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…

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…

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.

The transition of the European steel industry towards climate neutrality will build on the deployment of new technologies and will be dependent on the reliable availability of low carbon energy (mainly electricity and hydrogen) at economically viable and affordable prices.

EUROFER supports the position of the steel for packaging sector represented by APEAL, the Association of European Producers of Steel for Packaging, regarding the Packaging and Packaging Waste Regulation (PPWR) proposal, as it suggests much needed improvements to the new EU legislation in order to contribute to a sustainable and resource-efficient solution for a green and resilient EU economy.

EUROFER welcomes PW prevention measures that take into account the wider scope of a circular and resource efficient economy, ensuring a net decrease in carbon emissions. It is worth to look at design for high-quality recycling, guaranteeing high-quality input in the recycling operations.

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 steel industry welcomes the European Commissions initiative to secure the sustainable access to critical raw materials. This is necessary to support the EU ambition to be the first climate neutral continent, to lead the digital decade and to be sure that the future of industry is made in Europe.

The steel industry welcomes the European Commissions initiative to secure the sustainable access to critical raw materials. This is necessary to support the EU ambition to be the first climate neutral continent, to lead the digital decade and to be sure that the future of industry is made in Europe.

POSITION PAPER Ref. Ares(2020)2316668 - 30/04/2020 EUROFER COMMENTS TO DRAFT CLIMATE LAW The European steel industry is committed to contributing responsibly to the achievement of the EU’s long-term climate objectives in line with the ambition of the Paris Agreement.

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

With regard to the European Climate Law setting the climate neutrality objective by 2050, it is imperative that the legislation does not solely focus on the long-term target but also on the regulatory framework which is required to reach the long-term target.

The European steel sector welcomes the forthcoming revision of the EU Waste Framework Directive 2008/98/EG (WasteFD) intending to reduce the environmental and climate impacts, increase environment quality and improve public health associated with textiles and food waste, and contribute to the ambition of the European Green Deal in terms of reducing waste generation and the transition to a circular economy.

Review of the Emissions Trading System: EUROFER paper • • • • • • • KEY MESSAGES The ETS review needs to balance environmental ambition with the necessary enabling conditions for decarbonisation investments (internationally competitive energy and raw materials, effective trade and carbon leakage measures, funding support, lead markets).

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

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.

Position Paper Ecodesign for Sustainable Products Regulation Publication date: 22 June 2022 The steel industry welcomes the release of the recently proposed Ecodesign for Sustainable Products Regulation (ESPR) by the European Commission.

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

European Steel Association, EUROFER, welcomes the initiative on sustainable products. This initiative can be an enabler for achieving EU goals on resource efficiency and climate, once the three pillars of the sustainability are taken equally into account for controlling and removing, to the extent possible, trade-offs.

Carbon Border Adjustment Mechanism EUROFER’s recommendations for strengthening carbon leakage protection while increasing climate ambition Our key messages ➢ Increasing climate ambition and rising carbon costs require strengthened rather than weakened carbon leakage protection ➢ The inclusion of the steel sector in the CBAM entails a high degree of complexity and risk, since steel products are traded with many third…

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

Please find attached the contribution from EUROFER, the European steel association. It includes the following documents: 1. Paper on border adjustment and carbon leakage measures 2. Legal opinion by law firms Nctm, Luther and GIDE on WTO compatibility aspects of carbon border measures 3.

High energy prices affect the competitiveness of European energy-intensive industries (EIIs), and in particular the steel industry vis-a-vis competitors in third countries. A coherent EU energy policy framework should aim at ensuring affordable energy prices, so to boost industrial competitiveness and avoid losing further market shares at a global level.

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)

EUROFER Position paper on the Commission’s proposal for the revised Construction Products Regulation - 2022/0094 (COD) The European Steel Association (EUROFER) broadly welcomes the Commission’s proposal for a revised Construction Products Regulation (CPR) and supports the following elements in particular: • • • • • • • • Alignment with the Ecodesign for Sustainable Products Regulation (ESPR) proposal is essential…

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

The European Steel Association, EUROFER, wishes to express its views on the consultation for the revision of the Construction Products Regulation (CPR). Over 30% of steel produced is used in the construction sector, and steel construction products play a vital role in the construction of stable, durable, energy efficient, and ultimately reusable and recyclable buildings.

The European steel industry, represented by EUROFER, welcomes the European Commission’s Inception Impact Assessment for the revision of EU legislation on Hazard Classification, Labelling and Packaging of Chemicals, which aims to improve this legislation. We appreciate the possibility for the industry to comment on this topic and take this opportunity for providing our contribution in the attached file.

