Ecodesign requirements for iron and steel products

Badische Stahlwerke (BSW), as an EAF-based producer of long steel products, supports the objectives of the ESPR to improve transparency, strengthen circularity and create demand for lower-carbon steel. In designing future requirements, it is important to recognise that scrap-based EAF steelmaking already represents an established circular and comparatively low-carbon production route at industrial scale.

We thank the European Commission for the opportunity to comment on this Call for Evidence on the ESPR Delegated Act on iron and steel products. We support prioritising iron and steel under the ESPR Working Plan and aligning this Act with the Steel and Metals Action Plan and the Industrial Accelerator Act (IAA).

The Near Zero Emission Steel (NZES) coalition welcomes the Commission's efforts to support a more com-petitive, sustainable and circular European steel industry by preparing to define performance classes for low-carbon steel under the Ecodesign for Sustainable Products Regulation (ESPR).

CAN Europe supports the definition of ecodesign requirements for iron and steel products in the ESPR delegated act. Getting these requirements right will be instrumental to the success of the steel transition in Europe as the sector requires long-term investment certainty to move away from the fossil model.

EUROFER supports the objectives of improving transparency, reducing greenhouse gas emissions, strengthening circularity, and developing lead markets for low-carbon steel. At the same time, the Impact Assessment (IA) must carefully weigh environmental benefits alongside administrative costs, implementation complexity, market distortions, raw material security, and industrial competitiveness.

SolarPower Europe seeks to highlight the fact that the carbon footprint methodology developed under the ESPR Delegated Act for steel will establish an important precedent for future ESPR product groups and other applications of low carbon definitions in EU law such as under the Industrial Accelerator Act or the Net zero industry act.

Being a cross-sectoral association with member companies operating in different industries and across various stages in the supply chain, the Japan Business Council in Europe (JBCE) welcomes the opportunity to provide its feedback on the impact assessment concerning ecodesign requirements for iron and steel products under the Ecodesign for Sustainable Products Regulation (ESPR).

maki Consulting GmbH welcomes the initiative and the substantial technical work undertaken for the future Delegated Act on intermediate iron and steel products. The attached evidence focuses on methodological and policy-design choices that should be tested in the Impact Assessment before the regulatory architecture is fixed.

The VDA supports the objective of making iron and steel products more sustainable. Well-designed ecodesign requirements can improve transparency for customers and provide industry with the legal certainty and long-term predictability needed to invest in the transition. At the same time, the regulatory framework must avoid duplication of rules that already apply to the automotive sector.

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The Istanbul Chamber of Industry (ISO) welcomes the European Commissions efforts to advance environmental sustainability and reduce carbon emissions through the Ecodesign for Sustainable Products Regulation (ESPR).

The Association of Industrial Unions and Transport (APZD) welcomes the European Commission’s efforts to promote decarbonisation, circularity and transparency in the steel industry through the upcoming delegated act under the Ecodesign for Sustainable Products Regulation. We consider the initiative to be particularly relevant for high-steel-consuming sectors, including the automotive industry.

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APPLiA - Home Appliance Europe supports the Commission's ambition to improve circularity and transparency in the iron and steel value chain. Delivering on this objective well depends on obligations being assigned appropriately across the value chain to the actors best placed to provide or verify the data.

The Polish Steel Association (HIPH) welcomes the launch of the consultation process concerning the preparation of the delegated act for iron and steel products under the Ecodesign for Sustainable Products Regulation (ESPR).

We call on the European Commission to maintain the scope of the upcoming ESPR Delegated Act to iron and steel intermediate products as set out in the ESPR Working Plan and to refrain from extending Digital Product Passport (DPP) obligations to final products containing iron or steel at this stage.

Swedish Enterprise welcomes the Commission's initiative to develop ecodesign requirements for iron and steel intermediate products under the Ecodesign for Sustainable Products Regulation (ESPR). As the first delegated act covering an intermediate product, it will set an important precedent.

Sirk Norge represents Norway's waste and recycling industry and its stakeholders. Our close to 200 members (private and public companies) handle materials across all waste streams. We have over 30 years of industry-specific expertise in promoting and developing responsible waste management and circular economy policies.

DIN, the German Institute for Standardization, welcomes the European Commission's initiative to establish ecodesign requirements for iron and steel products under the Ecodesign for Sustainable Products Regulation (ESPR). European standardization should play a central role in implementing the delegated act.

