Steel Union

Industry association · Czechia

positions filed

in the 326 files tracked

legislative files

of 326 tracked

with a full position paper

attached to a submission

Counts here are a floor, never a total: they cover the 326 consultation files tracked so far (29,503 submissions, mostly 2025–26), so an organization's real filing history is larger, not smaller.

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Their record over time

Steel Union filed 4 positions between 26 Aug 2025 and 8 Jun 2026, across 4 of the 326 legislative files tracked here, attaching a full position paper 1 time.

2025 · 3 filed2026 · 1 filed

What they argued

Circular Economy Actfiled 6 Nov 2025source

We welcome the initiative of the European Commission to prepare a comprehensive Circular Economy Act (CEA) aimed at accelerating the transition towards a more circular economy in the European Union. The forthcoming Circular Economy Act offers an important opportunity to reposition circularity from being seen purely as an environmental concept to a strategic industrial policy instrument that strengthens the EUs…

Revision of the benchmark values for free allocation of emission allowances (2026-2030)filed 8 Jun 2026source

Dear colleagues. Below please find attached our feedback. On one hand, we do not support the 2026-2030 benchmarks (BMs) as proposed by the COM, especially due to the fall-back BMs values. There is an extreme variability of installations using such BMs, both from the size and processes side, that one common BM value is totally irrelevant and can significantly and unjustifiably harm many installations.

Carbon Border Adjustment Mechanism: extension of its scope to downstream goods and anti-circumvention measuresfiled 26 Aug 2025PDFsource

The Czech steel sector calls for urgent and effective solutions to make CBAM effective and fit for purpose, incl. CBAM downstream extension and strong anti-circumvention measures. Attached please find our position paper containing justification and several solutions in this regard, including list of individual CN codes we need to be covered by CBAM.

Protection of workers from the risks related to exposure to carcinogens or mutagens at workfiled 21 Oct 2025source

While we fully support the goal of protecting workers' health, the OEL value of 0.00007 mg/m³ for benzo[a]pyrene (BaP), as proposed by the Commission in the Proposal for a directive - COM(2025)418 is technically and operationally unachievable for coke oven operations, even when using the best available techniques (BAT).

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Turns up on the same files

Organizations that also filed on at least two of the same consultations. A shared interest in the same dossiers — not evidence of coordination, and we do not suggest any.

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