U.S. Clean Competition Act (CCA) / United States Carbon Border Adjustment Mechanism
ENFORCEMENT TIMELINE
Planned introduction in 2026
Overview
The U.S. Clean Competition Act (CCA) is a bipartisan federal bill that would impose a border carbon adjustment tariff on imported carbon-intensive products (steel, aluminum, chemicals, cement, refined petroleum, paper, etc.) while also promoting decarbonization among U.S. domestic manufacturers. While similar to the EU's Carbon Border Adjustment Mechanism (CBAM), the CCA is distinctive in its dual-incentive design: it imposes a charge of $55 per ton (increasing annually for inflation, among other factors) not only on imports but also on domestic carbon-intensive production activities in the United States whose emissions exceed the U.S. average. This is intended to secure a decarbonization competitiveness advantage for the U.S. market and to discourage imports from high-emission countries such as China.
Enforcement Timeline
June 2022: The Clean Competition Act (Senate Bill S.4426) is first introduced by the White House and Democratic lawmakers
December 2023: A revised bill expanding covered products and strengthening alignment with the EU CBAM is reintroduced in Congress
2024–2025: Bipartisan (Republican and Democratic) deliberation and detailed negotiation toward enactment continues
December 2025: Senator Whitehouse (D) reintroduces a revised bill (S.3523 / H.R.6787) in the 119th Congress, including expanded covered products and strengthened alignment with the EU CBAM
2026: With Republicans currently controlling both chambers of Congress and the administration, most analyses view the prospects for enactment as low; however, discussion of similar measures within the United States continues alongside the EU CBAM's 2026 entry into full effect
Related Regulations / Topics
Business Impact
Companies exporting steel, aluminum, chemicals, plastics, glass, paper, and similar products to the United States would be required to rigorously measure and report the carbon intensity of their products (lifecycle CO2 emissions) in accordance with U.S. Environmental Protection Agency (EPA) standards. If a manufacturing process's carbon intensity exceeds the U.S. benchmark, a substantial border carbon tax would apply upon export, significantly reducing the price competitiveness of exports to the U.S. Manufacturers with domestic U.S. facilities could also face charges on emissions exceeding the domestic benchmark, making accelerated procurement of renewable energy and energy efficiency investment locally an urgent priority.
The bill remains under deliberation and has not been enacted, and it currently imposes no legal obligation on companies. However, it reflects a growing domestic U.S. debate over carbon border adjustment measures similar to the EU's CBAM, and companies in carbon-intensive industries such as steel, aluminum, and chemicals may find it worthwhile to consider preparing carbon intensity data in anticipation of possible future legislation.
