EPA Moves 2025 GHG Report Deadline to March 10, 2027

If your plant runs boilers, process heaters, or other combustion equipment big enough to report greenhouse gases to EPA, someone on your team probably had October 30, 2026 on the calendar. That was the deadline for reporting year 2025 data under EPA's Greenhouse Gas Reporting Program, and EPA's reporting tool was not even ready for it.

On October 14, 2026, EPA published an interim final rule that moves the deadline to March 10, 2027. The rule took effect the day it published.

The same day, EPA also proposed more time for some companies facing a December 18, 2026 deadline under its trichloroethylene (TCE) rule. Both changes land on manufacturers, so we are covering them together.

This post is a plain-language summary, not legal advice. Read the rules and 40 CFR before you change course.

What changed for greenhouse gas reporting

The interim final rule, published at 91 FR 65112, revises one line of the Greenhouse Gas Reporting Rule. 40 CFR 98.3(b)(6) now reads: "The annual GHG report for reporting year 2025 must be submitted no later than March 10, 2027."

That is the second move for this deadline. Annual reports normally are due March 31. A February 27, 2026 final rule (91 FR 9712) moved the reporting year 2025 deadline from March 31, 2026 to October 30, 2026. This new rule moves it again, to March 10, 2027.

EPA says this action "only changes the reporting deadline for annual greenhouse gas reports for reporting year 2025 and makes no other changes to the rule."

Why EPA moved it again

EPA gives two main reasons.

First, it wants time to finish its reconsideration of the program. On September 16, 2025, EPA proposed a broad reconsideration of the Greenhouse Gas Reporting Program (90 FR 44591). Among other things, EPA proposed that no industries would need to submit annual reports for calendar year 2025, and EPA's program page describes it as a proposal to "permanently remove program obligations for 46 source categories." EPA received more than 50,000 comments and has not finalized it. The new deadline is meant to let EPA act on the proposal before reports come due.

Second, the reporting tool is not ready. Facilities report through EPA's electronic Greenhouse Gas Reporting Tool (e-GGRT), which EPA normally opens about six weeks before the deadline. EPA says it could not have e-GGRT ready for October 30, 2026.

EPA's stated goal is to avoid two bad outcomes: reporters rushing a report that may not be required, or reporters getting too little time if EPA keeps many of the existing obligations.

Who is covered

The Greenhouse Gas Reporting Program, at 40 CFR part 98, covers about 8,200 facilities, fuel and industrial gas suppliers, and CO2 injection sites each year. For most source categories, the threshold is emitting at least 25,000 metric tons of CO2 equivalent per year.

EPA's list of example sectors includes facilities with general stationary fuel combustion (boilers, process heaters, incinerators, turbines, and engines) in lumber and wood products, pulp and paper, chemical manufacturing, refining, rubber and plastics, steel, electroplating, and motor vehicle parts, along with cement, ceramics, electronics, and other source categories. EPA notes the list is not exhaustive.

Most small contractors and light manufacturers will not reach the threshold. If you have never reported under part 98, this rule does not create a new obligation for you.

Comment and hearing dates

• Comments on the interim final rule are due November 30, 2026, in docket EPA-HQ-OAR-2025-0186 at regulations.gov.
• A virtual public hearing will be held October 29, 2026 only if someone requests one by October 19, 2026. If a hearing goes forward, pre-registration to speak closes October 26, 2026.

Also this week: EPA proposes more time on some TCE deadlines

On October 14, 2026, EPA also proposed compliance date extensions to its TSCA rule on trichloroethylene (TCE), published at 91 FR 65148. Comments are due November 13, 2026, in docket EPA-HQ-OPPT-2026-7327.

Under the 2024 TCE rule (89 FR 102568) and a September 2025 interim final rule (90 FR 44772), several chemical processing uses must stop by December 18, 2026. EPA now proposes to push that date to December 31, 2027 for:

• Processing TCE as a reactant or intermediate.
• Processing and industrial or commercial use of TCE as a processing aid in battery manufacture, polymer fiber spinning, fluoroelastomer and Alcantara manufacture, caprolactam manufacture, and beta-cyclodextrin manufacture.
• Disposal of TCE from those uses to industrial pre-treatment, industrial treatment, or publicly owned treatment works.

EPA also proposes to move the first phasedown step for TCE used to make the refrigerant HFC-134a (cutting TCE feedstock to 75 percent of baseline) from June 7, 2027 to December 31, 2027. Companies that make, process, or distribute TCE would have 30 days after a final rule to update their downstream notifications and safety data sheet text.

