EUROFER

The steel industry welcomes the European Commission's initiative to prepare a comprehensive Circular Economy Act (CEA) to accelerate the transition towards a more circular economy in the European Union. The forthcoming CEA offers an important opportunity to reposition circularity from a purely environmental concept to a strategic industrial policy instrument that strengthens the EUs competitiveness, resilience, and…

The Industrial Accelerator Act (IAA) represents a timely and welcome initiative to foster climate neutrality by accelerating industrial decarbonisation and to support the development, competitiveness and resilience of the Union's manufacturing sector.

The European steel industry fully supports the objectives of the Industrial Decarbonisation Accelerator Act, to create the market demand in both private and public procurement for low CO2 steel products made in Europe. This is a key part of realising the business case for the steel industry to make the required investments in low CO2 steelmaking technologies.

European Content and Lead Markets for Low-CO2 European Steel: Demand Side Policies for Sustainable Production and Fostering Decarbonisation Investments In the midst of the most profound transformation in history, the European steel industry, and its value chain, is confronted with an existential crisis due to a combination of weak demand, unprecedented import levels resulting from global overcapacity, persistently…

EUROFER members welcome the opportunity to contribute to the consultation to review the EU taxonomy environmental delegated act to update and simplify the technical screening criteria. We provided suggestions to further strengthen and support the effective implementation of Annex I to the Commission Delegated Regulation - amending Delegated Regulation (EU) 2023/2486 as regards enhancing the usability of the…

The European Steel Association, EUROFER, supports the European Commissions comprehensive sustainable finance strategy, aimed at redirecting capital flows toward sustainable and inclusive growth. However, this goal can only be met if the EUs sustainable finance taxonomy recognises the specific needs of hard-to-decarbonise sectors such as steel.

The European Steel Association (EUROFER) fully supports the objectives of having a level playing field and legal certainty on green claims, whilst ensuring consumers can trust and recognise efforts to increase environmental sustainability. In order to meet these objectives, the directive should be more precise on specific requirements to ensure consistent enforcement across member states, including: 1.

The European Steel Association - EUROFER, supports the establishment of a common and consistent assessment framework that will, in principle, reduce cost to industry by limiting the proliferation of assessment methods and labels. This should help retain access to a single market without barriers to trade, and also ensure that the environmental impact of imported goods can be properly assessed.

The proposed regulation on Clean Corporate Fleets presents an opportunity to accelerate the decarbonisation of the entire European automotive ecosystem, beyond tailpipe emissions. This should include European content requirements for components and materials, such as steel, being subject to the EUs emissions trading system and at a high risk of carbon leakage.

EUROFER paper: CBAM consultation on circumvention & downstream sectors • • • • • • • • • KEY MESSAGES CBAM circumvention risks are extremely high for steel due to the unique combination of: o Wide product scope & trade flows with numerous third countries; o Heterogenous carbon footprint linked to multiple options of combining production routes and input materials; o Complex and multiple value chains, with several…

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

The European Steel Association, EUROFER, supports the general increase of vehicles’ maximum weight in the EU to 44t (and allowing individual countries to set heavier limits as in case of Nordic countries like Sweden and Finland) and the free transit of vehicles of this load between EU Member States, based on two main reasons: - Climate - Internal market In the attached EUROFER feedback document one can find further…

Response to Call for Evidence Electrification Action Plan The European steel sector recommendations to the Commission call for evidence on the Electrification Action Plan (EAP) Publication date: October 2025 Federico B.

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

The European steel industry supports maintaining the ambition of CO2 emission targets, however, in line with other stakeholders in the automotive sector (e.g. ACEA and CLEPA), there needs to be flexibilities for OEMs in meeting the targets. This can be achieved in a collaborative way that benefits the whole supply chain.

EUROFER supports the Commissions intention to develop robust, forward-looking measures that retain more secondary materials. As with aluminium scrap, the trade flows of ferrous scrap generated within Europe should also be strictly controlled and regulated by suitable trade measures, appropriately designed to ensure that future policies deliver maximum environmental, economic, and strategic value for the European…

EUROFER paper: CBAM benchmarks should reflect best environmental practises 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.

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

EUROFER supports the objectives of improving transparency, reducing greenhouse gas emissions, strengthening circularity, and developing lead markets for low-carbon steel. At the same time, the Impact Assessment (IA) must carefully weigh environmental benefits alongside administrative costs, implementation complexity, market distortions, raw material security, and industrial competitiveness.

EUROFER supports the single annual repurchase slot as set in Art 4.2 for the reasons stated in recital 17. As clarified in this recital, "allowing authorised CBAM declarants to enter multiple repurchase requests into the CBAM registry would increase administrative complexity, hinder effective control and enable optimisation strategies aimed at profiting from price fluctuations over time.

EUROFER welcomes the update of the European List of ship recycling facilities set out in the draft Commission Implementing Decision amending Implementing Decision (EU) 2016/2323. The European steel industry has a direct interest in ship recycling, because steel recovered from dismantled ships is a high-quality secondary raw material for EU steelmaking.

The draft implementing act, as it stands, will have a very limited effect on reducing the environmental impact of NZIA technologies, compared to current practices in the public procurement. The European steel industry request that public auctions help create lead markets that will drive demand for low CO2 steel products made in the EU.

The European Steel Association, EUROFER, welcomes the opportunity to provide a response to the Public Consultation on the Occupation Exposure Limit (OEL) for Benzo(a)pyrene (BaP), launched by the European Commission with its draft proposal COM (2025)418. Our detailed comments are included in the attached document.