EUROFER Feedback with regards to: “Ref. Ares(2019)141469 - 10/01/2019 The European Steel Association (EUROFER) is pleased to submit the following comments on the ‘Hazardous chemicals — new rules on classification, labelling and packaging’, in particular with regards to Cobalt Harmonised Classification and Labelling (CLH).

EUROFER paper: the 2040 climate target requires an industrial revolution, but its enabling conditions are not there yet The debate on the 2040 targets offers the opportunity for a reflection on the contribution of the EU climate policy to the objectives of the Clean Industrial Deal and more broadly on EU’s role in the global arena.

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

Industrial Emissions Directive (IED) inception impact assessment – EUROFER response (box) Due to the COVID-19 pandemic, many steel operators cannot effectively contribute to Commission activities or are simply not available. Therefore, this contribution cannot comprehensively reflect the full view of the sector.

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…

The European steel industry would like to contribute to the circular economy through this piece of legislation concerning the automotive sector, which is the second largest demand sector for finished steel products.

The European Steel Association (EUROFER) welcomes the review of the Directive 2000/53/EC on End-of-Life Vehicles (ELVs). The Directive has contributed effectively to the improvement of the management of waste generated by discarded vehicles (ELVs) and to the establishment of ELVs recycling.

The European steel industry, represented by EUROFER, welcomes the European Commission’s Inception Impact Assessment for the revision of EU legislation on Registration, Evaluation, Authorisation and Restriction of Chemicals (REACH), which aims to clarify the interface between the REACH and other legislation and improving the overall REACH process.

16 December 2025 EUROFER Comments on the Commission Proposal for a Highly Effective Trade Measure Page • EUROFER welcomes the European Commission’s proposal for a new trade measure addressing the negative spillover effects of global steel excess capacities.

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

The Steel Action Plan commits to a new steel trade measure to protect and promote EU steel capacities in light of massive global excess capacity. The capacity objective is the key for designing a highly effective steel trade measure setting tariff-rate quotas reflecting import market shares that support workable capacity utilization as a condition for profitability and sustainability notably decarbonisation.

The revision of the CO2 regulations for cars and vans is an opportunity to ensure future vehicle designs can meet the objectives of the Paris Climate agreement, without risking the shifting of emissions from the tailpipe to other lifecycle stages.

The European steel industry welcomes the opportunity to provide its feedback and disclose its position on the European Commission's proposals on the revision of the rules on infrastructure and market design for renewable and low-carbon gases (EU Regulation 715/2009 and Directive 73/2009) in the context of the Fit-for-55 Package and the binding climate neutrality trajectory set out in the European Climate Law (EU…

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 steel industry welcomes the release of the Waste Shipment Regulation revision by the European Commission. However, significant improvements are necessary to ensure effectiveness of the revised rules in contributing to the objectives of the EU Circular Economy Action Plan and the EU Green Deal.

EUROFER welcomes the efforts of the EU Commission for making some EU laws instrumental in transforming the EU economy into a circular one and in reaching the goals of the EU Green Deal. The Waste Shipment Regulation (WSR) is one of them. It has been an effective instrument for improving environmental protection and regulating waste transport.

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 input Public consultation on Green-listing certain waste for the purposes of shipments to recovery between Member States Date and time: 11 September 2026 EUROFER supports the objectives of the proposed Delegated Act on green-listing certain waste for the purposes of shipments for recovery between Member States.

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

The European steel industry welcomes the opportunity to provide its feedback and disclose its position on the European Commission's proposals on the revision of the rules on infrastructure and market design for renewable and low-carbon gases (EU Regulation 715/2009 and Directive 73/2009) in the context of the Fit-for-55 Package and the binding climate neutrality trajectory set out in the European Climate Law (EU…

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.

EUROFER welcomes the opportunity to comment on the Proposal on foreign subsidies distorting the internal market and calls the institutions to make of this a comprehensive and broadly covering tool which goes beyond concentrations and public procurement.

EUROFER supports the ambitious White Paper on Foreign Subsidies and agrees with the Commission on the presence of a regulatory gap, which we believe exists and needs to be filled: •The steel sector has experienced the near impossibility to have WTO actions initiated tackling third country subsidies and State-Owned Enterprises at the root, due to the prohibitive evidence and injury requirements to take action under…

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.

EUROFER welcomes the opportunity to provide its feedback to the ongoing review of the E-PRTR Regulation. EUROFER considers the E-PRTR Regulation a valuable source of reported emissions of a given pollutant over time and appreciates the effort carried out by the European Commission to improve the reporting rules. Please find attached three key issues EUROFER believes should be carefully considered during this review.

The European steel industry welcomes the development of a coherent product policy framework that supports a circular economy and sustainability, giving full recognition to materials fit for circularity and supporting sustainable outcomes. We are at a critical stage in which EU product policy can be shaped to fully support the development of a more Circular Economy.

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.