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…
SU
Steel Union
Industry association · Czechia
not in the EU Transparency RegisterThis organization files on consultations without a register number, so its record here is built from its filings alone. Register facts (staff, costs, accreditations) are not available for it.
6
positions filed
in the 665 files tracked
6
legislative files
of 665 tracked
2
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.
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Their record over time
Steel Union filed 6 positions between 8 Jul 2025 and 8 Jun 2026, across 6 of the 665 legislative files tracked here, attaching a full position paper 2 times.
2025 · 5 filed2026 · 1 filed
What they argued
In the last years EU has lost its strong industry companies and is continuously loosing production/capacities, competitiveness. Companies are not able to decarbonise as they planned due to lack of enabling conditions (competitive energy costs and certainty about stability of energy supply, weak carbon leakage and trade protection, sufficient financial support without unnecessary conditionality, availability of raw…
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.
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.
We strongly oppose the proposed 90% climate target for 2040 as this would directly endanger existence of the steel sector in the EU, with all the social, economic and strategic consequences. No ambitious goals should be set until enabling conditions for decarbonisation are in place. Please, read more in the attached position.
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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