Outokumpu

Outokumpu comments the planned Circular Economy Act The circular economy is advancing, but more encouraging examples of its business models are needed. Achieving a true circular economy requires well-functioning markets. We support the general purpose of the planned Act, as it will facilitate the free movement of circular products, secondary raw materials and waste.

Outokumpu supports the idea that the revision of the EUs current public procurement rules will allow for sustainability, resilience and European preference criteria in EU public procurement for strategic sectors.

A mandatory EU origin requirement for steel and stainless steel is a necessary and proportionate measure to safeguard fair competition, reinforce EU trade policy, and support Europes strategic autonomy. It ensures that public procurement drives demand for low carbon, EU produced materials rather than subsidizing imported emissions.

Global CO2 emissions need to be reduced significantly during the next decade. Even if the emissions in the EU have reduced, global emissions continue to grow. Climate change mitigation needs strong global actions. Third countries will provide final NDC’s submissions to the Paris Agreement in 2020.

- Carbon Border Adjustment (CBA) would be supplementing the European Climate Policy. It is needed to achieve the long-term ambitions of EU climate policy while avoiding carbon leakage. CBA can also be seen as a temporary tool whereas the long-term target is to have a global price for carbon.

Outokumpu welcomes the opportunity to provide feedback on the draft revision of benchmark values for free allocation under the EU ETS for the 20262030 period. As a global leader in lowcarbon stainless steel, Outokumpu supports the principle of regularly updating EU ETS benchmarks based on real performance data, in line with technological progress and with the overarching goal of meeting the EUs climate goals.

Introduction Energy efficiency is one of the most cost-effective ways to decarbonise the energy system in both short and long term. A successful energy efficiency policy should aim at supporting multiple targets such as strengthening the competitiveness of industrial value chains and helping to reach climate goals, among others.

Outokumpu is a major producer of stainless steel in the EU and we are deeply concerned about the proposed classification of cobalt and the implications it will have on stainless steel due to the small amounts of cobalt that are present in all stainless steel as impurity.

The deduction for the carbon price paid in the country of origin plays an important role in the equation calculating the final CBAM costs. In order to ensure the environmental integrity of the CBAM and its effectiveness in ensuring a level playing field for European producers, it is essential that a very cautious and conservative approach is adopted in recognising the carbon price in the country of origin.

Outokumpu strongly supports a robust and predictable EU Emissions Trading System (ETS) as a cornerstone of Europes climate policy and industrial competitiveness, generating economic growth and employment in Europe. We welcome the Commissions commitment to the climate targets for carbon neutrality by 2050 and at least 90% greenhouse gas emission reduction by 2040.

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.

The Centre should become Europe's central platform for monitoring global raw material markets, identifying emerging supply risks and supporting coordinated action to strengthen resilience. Its analytical function should provide continuous monitoring of supply-demand developments, identify bottlenecks across value chains and support diversification of supply sources.