November 20, 2023

U.S. International Trade Commission Will Ask All Metals Firms To Report Greenhouse Gas Emissions

As Connecting the Dots reported this past summer, the Office of the U.S. Trade Representative (USTR) tasked the U.S. International Trade Commission (ITC) with conducting an investigation into, and issuing a public report on, the greenhouse gas (GHG) emissions intensity of U.S.-produced steel and aluminum.

The ITC has now published its draft call for information in The Federal Register. All domestic steel and aluminum manufacturers will have to respond to the survey when the final version of it is released in spring 2024. The ITC already has sent a draft questionnaire to some companies. Find the draft here.

The ITC has said, to the extent possible, the final report will provide GHG emissions intensity estimates of steel and aluminum produced in the United States by product category and production stage in 2022, with data defined as:

  • Scope 1: Direct emissions from the facility’s owned or controlled sources.
  • Scope 2: Indirect emissions from the generation of the facility’s purchased energy, including electricity, steam, heat, or cooling.
  • Certain scope 3 emissions: Emissions associated with material and resource inputs for the production of steel and aluminum.

The ITC said the report also will provide a description of the methodologies used to collect relevant information and to analyze product-specific GHG emissions intensities for the range of steel and aluminum products made in the United States.

In June, the Office of the USTR noted the ITC should:

  • Conduct a survey of firms with facilities producing steel and aluminum in the United States, whether the firms are U.S.- or foreign-owned, and that survey should seek to gather data that is not already reported pursuant to the U.S. Environmental Protection Agency GHG Reporting Program or other publicly available information.
  • Use the information obtained through the survey and external data sources to estimate the highest and the average GHG emissions intensity of steel and aluminum produced in the United States by product category in 2022. These percentile and average estimates should, to the extent possible, be weighted by metric ton of steel or aluminum production associated with each emissions-intensity data point.
  • Produce GHG emissions intensity estimates for the broad categories of steel and aluminum products.
  • Consider producing GHG emissions intensity estimates for additional product categories, including at subcategory levels.

Read the original full guidance from Office of the U.S. Trade Representative here.

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