The Coalition provided comments to the National Energy Technology Laboratory (NETL) at the Department of Energy in response to its Request for Information on the implementation of aspects of the PROVE IT Act included in the Fiscal Year 2026 spending package. The language contained in the package directs the Department of Energy and NETL to conduct a study comparing the emissions intensity of certain US-produced goods to those produced in other countries.
With the European Union implementing its carbon border adjustment mechanism (CBAM), covered materials and products manufactured in the United States and exported to the EU will be subject to tariffs based on average product emissions, unless manufacturers of covered products can demonstrate the carbon intensity of their products. Covered materials under the CBAM include cement, iron and steel, aluminum, fertilizer, hydrogen, and electricity.
Transparent, reliable, and publicly available US emissions data to support credible carbon accounting and accurately reflect the emissions of goods and products manufactured within the US is central to the success of the American carbon management industry.
The United States produces some of the cleanest energy and materials on the market today, compared with global averages of emissions intensity. To maintain US carbon advantage, transparent and comparable emissions data across sectors will ensure that American energy and industrial products can continue to compete in global markets that are increasingly prioritizing cleaner production.
The Carbon Capture Coalition’s comments pointed to existing datasets, models, and repositories that can be used to provide reliable facility-level emissions data and encouraged NETL to account for emissions reductions from carbon capture and storage when calculating a product’s emissions intensity. Additionally, the Coalition noted that the EU CBAM methodology’s reliance on default values may not fully reflect the performance of US facilities deploying lower-carbon production technologies, when actual emissions data are unavailable, including for carbon capture and storage.
Access to reliable, verified US emissions data is therefore important for reducing reliance on default values and enabling American producers to demonstrate their actual emissions performance.
Carbon capture and permanent geologic storage can materially reduce the direct emissions associated with the production of CBAM-covered goods. The Coalition is encouraged to see the EU’s CBAM methodology recognize these emissions reductions by allowing qualifying CO₂ transferred to permanent geologic storage to be accounted for as not emitted.
See the Coalition’s comments here.