They could, easily, but Americans wouldn’t accept it.
We have become used to high CO2 content beers................
You might be thinking of bottle conditioned beer.
I don’t know if those are even sold in the US anymore.
They continue fermenting after bottling and require different storage conditions from most beers.
Mr. Mew loved Morland’s Hen’s Tooth, but that was discontinued years ago.
I don’t think he’s had a bottle conditioned beer that he hasn’t made since then.