95--Carbon Border Adjustment Mechanism Study RFI

Amended to extend period for responses through Wednesday September 2, 2026 and to provide updated CBAM RFI document with extended date reflected as the due date. Summary: This is a Request for Information (RFI) issued by the Department of Energy (DOE), National Energy Technology Laboratory (NETL), for informational purposes only. NETL is soliciting data, information, and expert commentary from the United States (U.S.) industry, academia, and other stakeholders related to emissions (carbon dioxide (CO2), nitrous oxide (N2O), and perfluorocarbons (PFCs)) of U.S. manufacturing to support a study on the effects of the European Union's (EU s) Carbon Border Adjustment Mechanism (CBAM) on U.S. exporters. Disclaimer: This RFI is NOT a Request for Proposal (RFP) or capability statement. It is not to be construed as a commitment by the Government to issue a solicitation or award a contract. Respondents are advised the Government will not pay for any data or cost incurred in response to this RFI. All costs associated with responding to this RFI will be solely at the respondent s expense. Background: The purpose of this RFI is to gather data necessary for NETL to conduct a Congressionally directed study as requested by H.R. 6938 (published in H.R. 119-213 ): The Committee directs NETL to consult with relevant agencies, institutions, academia, and think tank partners and to provide not later than one year after the date of enactment of this Act a study to determine the average emissions intensity of certain goods produced in the United States compared to those from other countries. Certain goods shall include all items implicated by the EU s Carbon Border Adjustment Mechanism. The report shall include a detailed and transparent description of the methodology used to determine the average product emissions intensity of a product, a record of all sources of data used, and a list of covered products, including their associated heading or subheading of the U.S. Harmonized Tariff Schedule. Information Request: NETL is using this RFI to facilitate consultation with industry, relevant agencies, institutions, academia, and think tank partners. Specifically, NETL seeks input from the following: Producers, manufacturers, and trade organizations in the following sectors: o Iron and steel o Aluminum o Cement (including kaolin clay) o Fertilizers o Hydrogen Life-Cycle Assessment (LCA) and Techno-Economic Analysis (TEA) practitioners and data providers. Academic and research institutions with expertise in industrial process emissions and greenhouse gas accounting . Software companies and technology providers specializing in emissions tracking, reporting, and verification. Other interested government, non-governmental, and private-sector entities. In response to this RFI, NETL asks respondents to provide as much of the following information as possible. Please see the Submission Instructions section regarding the use of data appendices. Producer/Exporter NETL is only interested in the following emissions per sector: Iron and steel CO2 only Aluminum CO2 and PFCs Cement (including kaolin clay) CO2 only Hydrogen CO2 only Fertilizers CO2 and N2O 1. Respondent Information: Producer/Exporter name, location, and primary point of contact. 2. Data and Evidence for U.S. Carbon Intensity: a. Existing Reporting Programs: To accurately calculate the carbon intensity of U.S. produced goods that are impacted by CBAM, NETL is interested in leveraging data from existing reporting programs. Where available, please provide copies of relevant reports, such as: i. CBAM (quarterly) reports already prepared for, or submitted to, the EU/EU importers. ii. Data prepared for, or submitted to, the U.S. Environmental Protection Agency (EPA). iii. Data prepared for, or submitted to, other international climate or environmental programs or trade organizations, disaggregated to show type and quantity of emissions from each source (e.g., CO2 from stationary combustion, indirect CO2 from electricity usage) and associated production quantities, so that emissions factors (kilograms CO2 equivalents (CO2e)/tonne of product) can be calculated. b. Beyond Existing Reporting Programs: Provide verifiable, facility-level or product-level data to support the calculation of carbon intensity for goods produced in the U.S. This includes, but is not limited to the following: i. Production data 1. Quantity of goods produced per process and/or subprocess (e.g., tonnes of flat sheet aluminum produced by hot rolling, tonnes of flat sheet aluminum produced by cold rolling, tonnes of aluminum pipes produced by extrusion). 2. Description of production process for aforementioned product. 3. Associated current U.S. Schedule B codes and/or TARIC codes for these products. 4. Time frame associated with above production data (ideally at least one calendar year). ii. Production facility address. iii. Electricity consumption 1. Electricity consumed (megawatt hours) by process and/or subprocess. 2. On-site energy produced (type and quantity) by process and/or subprocess, if applicable. 3. If power is produced on site, percentage of electricity demand met by on-site generation. 4. Name of power plant and paired production facility if a Power Purchase Agreement (PPA) exists and if facility is directly connected to the power plant or only to the local grid. iv. Fuel consumption (type and quantity) by process and/or subprocess. v. Material feedstock consumption data, including feedstock country of origin (type and quantity) by process and/or subprocess. vi. Direct process emissions data (quantity, type, and source). vii. Quantity of recycled materials used (e.g., scrap steel, recycled aluminum). viii. Quantity of any coproducts or byproducts generated that would reduce carbon intensity of any process and/or subprocess. 3. Calculation Methodologies and General Comments: a. Describe or define how your organization currently calculates a product s carbon intensity, noting specific methodologies used (e.g., ISO 14040/14044, GHG Protocol). b. Describe how those calculation boundaries align with, or differ from, the EU CBAM methodology boundaries. 4. General CBAM Comments: a. Describe your organization s efforts to prepare for the effects of CBAM implementation. b. Describe the most significant factors that differentiate your facility's carbon intensity from similar products produced in other countries, including those within the EU (e.g., technology, fuel mix, environmental regulations, scrap utilization). c. Describe the primary technical, financial, and logistics barriers for your organization to comply with international carbon regulations requiring actual, verified data. d. Describe how the results of NETL s study could be best presented and communicated to support U.S. industry. 5. Challenges or Limitations Related to RFI: Challenges or limitations to providing the aforementioned data to NETL (e.g., requested format, granularity requested, Confidential Business Information concerns). 6. Data for Other Countries: Citations or hyperlinks to data sources or studies that may be useful to inform the carbon intensity of similar goods produced in other countries. Trade Associations NETL is only interested in the following emissions per sector: Iron and steel CO2 only Aluminum CO2 and PFCs Cement (including kaolin clay) CO2 only Hydrogen CO2 only Fertilizers CO2 and N2O 1. Respondent Information: Trade Association name, location, and primary point of contact. 2. Data and Evidence for U.S. Carbon Intensity: a. Disaggregated data from existing reporting programs organized by the Trade Association. For goods produced in the U.S., where available provide member-submitted facility-level or product-level data showing type and quantity of emissions from each source (e.g., CO2 from stationary combustion, indirect CO2 from electricity usage) and process and/or subprocess and associated production quantities so that emissions factors (kilograms CO2 equivalents (CO2e)/tonne of product) can be calculated: i. Production data 1. Quantity of goods produced per process and/or subprocess (e.g., tonnes of flat sheet aluminum produced by hot rolling, tonnes of flat sheet aluminum produced by cold rolling, tonnes of aluminum pipes produced by extrusion). 2. Description of production process(es) for aforementioned product. 3. Associated current U.S. Schedule B codes and/or TARIC codes for these products. 4. Time frame associated with above production data (ideally at least one calendar year). ii. Production facilities addresses or general locations (e.g., Southwest, Illinois) covered by the aforementioned data. iii. Electricity consumption 1. Electricity consumed (megawatt hours) by process and/or subprocess. 2. On-site energy production (type and quantity) by process and/or subprocess, if applicable. If power is produced on site, percentage of electricity demand met by on-site generation. 3. Name of power plant and paired production facility if a…