under EU methane regulations and CBAM potentially presenting further impacts in the future. Current alternatives contain a key paradox: low-carbon producers lose their competitive edge; high-emitters get a free pass hiding behind national averages. Trust deficit: Companies face heightened litigation risk, reduced access to climate-conscious capital and slower clean technology development, all stemming from the loss of standardised, verified emissions data.
Table of contents
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Executive Summary
- Three critical impacts :
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Background
- GHGRP: Pros and Cons
- Pros
- Cons
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What are the impacts?
- Transparency
- Trade
- Trust
- The bottom line – how will losing the GHGRP impact costs?
- What options are available for companies to replace the GHGRP?
- Conclusions:
Tables and charts
This report includes the following images and tables:
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Reporting options to replace the GHGRPUS states with mandatory facility-level emissions reportingReporting threshold, coverage, and GHGRP reliance of state-level facility emissions reporting programsUS LNG emissions intensity range vs average intensities for other LNG producing countriesEmissions intensities of US steel projects compared to the global average
What's included
This report contains:
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