e-GGRT and HFC Data Reporting related to AIM
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This page includes information on using EPA’s electronic Greenhouse Gas Reporting Tool (e-GGRT) to report to EPA certain hydrofluorocarbon (HFC) information related to the American Innovation and Manufacturing (AIM) Act, which was enacted on December 27, 2020. The AIM Act directs EPA to phase down production and consumption of HFCs in the United States by using an HFC allowance allocation and trading program. In response to this legislation, the EPA Administrator signed a final rule on September 23, 2021. The final rule sets the HFC production and consumption baseline levels from which reductions will be made, establishes an initial methodology for allocating and trading HFC allowances for 2022 and 2023, and creates a robust, agile, and innovative compliance and enforcement system.  More information about the final rule can be found here: https://www.epa.gov/climate-hfcs-reduction/final-rule-phasedown-hydrofluorocarbons-establishing-allowance-allocation.

As part of the rulemaking process, EPA referenced historical data on the production and import of HFCs collected through e-GGRT. On October 1, 2021, EPA issued allowances to companies that produced and/or imported HFCs in 2020, based on the three highest years of production or consumption between 2011-2019. More information on the 2022 HFC allowance allocations can be found here: https://www.epa.gov/climate-hfcs-reduction/final-rule-phasedown-hydrofluorocarbons-establishing-allowance-allocation

HFC Allowance Set-aside

EPA has established a set-aside pool of HFC allowances, which EPA intends to issue to eligible companies no later than March 31, 2022. Companies that are eligible for allowances from the set-aside pool include, among others, importers that currently import and/or export HFCs but were not previously required to report to EPA under the Greenhouse Gas Reporting Program (GHGRP), codified in 40 CFR part 98, and were not identified in time to be included in the general allowance pool. As part of an application for allowances from the set-aside pool, anyone who imported regulated substances in 2020 that was not required to report under the GHGRP must provide EPA the following information by November 30, 2021, to be eligible for consideration:

  • Name and address of the company, the complete ownership of the company (with percentages of ownership), and contact information for a designated representative at the company;
  • The following information on an annual basis for all years between 2011 and 2020 where the person imported regulated substances:
    • The total quantity (in kilograms) imported of each regulated substance each year, including each shipment, dates of and port of entry for each import, and country from which the imported regulated substances were imported;
    • The Harmonized Tariff Schedule codes for the regulated substances or blends imported;
    • The CAS numbers for the regulated substances imported, including the CAS numbers for individual components in imported blends;
    • The quantity (in kilograms) of regulated substances imported for use in processes resulting in their transformation or destruction; and
    • The quantity (in kilograms) of regulated substances sold or transferred during that year to each identified person for use in processes resulting in their transformation or destruction.
  • The following information on an annual basis for all years between 2011 and 2020 where the person exported regulated substances:
    • The names and addresses of the exporter and the recipient of the exports;
    • The quantity of each specific regulated substance exported, including the quantity of regulated substance that is used, reclaimed, or recycled;
    • The date on which, and the port from which, the regulated substances were exported from the United States or its territories;
    • The country to which the regulated substances were exported; and
    • The Harmonized Tariff Schedule codes and CAS numbers for the regulated substances shipped.

This information must be provided using the forms available below and submitted through e-GGRT. Instructions for submitting through e-GGRT are included here. In addition to reporting on HFC imports and exports using the forms below through e-GGRT, companies requesting HFC allowances from the set-aside pool must submit a set-aside application to EPA through the Ozone Depleting Substances (ODS) Program in CDX. Information on how to submit a set-aside application to EPA is available here: https://www.epa.gov/climate-hfcs-reduction/hfc-allocation-rule-reporting-and-recordkeeping.

Reporting on HFC Production, Imports, Exports, and Destruction

The GHGRP requires certain suppliers of HFCs to report their activities to EPA annually under 40 CFR part 98, subpart OO. As further detailed in subpart A and subpart OO of the GHGRP, suppliers who are required to report under subpart OO include, but are not limited to:

  • All producers of bulk HFCs;
  • Importers or exporters who annually either import or export fluorinated GHGs (including bulk HFCs), fluorinated heat transfer fluids (HTFs), nitrous oxide, and carbon dioxide that in combination total 25,000 metric tons carbon dioxide equivalent (CO2e) or more; and
  • Facilities that annually destroy a total of 25,000 metric tons CO2e or more of fluorinated GHGs (including HFCs) or fluorinated HTFs.

e-GGRT is limited to submitting and revising GHGRP annual reports for years 2016 to 2021. However, EPA has made available a Microsoft Excel (XLS) form for years 2011 to 2015 for HFC suppliers who did not submit an annual report for one or more of those years, and would now like to submit their supply data for those corresponding years. 

The Excel file(s) for year 2011 to 2015 may only be submitted in e-GGRT by attaching them to the GHGRP 2020 annual report. If you are not familiar with how to submit an annual report via e-GGRT, see detailed instruction links below.

Note that if your facility is subject to GHGRP and failed to provide a timely annual report, your facility may be out of compliance with 40 CFR Part 98 and the Clean Air Act.

Regardless of whether a company must report under the GHGRP, anyone seeking allowances under the set-aside as an importer of HFCs must provide import data from 2011-2020.

e-GGRT Reporting Instructions

See Uploading Back-year GHGRP Data for detailed reporting instructions for Reporting years 2011-2015

See Subpart OO Reporting Form Instructions for detailed reporting instructions for Reporting years 2016 and forward.

Download Reporting Forms

Subpart OO - Special 2011 - 2015 Backyear Form for Companies that Import or Export

Subpart OO - Special 2011 - 2015 Backyear Form for Facilities that Produce Transform or Destroy

Subpart OO - Empty Reporting Form for Reporters Not Subject to Part 98 for RY2020.xlsx


For questions regarding registration, reporting questions, or any issues submitting your HFC data, please complete this form.

This web site is maintained by a contractor to the U.S. Environmental Protection Agency (RY2021.R.02)