Unelected and Unaccountable: How the ISO–GHG Protocol Partnership Threatens American Energy Sovereignty
The Bull Moose Project has released a new policy primer on the ISO–GHG Protocol partnership, and the core argument is simple: a quiet international standard-setting deal is being used to impose an activist emissions agenda on American businesses without a single vote from American lawmakers or the public.
In September 2025, the ISO announced a partnership with the GHG Protocol to "harmonize" global emissions accounting standards. Most Americans have never heard of either organization, and that's by design. The GHG Protocol is an advocacy framework backed by progressive philanthropies and foreign governments, including Bloomberg Philanthropies, the MacArthur Foundation, and the governments of France, Germany, and the Netherlands. The ISO partnership gives that agenda the cover of technical legitimacy.
The methodology itself is fundamentally flawed. The GHG Protocol measures aggregate emissions rather than emissions intensity, meaning an efficient company that doubles output while cutting emissions per unit looks worse on paper than one that simply produces less. On top of that, its Scope 3 reporting requirements force companies to track and report emissions across supply chains they don't own or control — costs that fall hardest on small and mid-sized manufacturers and flow directly to consumers as higher energy prices.
This poses three key risks: competitive disadvantage for U.S. producers operating under standards misaligned with domestic realities, disproportionate compliance burdens on smaller firms, and higher consumer energy costs at a moment when affordability is a national priority.
Our core recommendation is for Congress and the administration to act before these standards achieve binding force by default — putting the ISO under formal review, directing the SEC and EPA to pause adoption of any GHG Protocol-derived standards, and advancing intensity-based alternatives like the PROVE IT Act as the American answer.