ESWET the European Suppliers of Waste-to-Energy Technology represents companies that have built and supplied over 95% of the Waste-to Energy (WtE) plants in operation in Europe. It seeks to promote the technologies which recover both energy and materials from non-recyclable waste that would otherwise end up in landfills.

Groupe SEB is a global leader in small domestic equipment, committed to provide innovative and high-quality household appliances with a portfolio of well-known brands such as Tefal, Rowenta, Moulinex, Krups, and WMF, and operating in over 150 countries and serves both consumers and professionals.

We,the Japanese electrical and electronic industrial associations JEMA, JEITA, CIAJ and JBMIA (JP4EE) supports the European Commissions objectives of promoting environmental sustainability and improving resource efficiency, and welcomes the opportunity to contribute to this Call for Evidence. We believe that the scope of the delegated act should not be expanded to final products containing iron and steel.

See ESPR Iron and Steel Questionnaire UNESID Final including rational v4 Harmonised definition of \"green steel\". Methodological Principles [1] agreed by UNESID partners UNESID Low-carbon steel labelling reference values EN v4 (non-paper) The three documents has been integrated in the first one in a row.

CEMEP supports European measures aimed at increasing demand for low-carbon steel and accelerating the decarbonisation of the steel industry. However, this transition must be designed in a way that the competitiveness of the entire European value chain, including downstream industries such as electric motor manufacturing.

Comments on the protection of business-sensitive information under the ESPR Digital Product Passport (DPP) Subject: Protection of sensitive business information and limitation of access to strategic data in the Digital Product Passport (DPP) Dear Sirs, In relation to the development of the delegated acts of Regulation (EU) 2024/1781 on Ecodesign for Sustainable Products (ESPR) and, in particular, with the definition…

MedTech Europe welcomes the opportunity to contribute to the European Commissions consultation on ecodesign requirements for iron and steel products under the Ecodesign for Sustainable Products Regulation. Please see our position in the attached document.

voestalpine supports the objectives of improving transparency, reducing greenhouse gas emissions, strengthening circularity, and developing lead markets for low-carbon steel. At the same time, the Impact Assessment (IA) must carefully weigh environmental benefits alongside administrative costs, implementation complexity, market distortions, raw material security, and industrial competitiveness.

The Ministry of Economics of the Republic of Latvia welcomes the Commission's initiative on ecodesign requirements for iron and steel products and supports its objectives. Based on consultations with the Latvian metalworking and mechanical engineering industry, we raise several considerations regarding alignment with the CBAM framework, the treatment of secondary raw materials, avoidance of duplicative data…

LKAB welcomes the European Commission's initiative, in line with the Clean Industrial Deal and the Steel and Metals Action Plan, to make the iron and steel value chain more sustainable through the Industrial Accelerator Act (IAA) and the upcoming Ecodesign Sustainable Product Regulation (ESPR) Delegated Act.

The BMW Group supports the objective of making iron and steel products more sustainable. Well-designed ecodesign requirements can improve transparency for customers and provide industry with the legal certainty and long-term predictability needed to invest in the transition. At the same time, the framework must avoid duplicating rules that already apply to the automotive sector.

Jernkontoret welcomes the opportunity to provide input to the Call for Evidence on ecodesign requirements for steel products under the Ecodesign for Sustainable Products Regulation (ESPR). Jernkontoret supports harmonised methodologies for reporting the environmental impact of iron and steel products across relevant EU legislation to ensure comparability, avoid conflicting results and minimise unnecessary…

The Nickel Institute supports the European Commission's objective of improving the environmental sustainability and circularity of iron and steel products under the Ecodesign for Sustainable Products Regulation (ESPR). Steel is fundamental to the EU's industrial competitiveness, strategic autonomy and decarbonisation ambitions.

FEDERREC is fully embedded in the positions of Recycling Europe. An ambitious framework under the Ecodesign for Sustainable Products Regulation (ESPR) is essential to decarbonise the steel sector and increase its circuslarity.

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The European association for ferroalloys and silicon, Euroalliages, welcomes the European Commissions initiative to develop Ecodesign requirements and performance classes for iron and steel products. Establishing a robust and transparent framework for assessing the environmental performance of these products can contribute to the decarbonisation of the European steel industry and its value chain, stimulate demand…

POSCO appreciates the opportunity to provide input to the European Commissions impact assessment on recycled content (ReCo), traceability, Digital Product Passport (DPP), and related information requirements for iron and steel products under the Ecodesign for Sustainable Products Regulation (ESPR).

