Response to the DOE’s National Energy Technology Laboratory (NETL) Request for Information

These comments are submitted in response to the DOE’s National Energy Technology Laboratory (NETL) Request for Information initiated on May 20, 2026 on the congressionally directed study to determine the emissions intensity of certain goods produced in the United States and other countries. The study is a timely opportunity to affirm America’s carbon advantage: compared to global competitors, domestic firms manufacture the same goods with much lower greenhouse gas emissions. This carbon advantage can be leveraged into a competitive advantage as countries implement Carbon Border Adjustment Mechanisms (CBAMs)—but only if U.S. performance is documented fairly.