ArcelorMittal

Steels recyclability is a strategic advantage for Europes green transition. Smart policies that prioritize scrap quality, CRM recovery, and domestic processing will accelerate decarbonization, strengthen resource security, and maintain EU industrial competitiveness.

ArcelorMittal welcomes the opportunity to contribute to the call for evidence in view of the reform of the EU public procurement rules. We therefore submit our key highlights and proposals in the attached document.

ArcelorMittal welcomes LIAA’s goal to increase the share of manufacturing to at least 20 % of EU gross value added and to stimulate demand for low-carbon materials, including lacier. However, the current proposal has weaknesses and loopholes that do not allow for the effective creation of lead markets for low-carbon lacier.

Filed in French · English published by the European Commission

rcelorMittals welcomes the objective of the Industrial Accelerator Act and its goals to increase manufacturing to at least 20% of EU gross value added and boost demand for lowcarbon materials, including steel. However, the current proposal contains weaknesses and loopholes that risk failing to create effective lead markets for lowcarbon steel.

ArcelorMittals welcomes the objective of the Industrial Accelerator Act and its goals to increase manufacturing to at least 20% of EU gross value added and boost demand for low carbon materials, including steel. However, the current proposal contains weaknesses and loopholes that risk failing to create effective lead markets for low carbon steel.

ArcelorMittal is a leading steel and mining company with a presence in 60 countries and an industrial footprint in 15. The company is a key supplier of high-quality steel to major markets, including automotive, construction, household appliances, and packaging.

Please find attached ArcelorMittals contribution to the call for evidence regarding the revision of the Taxonomy Climate Delegated Act. We thank the European Commission for the opportunity to provide input. Our comments and proposals focus on the key issues of particular relevance to the steel sector.

"With the view of the European Climate Law setting the climate neutrality objective by 2050, it is imperative that the legislation does not solely focus on the long-term target but also on the regulatory framework within, which is required to reach the long-term target.

PRIORITIES AND COMMENTS TO THE CORPORATE SUSTAINABILITY DUE DILIGENCE PROPOSAL ArcelorMittal supports the EU Green Deal and the Sustainable Finance agenda. In this context, Arcelormittal has reviewed the Corporate Sustainability Due Diligence Proposal released by the European Commission and wishes to give its contribution to the public consultation.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Policy Paper EU Rules for the Certification of Carbon Removals The European steel industry contribution to the European Commission Calls for Evidence Publication date: May 2022 Introduction The European steel industry is among the economic sectors currently developing solutions for the capture and use (hereinafter as CCU) of CO2 contained in industrial off-gases, residual waste streams from internal production…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

KEY MESSAGES The ETS review needs to balance environmental ambition with the necessary enabling conditions for decarbonisation investments (internationally competitive energy and raw materials, effective trade and carbon leakage measures, funding support, lead markets).

The proposed regulation on Clean Corporate Fleets presents an opportunity to accelerate the decarbonisation of the entire European automotive ecosystem, beyond tailpipe emissions. This should include European content requirements for components and materials, such as steel, being subject to the EUs emissions trading system and at a high risk of carbon leakage.

ArcelorMittal France, welcomes the initiative on sustainable products. This initiative can be an enabler for achieving EU goals on resource efficiency and climate, once the three pillars of the sustainability are taken equally into account for controlling and removing, to the extent possible, trade-offs. It is also important to recognise that EU products policy will also have an impact on the economic aspects.

Carbon Border Adjustment Mechanism EUROFER’s recommendations for strengthening carbon leakage protection while increasing climate ambition Our key messages ➢ Increasing climate ambition and rising carbon costs require strengthened rather than weakened carbon leakage protection ➢ The inclusion of the steel sector in the CBAM entails a high degree of complexity and risk, since steel products are traded with many third…

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Dear Sir/Madam, The development of an effective carbon border adjustment is essential as basis for the transition to carbon neutrality of the steel sector production in Europe and a crucial cornerstone of European Green Deal success. This impact assessment is an important step to have the right design in place.

The development of an effective carbon border adjustment is essential as basis for the transition to carbon neutrality of the steel sector production in Europe and a crucial cornerstone of European Green Deal success.

We highly appreciate the progress made on CBAM in the Steel & Metals Action Plan earlier this year. Particularly the recognition and the planned solution to Resource Shuffling in that document is essential to avoid carbon leakage and enable investments in the EU.

The 2040 climate target requires an industrial revolution, but its enabling conditions are not there yet. To reverse the current deindustrialisation trend, rather than an abstract debate on macro targets, political capital should be invested in delivering on the following enabling conditions, some of which have been laudably recognised in the Steel and Metals Action Plan: an effective solution to global steel…

The principle that any recognition of carbon costs paid outside the EU should remain fully aligned with the rules and principles of the EU Emissions Trading System (EU ETS). Any divergence from ETS rules risks undermining the environmental integrity of the CBAM and weakening the carbon leakage protection provided to European industry. Please see attached

Policy should be recognising only effective, explicit and net carbon price paid in countries of origin with ambitious, transparent and robust climate legislation. The deduction for the carbon price paid in the country of origin plays an important role in the equation calculating the final CBAM costs.

The revision process of the ELVs Directive needs to aim at the following key objectives: 1. to transform the ELVD into a Circularity enabler promoting and ensuring design for recyclability of new vehicles and their parts; 2.

During a transitional period (e.g. until 2030), the CBAM levy of CBAM steel goods (i.e. customs codes as of 7205) should be based on the default values of the country of origin (based on the most carbon-intensive production route) in order to avoid resource shuffling.

ArcelorMittal the worlds leading integrated steel and mining company, and Europes largest steel producer welcomes the European Commissions leadership in proposing a long-term, highly effective trade measure to address global excess capacity in steel. We are encouraged that many stakeholders share our view on the urgent need for decisive action.

As one of Europe's largest industrial companies, ArcelorMittal welcomes the European Commission's initiative to develop a dedicated Research and Innovation Strategy for Water Resilience. Water resilience should not be considered solely as an environmental objective. It is increasingly becoming a prerequisite for industrial resilience, competitiveness, decarbonisation and European strategic autonomy.

CBAM benchmarks should reflect best environmental practices. The CBAM benchmarks are meant to reflect the level of free allocation granted to European industry in order to ensure an effective carbon leakage protection and a level playing field with importers. Therefore, they play a major role in the calculation of the CBAM obligation, since they are discounted from the total costs of embedded emissions.