Polish Ministry of Economic Development and Technology welcomes the opportunity to participate in call for evidence for Ecodesign requirement for steel products under Ecodesign for Sustainable Products Regulation (ESPR).

Derichebourg Environnement welcomes the opportunity to contribute to the European framework under the Ecodesign for Sustainable Products Regulation (ESPR). The Derichebourg Group is a major international operator in circular economy and waste recycling, mainly metal (steel, copper, aluminum, etc.) and public sector services. The group currently operates in 17 countries and has 8,800 employees worldwide.

An ambitious and harmonised EU definition of low-emissions steel - Stegra welcomes the development of a harmonised EU framework for defining the low carbon and near-zero emissions performance of steel. A common European methodology can provide clarity to producers and buyers, reduce fragmentation and, most importantly, help create a market for investments in deeply decarbonised steel production.

In the attached feedback, Agora Industry provides feedback for the policy objectives relating to information requirements about the carbon footprint of iron and steel and setting performance classes and environmental thresholds that the Commission has identified in its call for evidence.

1. Classes of performance and minimum environmental performance thresholds. We support the introduction of classes of performance and minimum environmental performance thresholds. To ensure a strong labelling mechanism and thresholds, robust datasets at installation level should be used.

Garant welcomes the objectives of the Ecodesign Regulation, in particular the promotion of decarbonisation, the circular economy and the creation of harmonised sustainability and product information. Standardised data on product carbon footprints (PCFs), recycled content and material properties can make an important contribution to greater transparency along value chains.

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The Danish chamber of commerce welcomes the opportunity to provide input to support the development of ecodesign requirements for iron and steel products to be adopted as a delegated regulation under the Ecodesign for Sustainable Products Regulation (ESPR). Please see our response attached.

The Global Steel Climate Council (GSCC) welcomes the opportunity to provide evidence to support the development of ecodesign requirements for iron and steel products to be adopted as a delegated regulation under the Ecodesign for Sustainable Product Regulation (ESPR). Please see attached file for our detailed response.

EPEE supports the objectives of the Ecodesign for Sustainable Products Regulation (ESPR) framework, including improved circularity and transparency on the carbon footprint of products, and reduced administrative burden for operators.

Recycling Europe, the voice of Europe's recyclers, supports the development of ecodesign requirements for iron and steel products under the Ecodesign for Sustainable Products Regulation (ESPR), recognising their potential to accelerate both decarbonisation and circularity across the steel value chain.

Tamini, a leading Italian producer of industrial, power, and special transformers and part of the Terna SpA Group, supports the European Commissions intention to introduce sustainable ecodesign requirements for iron and steel.

Bellona welcomes the opportunity to submit feedback on the ecodesign requirements for iron and steel,under the Ecodesign for Sustainable Products Regulation. This delegated act matters far beyond the steel sector: iron and steel is the first intermediate product group to complete the ESPR process, so its methodology will set the precedent for following products, and will define "low-carbon steel" for the purposes of…

The Turkish steel industry remains firmly committed to supporting the European Union's objectives of climate neutrality, circular economy, and sustainable industrial development. We believe that an ESPR framework based on technology neutrality, harmonised methodologies, open and competitive markets, practical transition periods, and equal treatment of Customs Union partners will make a significant contribution to…

Schneider Electric welcomes the opportunity to contribute to this consultation. Building on our experience, we call the European Commission to limit Ecodesign requirements for iron and steel products to intermediary products only. Please find attached our position.

Terna supports the European Commissions intention to introduce sustainable ecodesign requirements for iron and steel. At the same time, TSOs supply chains for certain steel-intensive grid components remain constrained, with long lead times and limited supplier availability across several market segments.

Future Cleantech Architects welcomes the opportunity to provide feedback to the public consultation for the impact assessment on ecodesign requirements for iron and steel products. The steel industry is a cornerstone of the European economy, providing critical inputs for many strategic sectors, including the automotive, construction, and defense sectors.

SUEZ welcomes the opportunity to contribute to the European Commissions public consultation on the definition of low-carbon steel. For 125 years, SUEZ has been creating value from steel across the entire value chain, from stamping operations to recycling, helping to reduce logistics, operational and environmental costs.

[JRAIAs Comments] The scope of the Ecodesign requirements for Iron & Steel should not be extended to final products because final products using iron and steel have not been included in the scope of the preparatory study conducted for about two years. The Preparatory Study (published on 23rd March) only covered iron and steel intermediate products.

