Jernkontoret is Swedish iron and steel producers' association representing companies that produce highly specialised steel products with a wide variety of applications. Jernkontoret welcome the initiative to prepare a Circular Economy Act (CEA), and to address the slow CE-transition in various parts of society.
JER
Jernkontoret
Industry association · Sweden · EU Transparency Register 76331988454-11
31
positions filed
in the 665 files tracked
27
legislative files
of 665 tracked
19
with a full position paper
attached to a submission
Counts here are a floor, never a total: they cover the 665 consultation files tracked so far (57,774 submissions, mostly 2021–26), so an organization's real filing history is larger, not smaller.
Who they are
Among the 1518 trade and business associations on this site, they rank #90 by legislative files engaged, a count of participation, not a measure of influence.
3.2
declared lobbying FTE
self-declared
€900K+
declared costs / yr (floor)
2
EP accreditations
as declared to the register
2012
in the register since
Declares membership of
Self-declared to the EU Transparency Register (snapshot 14 Oct 2026).
- Register category
- Trade and business associations
- Head office
- Stockholm, Sweden
Self-declared to the EU Transparency Register (snapshot 14 Oct 2026); cost bands are floors, not audited totals. Reused under Commission Decision 2011/833/EU.
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Their record over time
Jernkontoret filed 31 positions between 8 Feb 2019 and 11 Aug 2026, across 27 of the 665 legislative files tracked here, attaching a full position paper 19 times.
2019 · 1 filed2020 · 10 filed2021 · 6 filed2022 · 3 filed2025 · 6 filed2026 · 5 filed
What they argued
Jernkontoret supports an IDAA that establishes the right framework conditions across all industries and their value-chains, rather than targeting specific sectors or technologies. European industry needs stable and favorable long-term conditions such as access to affordable, reliable, and fossil-free energy.
Remissvar Jernkontorets reg.no:3521 Stockholm, November 18, 2021 European Commission Contribution on the proposal for revised RED Jernkontoret represents steel industry in Sweden with high ambition to be in the frontline of the transition towards decreasing climate related emissions.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Jernkontoret, the Swedish iron and steel producers association, submits comments regarding practical challenges in applying EU Taxonomy criteria and proposes improvements. The attachment includes specific remarks on Substantial Contribution (SC) and Do No Significant Harm (DNSH) criteria, general observations on Delegated Acts (DA), and comments on the EU Commission notice (C/2025/1373). 1.
Key message Enhance the opportunities for exploration and extraction in general in the EU. Critical Raw Materials are often extracted as a by-product of base metal and iron. Access to many of these metals will become scarcer in the future.
Jernkontoret, the Swedish iron and steel producers association, submits comments regarding E2-5 Substances of Concern (SoC) and Substances of Very High Concern (SVHC). 1. Jernkontoret supports limiting the SoC reporting to the chemical sector as well as adapting the terminology to REACH, thus making the datapoints more logical and possible to report. 2.
Jernkontoret, the Swedish steel producers´ association, comments on the proposal for an EU Climate Law. Jernkontoret also support the contribution from Eurofer. Setting a long-term target, such as the proposed climate neutrality 2050, gives the opportunity to development and deployment of new technologies in a resource efficient and economically feasible way.
The Swedish Steel Producers Association (Jernkontoret) supports the EU-goal of reaching climate-neutrality by 2050, and would like to submit the following feedback on the consultation regarding roadmap for the proposal for a climate law.
Jernkontoret, the Swedish iron and steel producers association call for the following important steps regarding EU climate policy and specifically ETS. The details are further developed in the attached document. A long-term perspective and stability in climate policy are crucial. Conditions in terms of access to energy, permits, trade and economic conditions are absolutely crucial for investments to take place.
Jernkontoret supports the establishment of a common and consistent assessment framework for how companies making green claims should assess their product's or organisation's impacts on the environment. Jernkontoret also find it important that this initiative is consistent with other policy initiatives, such as the sustainable product policy initiative, and takes into account the full product lifecycle.
The Swedish Steel Producer's Association, Jernkontoret, welcomes the initiative taken by the EU Commission on sustainable products. This initiative can be an enabler for achieving EU goals on resource efficiency and climate, as part of Circular Economy Action Plan. It is important that the three pillars of the sustainability are taken into account.
