Greenhouse Gas Reporting Program Requirements for Importers and Exporters

The EPA Greenhouse Gas Reporting Program (GHGRP) requires annual reporting of greenhouse gas (GHG) data and other relevant information from large sources and suppliers in the United States. The regulation referred to as 40 CFR Part 98, which was published in the Federal Register on October 9, 2009, covers:

• Suppliers of certain products that would result in GHG emissions if released, combusted or oxidized;
• direct emitting source categories; and
• facilities that inject CO2 underground for geologic sequestration or any purpose other than geologic sequestration.

Specifically, the regulation includes importers/exporters of:

• Coal based liquid fuels (subpart LL), 
• Petroleum products (subpart MM), 
• Industrial gases (subpart OO), 
• Carbon dioxide (subpart PP), and 
• Fluorinated GHGs contained in pre-charged equipment or closed-cell foams (subpart QQ).

Requirements for each of these types of importers/exporters are detailed below. Importers and exporters that meet the threshold as defined below and that are required to report under one of the following subparts should visit the GHG Reporting Program website to review the applicable requirements. A help desk is also available.  Data for the GHGRP is available through the Facility Level Information on GreenHouse Gases Tool (FLIGHT).

Suppliers of Coal-based Liquids Fuels (Subpart LL) 

• Importers who bring coal-based petroleum products or natural gas liquids (NGLs) into the United States from a foreign country must report if the quantity of coal-based petroleum products imported is equivalent to 25,000 metric tons of CO2e or more.
• Exporters who transfer coal-based petroleum products or NGLs from the United States to another country or to an affiliate in another country must report if the quantity of coal-based petroleum products exported is equivalent to 25,000 metric tons of CO2e or more.

Suppliers of Carbon Dioxide (Subpart PP) 

• Importers of bulk CO2, if total combined imports of CO2 and other GHGs exceed 25,000 tons of CO2e per year. 
• Exporters of bulk CO2, if total combined exports of CO2 and other GHGs exceed 25,000 tons of CO2e per year.