Iron and steel products carry sustainability data that will have direct commercial and regulatory weight: recycled content, embodied carbon, and whatever definition of low-carbon steel this act settles on. Our comment concerns one property of that data which the current framework does not require, and which is inexpensive to require now and expensive to retrofit later. The framework makes information available.

ASD welcomes the opportunity to provide feedback to this consultation on the development of ecodesign requirements for iron and steel products. In the following, we would like to share our considerations pertaining to the A&D sector to help ensure that the requirements are workable for our industry, taking into account its specific characteristics, including long product lifecycles, complex global supply chains, and…

Iberdrola welcomes the Commission's initiative to improve the environmental sustainability of iron and steel products and to support the development of markets for low-carbon materials. However, the design of ecodesign requirements should carefully consider their broader implications on industrial competitiveness, electrification and the energy transition.

The European Foundry Federation represents the national foundry associations of 20 European countries. Within the EU, the foundry sector comprises over 2,330 foundries, 138,000 direct employees and EUR 31 billion in annual production value. Around 70 % are family-owned SMEs, average EBITDA margins in the sector are near 3.5 %, and production is destined almost entirely for EU customers.

Electricity transmission system operators rely heavily on iron and steel products to run their activities, and their needs increase significantly as electrification progresses. RTE has established an investment plan of EUR 100 billion by 2040. Maintaining high environmental standards in our sourcing remains a key priority for the company.

Expansion of Scope and Representativeness The current JRC preparatory study is excessively narrow, as it limits analysis to only five representative products. For the future delegated act under the ESPR, this list must be expanded because approximately 70% of Spanish productionparticularly carbon long products manufactured via the electric arc furnace (EAF) routecurrently remains outside these categories.

Windmöller & Hölscher begrüßt die Bestrebungen zur Dekarbonisierung und Verbesserung der Kreislauffähigkeit energieintensiver Sektoren im Rahmen der Ökodesign-Verordnung. Wir erkennen an, dass harmonisierte PCF- und Materialdaten künftig einen wichtigen Beitrag zur Erfüllung der Nachhaltigkeitsziele leisten können.

As we understand it, cast iron foundry products are expected to be included as intermediate products within the scope of the iron and steel delegated act under the Eco-design framework. However, as clearly described in JRC reports, cast iron foundry products are in fact finished products, as they undergo no substantial transformation after melting and molding.

IndustriAll Europe welcomes the Commission's initiative to develop a delegated act under the Ecodesign for Sustainable Products Regulation (ESPR) for iron and steel products. The delegated act should contribute not only to decarbonisation and circularity, but also to strengthening European industrial capacity and ensuring a Just Transition for workers.

IVSH (Industrieverband Schneid- und Haushaltwaren e.V.) welcomes the opportunity to contribute to this Call for Evidence. While the finished consumer products represented by IVSH are currently not within the scope of the proposed Delegated Act, our member companies are significant downstream users of iron and steel products and will be affected by sustainability information, Product Carbon Footprint and Digital…

Iron and steelmaking are among the most carbon emissive industrial sectors. Product policy under Regulation (EU) 2024/1781 (ESPR) is the key missing cog to decarbonise steelmaking. To do so, the forthcoming delegated act must use all the useful tools embedded into the legal text. The ESPR is designed to bring environmental consideration to the fore of EU product policy, so far dominated by health and safety aspects.

The ICCT welcomes the opportunity to comment on the Impact Assessment for the Delegated Act on iron and steel products, within the Ecodesign for Sustainable Products Regulation. Out of the three main policy options that are suggested for the Impact Assessment, the ICCT would like to comment on the first two, concerning information requirements and the performance classes. Please see below our main comments.

BASF supports the objective of improving transparency and sustainability of iron and steel products under ESPR. However, future requirements should remain technology-neutral, build on existing industrial data systems and avoid disproportionate administrative burden. Carbon-footprint methodologies require further harmonisation before being used as regulatory benchmarks.

The Austrian Federal Foreign Trade Board criticises the proposal as being impractical and economically burdensome for the steel trade and the processing industry in Austria. Small and medium-sized enterprises and margins in the steel trade: Austrian steel trade is characterised by medium-sized enterprises, with small margins of 2-5 %.

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Its not a technical feeback but a point of view about sustainability.... As it cannot be limited with lowering CO2 alone. For the sustainable steel to be business-sustainable, there should be serious incentives and not only to the producer, it shall effect the price.