EPA is asking for comment on a longer alternative date of December 18, 2028, and on whether a final rule should take effect quickly, because the December 18, 2026 date is close. EPA is also reconsidering other parts of the 2024 TCE rule, including workplace exposure controls, in a separate rulemaking.

Remember that this is a proposal. Until EPA finalizes it, the December 18, 2026 date still applies.

What to do now

1. Confirm whether part 98 applies to you for reporting year 2025. Base this on the applicability rules in 40 CFR 98.2, your 2025 emissions, and your source categories, not on filing history. A site that started operating or first crossed a threshold in 2025 may owe its first report even if it has never used e-GGRT. If part 98 does not apply, you can likely stop here on the greenhouse gas item.
2. Move your internal deadline. Replace October 30, 2026 with March 10, 2027 for your reporting year 2025 report, and tell anyone who owns the data, including consultants and corporate environmental staff.
3. Keep your 2025 data and records in order. EPA changed only the reporting deadline. Keep the monitoring data, fuel records, and calculations you will need if EPA keeps your source category.
4. Plan for both outcomes. EPA's final action on the reconsideration could keep, change, or remove your obligations. Avoid big spending on report polish until EPA acts, but do not throw away the data.
5. Check state programs separately. This federal rule does not change any state greenhouse gas reporting rules your site may also be under.
6. If you use TCE, find out where you stand. Check whether any of your processes fall into the uses listed above, keep working toward the December 18, 2026 date unless EPA finalizes the change, and consider commenting by November 13, 2026 if the timing affects you.
7. Watch your SDS updates. If the TCE change is finalized, expect revised safety data sheets and downstream notices from your suppliers within about 30 days.

Provisio EHS helps manufacturers sort out which EPA programs apply, track shifting deadlines, and keep the records that hold up when an agency changes course. Safety-Chat and Provisio Core keep your chemical inventory and SDS library in one place, so supplier updates like these do not get lost. If you want a second set of eyes on how these changes affect your site, call us at 385-316-2837.

Sources

All retrieved Oct 15, 2026, about 8:22 to 8:40 AM MDT (America/Denver).

• EPA, "Extending the Reporting Deadline Under the Greenhouse Gas Reporting Rule for Reporting Year 2025 to March 10, 2027," interim final rule, 91 FR 65112, Oct 14, 2026 (effective Oct 14, 2026; comments due Nov 30, 2026; Docket EPA-HQ-OAR-2025-0186): https://www.federalregister.gov/documents/2026/10/14/2026-20982/extending-the-reporting-deadline-under-the-greenhouse-gas-reporting-rule-for-reporting-year-2025-to
• EPA, "Extending the Reporting Deadline Under the Greenhouse Gas Reporting Rule for 2025," final rule, 91 FR 9712, Feb 27, 2026: https://www.federalregister.gov/documents/2026/02/27/2026-03995/extending-the-reporting-deadline-under-the-greenhouse-gas-reporting-rule-for-2025
• EPA, "Reconsideration of the Greenhouse Gas Reporting Program," proposed rule, 90 FR 44591, Sep 16, 2025: https://www.federalregister.gov/documents/2025/09/16/2025-17923/reconsideration-of-the-greenhouse-gas-reporting-program
• EPA, Greenhouse Gas Reporting Program (GHGRP) web page: https://www.epa.gov/ghgreporting
• EPA, "Trichloroethylene (TCE); Regulation Under the Toxic Substances Control Act (TSCA); Compliance Date Extensions," proposed rule, 91 FR 65148, Oct 14, 2026 (comments due Nov 13, 2026; Docket EPA-HQ-OPPT-2026-7327): https://www.federalregister.gov/documents/2026/10/14/2026-20964/trichloroethylene-tce-regulation-under-the-toxic-substances-control-act-tsca-compliance-date
• EPA, "Trichloroethylene; Regulation Under the Toxic Substances Control Act (TSCA); Compliance Date Extension," interim final rule, 90 FR 44772, Sep 17, 2025: https://www.federalregister.gov/documents/2025/09/17/2025-17948/trichloroethylene-regulation-under-the-toxic-substances-control-act-tsca-compliance-date-extension
• EPA, "Trichloroethylene (TCE); Regulation Under the Toxic Substances Control Act (TSCA)," final rule, 89 FR 102568, Dec 17, 2024 (cited in 91 FR 65148): https://www.govinfo.gov/content/pkg/FR-2024-12-17/pdf/2024-29274.pdf