NV Bekaert SA

Bekaert welcomes the objectives of the proposed Circular Economy Act (CEA) to strengthen EU competitiveness, economic security, and sustainability. We support a harmonized, science-based, and market-oriented approach that ensures consistent product standards, avoids overlap with existing legislation, and promotes fair competition between EU and non-EU producers.

Summary Call for Simplification Bekaert strongly supports the objectives of the EU Taxonomy but highlights the urgent need for simplification and clarification of its technical screening criteria. Current rules are mainly designed for end-product manufacturers and create disproportionate complexity for component* and intermediate-goods* producers that enable decarbonization across multiple sectors.

Summary Call for Simplification Bekaert strongly supports the objectives of the EU Taxonomy but highlights the urgent need for simplification and clarification of its technical screening criteria. Current rules are mainly designed for end-product manufacturers and create disproportionate complexity for component* and intermediate-goods* producers that enable decarbonization across multiple sectors.

Directorate_General for Taxation and Customs Union Unit C-5 (Economic Analysis and Taxation of Exempted Sectors) August 26, 2025 Call for evidence for an impact assessment - Comments submitted on behalf of NV Bekaert S.A. to the public consultation on the “Carbon Border Adjustment Mechanism – downstream extension, additional anti-circumvention measures and rules for the electricity sector” Introduction 1.

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

Please find enclosed some comments submitted on behalf of NV Bekaert S.A. to the call for evidence on the CBAM implementation: rules on the methodology for calculating emissions embedded in CBAM goods; rules on the adjustment of CBAM certificates to reflect the EU ETS free allocation; rules on the deduction of the carbon price paid in a third country

As a preliminary point, Bekaert agrees that a trade measure that protects the steel market against negative trade-related effects caused by global overcapacities is necessary in view of the expiry of the steel safeguard measures. But as explained below, the EU steel ecosystem is an integrated value chain in which the primary (upstream) producers of steel and the downstream steel processors are mutually dependent.