Coal for Steel Production is Not a “Critical Material”

Washington, D.C. —

The U.S. Department of Energy’s (DOE) effort to designate metallurgical coal a “critical material” in the department’s 2026 Critical Materials Assessment relies on a flawed and insufficient process, as detailed in a letter signed by a dozen groups.

The Department of Energy’s May 2025 analysis fails to meet the threshold for designating metallurgical coal, which is used to make steel, as a critical material under the Energy Act of 2020.

The letter, signed by, Earthjustice, Public Citizen, Allegheny-Blue Ridge Alliance, Appalachian Voices, Center for Biological Diversity, Citizens Coal Council, Earthworks, Friends of the Earth, Kentucky Resources Council, Inc. Montana Environmental Information Center, Sierra Club, and West Viriginia Highlands Conservancy, states that metallurgical coal is a fuel, which the DOE itself acknowledges can be used in thermal applications. Simply put, metallurgical coal fails to meet the legal definition of a ‘non-fuel’ material, and DOE’s own data show no evidence of supply chain risk or reliance on imports that would justify this designation, according to the groups.

The Energy Department designation is one of several steps the Trump administration is taking to boost an uneconomic sector of the U.S. coal industry, including a new 2.5% tax credit included in the reconciliation bill signed by President Trump earlier this month, which would be available to coal exporters.

“At a time when the steel industry must rapidly transition to cleaner production methods, like electric arc furnaces and hydrogen-based direct reduced iron, it’s misleading and dangerous to give met coal this unqualified status, especially without any credible justification based on market realities or the statute itself,” said Carly Oboth, senior supply chain campaigner with Public Citizen’s Climate Program. “This move risks extending the life of highly polluting coal operations in communities that are already overburdened by environmental harms. Critical materials policy must be based on clear criteria in line with the statute, not the whims of fossil fuel-entrenched interests.”

“DOE’s effort to designate metallurgical coal as a critical material ignores the law and the coal industry’s harms,” said Caroline Weinberg, senior research and policy analyst with Earthjustice’s Clean Energy Program. “Coal is not only excluded from the critical materials list because it is a fuel material, but also because it is not supply constrained. DOE must not bend statutory definitions to serve the White House’s political agenda. Doing so will only waste taxpayer dollars and further exacerbate harms of the coal industry.”

“The U.S. has stable access to metallurgical coal, including significant domestic production and secure trade partners,” said Aimee Erickson, executive director of Citizens Coal Council. “Therefore, there is no material supply chain risk warranting a ‘critical’ designation, and the move could appear politically motivated rather than technically justified.”

“Appalachian communities are on the frontlines of metallurgical coal production, serving as the primary source of met coal in the United States,” said Kevin Zedack, government affairs specialist with Appalachian Voices. “While DOE’s designation of met coal as a critical mineral is supposedly intended to create new coal mining jobs, this administration has made it clear that they’re unconcerned with the wellbeing of coal miners by delaying silica dust protections, gutting federal black lung monitoring and preventative research programs, and eliminating economic development opportunities for communities to set their own priorities and vision for a healthy future. We are already mining more met coal than we can use in the United States; the industry doesn’t need another federal handout while our communities pay the price.”

“West Virginia has already carried the burden of coal extraction for generations. Our communities deserve an economy built on fairness and clean energy, not continued exploitation by an industry that profits off environmental harm and public health crises,” said Andrew Young, staff attorney for the Allegheny-Blue Ridge Alliance. “The Department of Energy’s attempt to label metallurgical coal as ‘critical’ only doubles down on coal’s destructive legacy. Instead, we should prioritize a real transition that invests in sustainable jobs and revitalizes our communities for the long term.”