Testimony
Climate and Energy
October 15, 2026

Public Comment: Department of Energy's CBAM Study RFI

Jia-Shen Tsai

Downloadable PDFs

The Niskanen Center recently submitted a comment in response to a Request for Information (RFI) from the Department of Energy’s National Energy Technology Laboratory (NETL) on the carbon-emission intensities of U.S.-produced goods in five key manufacturing sectors. The Energy Department will use Information collected through the RFI for a congressionally directed study on the impact of the European Union’s Carbon Border Adjustment Mechanism (CBAM) on U.S. exporters in the iron and steel, aluminum, cement, hydrogen, and fertilizer sectors. The CBAM adjustments function as carbon-emission tariffs.

Congress directed NETL to deliver the study within one year of the fiscal year 2026 appropriations law, which puts it due in January 2027. That is nearly a year before the EU’s December 2027 deadline for its next round of default value revisions, enough time for U.S. data to shape the default values that U.S. exporters will be charged on. As discussed in our submission, we urge NETL to move quickly. More countries are rolling out border carbon measures of their own, beginning with the United Kingdom in January 2027, and every month of delay costs U.S. producers ground in their export markets.