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 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 and type).
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.
b. Trade Association Knowledge Summary
i. Common/representative processes/production pathways used in the U.S. for producing each of the items covered under CBAM. Percentage of production facilities estimated to use each process.
ii. Most likely fuels used in the U.S. for producing each of the items covered under CBAM. Estimated percent of production facilities to use each fuel. Provide regional variation, if known.
iii. Percent of U.S. production facilities typically producing electricity on-site.
iv. Typical feedstock sources. Provide regional variation, if known.
v. Typical level of production facility integration and process and/or subprocess co-location. Percent of facilities that are integrated at each of the different levels. List of products that are typically produced at the same facility in the U.S.
3. Calculation Methodologies and General Comments:
a. Describe or define how your members or 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 members’ and/or your organization’s efforts to prepare for the effects of CBAM implementation.
b. Describe the most significant factors that differentiate the U.S.’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. Provide comments on the most robust, defensible methodology for calculating a national average product emissions intensity per a U.S. Schedule B code and/or TARIC code for the sectors listed in 2a.
d. Provide comments on weaknesses, gaps, or biases in the EU's CBAM calculation methodology.
e. Provide comments on technically sound alternatives or adjustments to EU’s CBAM calculation methodology.
f. 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.

All Other Respondents
1. Respondent Information: Name, location, and primary point of contact.
2. Existing Models, Tools, and Analyses:
a. Describe any existing LCA, TEA, or other process-based models developed or maintained by your organization for the following sectors: iron and steel, aluminum, cement, fertilizers, and hydrogen.
b. Copy or hyperlink to publications produced by your organization (e.g., white papers, reports, peer-reviewed publications) related to CBAM or to the comparison of U.S. industrial emissions intensity against international benchmarks.
3. Curated Datasets and Data Access: Provide datasets that contain information on the inputs, outputs, and emissions from the sectors listed in 2a.
4. Methodological Expertise and Recommendations:
a. Provide comments on the most robust, defensible methodology for calculating a national average product emissions intensity per a U.S. Schedule B code and/or TARIC code for the sectors listed in 2a.
b. Provide comments on weaknesses, gaps, or biases in the EU's CBAM calculation methodology.
c. Provide comments on technically sound alternatives or adjustments to EU’s CBAM calculation methodology.

As a result of information submitted in response to this RFI, NETL may elect to request additional clarification of responses received.
Reminder: NETL will not reimburse any company or association for any information that is submitted in response to this posting or travel costs incurred as a result of participating. Any information submitted is voluntary.
Confidential Business Information: Pursuant to 10 CFR 1004.11, any person submitting information that he or she believes to be confidential should submit via email two well-marked copies: one copy of the document marked “confidential” that includes all the information, including that believed to be confidential, and one copy of the document marked “non-confidential” that includes only non-confidential information. The U.S. Government is not liable for the disclosure or use of unmarked information. If your response contains confidential, proprietary, or privileged information, you must include a cover sheet marked as follows:
Notice of Restriction on Disclosure and Use of Data
Pages [list applicable pages] of this response may contain confidential, proprietary, or privileged information that is exempt from public disclosure. Such information shall be used or disclosed by the Government and its contractors (including DOE's contractor-operated laboratories) only for the purposes described in RFI [insert RFI number]. The Government may use or disclose any information that is not appropriately marked.
In addition, (1) the header and footer of any page that contains confidential information must be marked: “Contains Confidential Information Exempt from Public Disclosure” and (2) any line or paragraph containing such information must be clearly marked with [[double brackets]] or highlighting.
Submission Instructions: Narrative responses shall not exceed 3 pages, excluding a cover page and data appendices. The narrative should be Word or PDF format, and data appendices in Excel format. Responses are due no later than 5:00 pm ET on Wednesday, September 2, 2026. Please reference “CBAM Study: Request for Information” in the subject line of your email. THIS RFI IS NOT A REQUEST FOR COMPETITIVE QUOTES. Documentation must be submitted via e-mail at CBAMStudyRFI@netl.doe.gov. Telephone inquiries will not be honored.