The iron and steel sector contributes nearly 7% of global anthropogenic GHG emissions. As global climate commitments tighten and industrial decarbonization becomes urgent, green steel, produced using low-carbon alternatives such as green hydrogen and renewable electricity, has emerged as a potential solution. This Comment explores how national and international regulations are shaping the future of green steel, focusing on the interplay between climate policy and trade law.

For the first time in nearly 50 years, following the federal government's recission of CEQ's NEPA implementing regulations on April 11, 2025, there are no governmentwide regulations in place to provide consistent direction to all federal agencies on how to implement the governmentwide procedural obligations established by NEPA. This Comment explains the costs of eliminating the common floor that the CEQ regulations had established for federal agencies conducting the environmental analyses required to comply with NEPA’s statutory mandate, and why those costs need not have been incurred.