Repeal of Endangerment Finding and Vehicle GHG Emissions Standards

Policy Engagement Overview

Public Evidence

InfluenceMap's database covers roughly 1,000 companies and 300 industry associations globally, with the most engaged entities scanned on a weekly basis and all entities assessed at least every other quarter. The current state of corporate engagement on this regulation is summarized below. The Evidence Profile graph to the right indicates InfluenceMap's capture of corporate positions on the proposal, ranging from negative positions endorsing the repeal of the vehicle standards and/or endangerment finding, to positive positions calling for the administration to maintain these regulations. Both this page and the graph were last updated on October 22, 2025.

As the proposal closed for comment on September 22nd, InfluenceMap will be assessing comments submitted to the docket as they appear. As of October 17, less than 2% of regulatory comments on the proposal have been posted.

Public Responses to the Proposal

• In general, many groups across different sectors of the economy are concerned with the legal durability and repercussions of the EPA’s proposal, and proposed changes that would weaken GHG standards in the US instead of removing them completely

• Car and truck manufacturers are concerned that the proposal would create regulatory uncertainty, making it more difficult for manufacturers to plan their vehicle production for the future. The companies generally do not appear to support the repeal of the 2009 Endangerment Finding. Many road transport companies assessed advocated for the EPA to propose weaker emissions standards that would provide certainty in order to plan production for coming years, fearing that EPA’s proposal would be undone in a coming lawsuit or by a future administration.

• Oil and petrochemical companies also advocated for alternatives to repealing the 20009 Endangerment Finding. They primarily requested that the EPA repeal the most recent emissions standards finalized under the Biden administration, and not use GHG emissions standards to drive adoption of zero-emission vehicles in the future. This would result in a much weaker set of emission standards, which would be unable to promote vehicles with the smallest carbon footprint (zero-emission vehicles).

• Nearly 60 companies and investors signed September 2025 joint comments submitted by Ceres, advocating in defense of the endangerment finding and emphasizing that federal GHG emissions standards are “fully compatible with energy and industrial growth and profitability.” Signatories include IKEA US, Michelin North America, and the New York City Retirement Systems.

• The US Chamber of Commerce (US Chamber) submitted September 2025 comments advocating in favor of repealing federal vehicle GHG emissions standards, and further urging the EPA to take additional action against the corporate fuel economy (CAFE) and criteria pollution emissions standards for vehicles. The group also called for states to be preempted from issuing their own vehicle standards. Although not focusing explicitly on the endangerment finding, it appeared to endorse its repeal, stating it “strongly supports EPA’s current efforts to revoke or revise the regulations that would be amended by the Proposed Rule because they are enormously costly and ultimately unachievable.”

• The National Association of Manufacturers advocated for EPA to narrow its proposal and not repeal the 2009 Endangerment Finding, stating that “Repealing the 2024 Tailpipe Emissions Rule, While Deferring Other Actions, Could Be More Favorable to Industry.” The association stated that the proposal could lead to a “patchwork regulation” scenario in which GHG regulation is not upheld by the federal government, but instead by states.

Transport Sector Positioning – September 2025 Regulatory Comments:

• Comments from vehicle manufacturers assessed so far expressed concern with the proposal, emphasizing that it might not withstand later lawsuits and creates an environment of regulatory uncertainty.

• The Alliance for Automotive Innovation expressed concern with the proposals, stating that “The approach also has the potential to further amplify the severity of policy swings in future administrations,” and did not clearly support or oppose repealing the 2009 Endangerment Finding. The Alliance advocated for the EPA to separately revise the GHG emissions standards for light- and medium-duty vehicles MY 2027-2032, and to create a new set of “backstop” or “alternative” emissions standards through an “Interim Final Rule” (IFR), which would be weaker than existing GHG emissions standards. Ford, Stellantis, Volkswagen subsidiary Porsche, and Honda backed the Alliance’s comments.

