Stegra (Previously H2 Green Steel)

Stegra fully supports the European Commissions ambition with the Carbon Border Adjustment Mechanism (CBAM), which targets the embedded carbon emissions of products imported into the EU in specific sectors that are within the scope of the EU ETS and the most at risk of carbon leakage.

Stegra fully supports the objective of CBAM and recognizes that it, together with the phase-out of free allocation in EU ETS, is one of the most important prerequisites to decarbonize the industry in EU while also incentivizing decarbonization outside EU. The CBAM Regulation allows for a deduction of the carbon cost if a carbon price has been paid in a third country.

Dear COM, We support your ambition to make the ELV regulation improve the areas you have identified, i.e. 1. Design circular: make design and production circular. 2. Use recycled content: increase the recycled content in new vehicles. 3. Treat better: improve the treatment of ELVs. 4. Collect more: collect more ELVs in the EU and improve quality of exported used vehicles. 5.

International Credits (Article 6) should be excluded from ETS1. In todays complex geopolitical and economic landscape, some flexibility in the climate target for 2040 on the EU level, such as allowing the use of some international emission reduction credits, is understandable to ensure broad support from the public. However, 5% should be maximum cap and the contribution from IC could in the end be lower than 5%.

Stegra fully supports the objective of CBAM and recognizes that it, together with the phase-out of free allocation in EU ETS, is one of the most important prerequisites to decarbonize the industry in EU while also incentivizing decarbonization outside EU. The EU ETS and benchmarks for free allocation are based on processes, whereas the CBAM is based on goods. Simultaneously, the same type of good (e.g.

An ambitious and harmonised EU definition of low-emissions steel - Stegra welcomes the development of a harmonised EU framework for defining the low carbon and near-zero emissions performance of steel. A common European methodology can provide clarity to producers and buyers, reduce fragmentation and, most importantly, help create a market for investments in deeply decarbonised steel production.