The goal of this study was to develop a methodology for making an accurate comparison of the energy intensity of steel production in China and the U.S. The methodology addresses issues related to boundary definitions, conversion factors, and industry structure. In addition to the base case analysis, six scenarios were developed to assess the effect of different factors such as the share of electric arc furnace (EAF) steel production, conversion factors for the embodied energy of imported and exported intermediary and auxiliary products, and the differences in net calorific values of the fuels. The results of the analysis show that for the whole iron and steel production process, the final energy intensity in 2006 was equal to 14.90 GJ/tonne crude steel in the U.S. and 23.11 GJ/tonne crude steel in China in the base scenario. In another scenario that assumed the Chinese share of electric arc furnace production in 2006 (i.e. 10.5%) in the U.S., the energy intensity of steel production in the U.S. increased by 54% to 22.96GJ/tonne crude steel. Thus, when comparing the energy intensity of the U.S and Chinese steel industry,the structure of the industry should be taken into account.