• The Truck and Engine Manufacturers Association (EMA) stated that repealing the 2009 Endangerment Finding could be challenged in court later and creates litigation risks and uncertainty for manufacturers. Instead, the EMA advocated for EPA to repeal the existing emissions standards for heavy-duty vehicles (Phase 3 Standards), and revert to earlier and weaker heavy-duty vehicle GHG standards (Phase 2).

• Honda strongly opposed the repeal of the 2009 Endangerment finding and described the proposal as a “route to prolonged legal battles, possible market fragmentation, and technological stagnation,” while Ford Motor stated “eliminating standards altogether is not likely to provide the industry with the long-term stability we need to make historic investments in America and compete globally.” Volvo Group advocated to weaken existing GHG emissions standards, but stated that it “does not oppose” having GHG regulations for heavy-duty vehicles, or greater use of battery-electric vehicles in the sector.

• Tesla Motors strongly opposed the proposal, stating that it would “have a highly disruptive and unlawful retroactive result.” Rivian advocated for the EPA to withdraw its proposal, and advocated for a new proposal that “creates less uncertainty for the industry.”

• The Zero Emission Transportation Association, an industry group representing EV manufacturers and power companies, stated that “there is broad agreement across the industries we represent that rescinding the finding itself would be disruptive to the stable regulatory environment on which durable economic growth depends and would undermine investments made in reliance on that framework.” The group’s CEO, Albert Gore, strongly opposed the repeal of the endangerment in a previous July 2025 statement.

• Stellantis advocated for EPA to weaken existing GHG emissions standards through an IFR, but did not take a clear position on the repeal of the 2009 Endangerment Finding.

• The Transport Project, which represents a mix of vehicle and fuel manufacturers, advocated for the administration to revoke the Phase 3 GHG emissions standards for heavy–duty vehicles but did not push the agency to revoke the 2009 Endangerment Finding.

• Outside of regulatory comments, Daimler Truck “commended” the EPA’s proposal to revisit the GHG emission standards in statements published in Transport Topics in August 2025 and supported the proposal as a whole in the company’s testimony at an EPA hearing in August 2025.

• Airlines for America opposed repealing the 2009 Endangerment Finding, and emphasized the importance of GHG standards for the sector’s global competitiveness and existing investments made to comply with the regulatory framework.

  
  

Oil Sector Positioning – September 2025 Regulatory Comments:

• The American Petroleum Institute (API) emphasized that the association “believes EPA has authority to regulate GHGs under the CAA Clean Air Act” – a position that appears to contest the agency’s proposal to repeal the 2009 Endangerment Finding – and warned of litigation risk from revoking the finding. However, the group also advocated for the EPA to repeal the most recent standards for light-, medium-, and heavy-duty vehicles, and to prevent the agency from considering or promoting zero-emission vehicles while setting GHG emissions standards. Previously, API’s CEO broadly supported the proposed repeal in a July 2025 press release, followed by an August 2025 committee hearing testimony to the EPA in which the association supported the repeal of the emissions standards, but requested that the government “revise” the GHG emissions standards.

• Valero advocated for the EPA to repeal the most recent GHG emissions standards, and to remove the agency’s authority to promote zero-emission vehicles. The company did not clearly support or oppose repealing the 2009 Endangerment Finding in its comments.

Power Sector Positioning - September 2025 Regulatory Comments:

• Edison Electric Institute (EEI) submitted September 2025 comments that appeared to caution the EPA against repealing the endangerment finding, emphasizing that it would create an uncertain regulatory environment. However, EEI called upon the EPA to facilitate new fossil gas infrastructure, urging the agency to “continue these important efforts by establishing a durable regulatory framework to help get new natural gas generation capacity and other critical infrastructure online.” As with the US Chamber and API, EEI urged the EPA to finalize rules that would survive legal scrutiny.

  
  

Cross-Sector Positioning - September 2025 Regulatory Comments:

• Business Roundtable did not take a clear position on repealing the 2009 Endangerment Finding, but advocated for EPA to ensure that if the Endangerment Finding is revoked, states and local governments are unable to fill the regulatory gap with new regulations.

• The National Federation of Independent Business stated that it “concurs in the proposal.”