Jernkontorets reg no:32/21 Stockholm 18 November 2021 European Commission Contribution on the proposal for a carbon border adjustment mechanism (CBAM) Jernkontoret represents steel industry in Sweden producing a wide range of steel products and being highly dependent of export to the whole world market.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
EU GREEN DEAL ON STEEL Ref. Ares(2020)1882704 - 01/04/2020 EU CLIMATE LEADERSHIP REQUIRES WATERPROOF CARBON LEAKAGE MEASURES WHY A CARBON BORDER MEASURE NEEDS TO COMPLEMENT TEMPORARILY FREE ALLOCATION AND INDIRECT COSTS COMPENSATION IN THE TRANSITION TOWARDS CLIMATE NEUTRALITY This paper clarifies the reasons why it is appropriate from environmental, economic and legal perspectives to implement initially a carbon…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Jernkontorets diarienr: 3421 Stockholm 2021-11-19 Europeiska kommissionen Yttrande över EU-kommissionens förslag till förändringar i energieffektiviseringsdirektivet, COM(2021) 558 final Sammanfattning Jernkontoret, som företräder järn- och stålindustrin i Sverige, anser att en ökad energieffektivisering i förhållande till syftet och nyttan med användningen är en viktig del i arbetet för minskad klimatpåverkan, ett…
Filed in Swedish · English published by the European Commission
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Representing the steel industry in Sweden, Jernkontoret is deeply engaged in the area of energy efficiency. Making the best use of energy is central for the industry as it is a natural way to increase cost efficiency, competitiveness and sustainability.
Jernkontoret, the Swedish steel producers association support the consultation paper from Eurofer, attached. Concerning the extension to downstream goods the Swedish iron and steel industry are deeply concerned about the risk of circumvention due to the possibility to avoid CBAM cost by further processing outside EU.
Jernkontoret, the Swedish iron and steel producers' association, supports the overall problem description in the proposal. "Greening" of construction products have an important role in the transition to circular economy and decreasing climate impact. Harmonised legislation at EU-level is needed to create an inner market with fair competition.
Jernkontoret, the Swedish Steel Producer's Association, welcomes the European Commissions's IIA on CLP revision as a part of the Chemical Strategy for Sustainability and the opportunity to improve this legislation. Jernkontoret wants to comment the IIA revision on CLP as part of the ongoing open consultation.
Jernkontoret questions the inclusion of cobalt in this ATP as more clarification is required regarding all routes of exposure, mutagenicity, the carcinogenic potency methodology and consideration of bioavailbility for the classification of matrix materials like alloys. Jernkontoret is the Swedish Steel Producers Association.
Jernkontoret, the Swedish steel producers association, welcomes the Green Deal and the holistic perspective that characterize the strategy and we also support the EU ambition to become climate neutral by 2050. Both the Commission and the Member States (MS) need to commit to a long-term policy framework with realistic objectives, and simple and clear rules to provide this stable environment.
Remissvar Jernkontorets diarienummer: 19/26 Stockholm 16 april 2026 European Commission Comments to the Call for Evidence, Setting a renewable Energy Framwork for the decade ahead Jernkontoret represents the iron and steel industry in Sweden. An industry which is in the forefront of the transition towards reduced greenhouse gas emissions.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Jernkontoret, the Swedish iron and steel producers association, provides feedback on the draft Climate Delegated Act. AA. Regarding Annex I (Climate change mitigation) Section 3.9 on the manufacture of iron and steel, we welcome the addition of a criterion 1(c) bringing life-cycle perspective to the activities, and the ambition of point 3 to address practical difficulties in reporting economic data at the level of…
Protecting biodiversity: nature restoration targets under EU Biodiversity Strategy Feedback from Jernkontoret - The Swedish Steel Producers´ Association Contact: [name removed], Ph. D., Senior Advisor, Water, ecosystems, and sustainability. Mobile: [phone removed].
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The new Industrial Emissions Directive (IED) risks slowing the green transition, innovation and complicating permit processes The IED has been an effective tool for reducing industrial emissions and has delivered new legislation year after year via Seville process and BAT-conclusion, sector by sector. All 30 BREF are not yet revised under this cycle.
•There is a significant EU added value elaborating sector BREF in the Seville process. An improved Seville process will be able to both contribute to circular economy and to interact with decarbonization of industry and major changes in IED may not be necessary.
When introducing new requirements as in the battery legislation, it is important that there is a clear environmental benefit with the measures and that the impact assessment that the Commission is planning for is thorough.
Jernkontoret, the Swedish Steel Producers’ Association, welcome the revision of EU legislation on REACH as a part of the Chemical Strategy for Sustainability. Jernkontoret agreed on the main goal for REACH and want to see how the IIA revision on REACH as part of the ongoing open consultation.
Filed in French · English published by the European Commission
Call for Evidence Jernkontorets diarienr: 44/25 Stockholm 2025-10-08 European Commission In reply to the EC Call for Evidence – Electrification Action Plan The Swedish Steel Producers’ Association, Jernkontoret, hereby takes the opportunity to contribute to the Call for Evidence related to the future Electricity Action Plan.
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
Jernkontoret welcomes the EU's efforts to strengthen its strategic autonomy with regard to critical raw materials. We recognize the potential of functions relating to demand aggregation, stockpiling and coordinated procurement.
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…
Inception impact assessment regarding revision of lists of pollutants affecting surface and groundwater (Ref. Ares (2020)5809213 – 23/10/2020) Feedback from Jernkontoret - The Swedish Steel Producers´ Association Contact: [name removed], Ph. D., Senior Advisor, Water, ecosystems, and sustainability. Mobile: [phone removed].
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
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