Wirtschaftsvereinigung Stahl

The German steel industry welcomes the initiative of the European Commission to prepare a comprehensive Circular Economy Act (CEA) to accelerate the Unions transition towards a more circular economy. The forthcoming CEA provides the opportunity to becoming a strategic industrial policy tool that strengthens competitiveness, resilience, and climate neutrality.

The German Steel Association welcomes the European Commissions consultation on the revision of the EU Public Procurement Directives. This revision represents a strategic opportunity to transform public procurement from a predominantly price-driven instrument into a value-based policy tool that strengthens Europe’s industrial base, supports strategic autonomy, and accelerates the transition of the steel industry…

Filed in German · English published by the European Commission

The Industrial Accelerator Act (IAA) marks an important step in the EU's ambition to build lead markets for low-carbon industrial products. The German Steel Association had placed high expectations in this initiative as a decisive instrument to incentivise domestic transformation investment, to strengthen European industrial resilience, and to create real demand for low-carbon steel made in EU.

The steel industry in Germany is committed to decarbonisation and to contribute its share to achieving the German and European climate goals. Therefore, we welcome the European Commissions publications on the Clean Industrial Deal (CID) and Steel and Metals Action Plan (SMAP).

The steel industry aims to achieve climate neutrality in line with the agreed climate objectives. When transforming into green steel, it can already save significant amounts of CO2 by 2030, with the right framework conditions. The replacement of coal and, in the long term, natural gas with green electricity and hydrogen plays a crucial role in this process.

Filed in German · English published by the European Commission

The steel industry in Europe has embarked on the path to climate neutrality and is a pioneer in the production of CO2-reduced steel. To support this transition, the rapid development of lead markets for clean steel is crucial. Public procurement law plays a central role in this, but a review of public procurement law is necessary due to the complex procurement procedures and inconsistent regulations in Europe.

The German steel industry supports the European Commission's initiative to standardize the regulatory environment for packaging and packaging waste. The transition from a directive to a regulation can unify framework conditions and requirements between EU member states, promoting the sustainable handling of recyclable material.

The Steel Association welcomes the Commission’s efforts to reduce packaging waste and promote recycling. The European Packaging Directive, as a regulatory pillar of packaging recycling, has managed to bring large quantities of packaging back into the recycling cycle, although this is almost exclusively the case for traditional packaging materials such as steel and tinplate, for which recycling systems already…

Filed in German · English published by the European Commission

The German steel association (Wirtschaftsvereinigung Stahl) welcomes the EU Commissions initiative to revise the Delegated Acts of the EU Taxonomy. As a sector undergoing a profound transition towards climate-neutral production while facing global overcapacity, high investment needs and increasing regulatory pressure, a clear, workable and proportionate Taxonomy framework is essential.

The Critical Raw Materials Act (CRMA) represents an important milestone for the European supply of raw materials and for strengthening the resilience of the European economic area. The German Steel Federation welcomes this regulation. Steel is the most important construction material. Due to its multi-recyclability, steel is a prime example of the circular economy.

The path taken by the EU to increase the resilience of the European supply and value chain points in the right direction. In particular, the fact that the planned legislation contains a very broad package of measures which influence each other and are as mutually supportive as possible is to be welcomed.

Dear Sir/Madam, please find enclosed the opinion of the Wirtschaftsvereinigung Stahl on the European Commission’s proposal for a European Climate Change Act (COM(2020)80). With best wishes, [name removed] Head of Brussels Office Wirtschaftsvereinigung Stahl [Steel Association] German Steel Federation Avenue des Arts 56 B-1000 Brussels Tel.: [phone removed] Mobile: [phone removed] Mobile: [phone removed] E-mail…

Filed in German · English published by the European Commission

06.02.20/Hö Stellungnahme zur Roadmap der EU-Kommission „European Climate Law“ Mit dem „Green Deal“ hat die neue EU-Kommission eine umfassende Strategie zum Erreichen der angestrebten Klimaneutralität in der EU bis 2050 vorgelegt. Vorgesehen ist ein äußerst ehrgeiziges Maßnahmenpaket für einen auf den Klimaschutz ausgerichteten Umbau der Wirtschaft.

Filed in German · English published by the European Commission

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

The Steel Business Association welcomes the upcoming revision of the EU Waste Framework Directive 2008/98/EC (WFD) with the idea of a stronger focus on circular economy and the objectives of increasing the protection of the environment and public health from the effects of waste management, reducing waste generation, increasing reuse and improving separate collection, as well as promoting preparation for re-use and…

Filed in German · English published by the European Commission

With the presentation of the Circular Economy Action Plan, the European Commission had also announced a revision of the Waste Framework Directive (WFD). With a ‘Call for Evidence’ (CFE), the Commission is currently identifying possible priorities for the impact assessment and is thus launching the revision.

Filed in German · English published by the European Commission

Stand: 16. Mai 2022 Stellungnahme Stellungnahme der Wirtschaftsvereinigung Stahl zum Vorschlag für eine Richtlinie des Europäischen Parlaments und des Rates über die Sorgfaltspflicht im Bereich der Nachhaltigkeit von Unternehmen und zur Änderung der Richtlinie (EU) 2019/1937 (CSDD-E; COM(2022) 71 final vom 23.2.2022) Allgemein Für die Stahlindustrie in Deutschland ist die Verbesserung und Sicherstellung von…

Filed in German · English published by the European Commission

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

The proposal for the Environmental Claims Directive aims to tackle false environmental claims by ensuring that consumers are provided with reliable, comparable and verifiable information in order to make more sustainable choices. The general objective is to reduce the risk of so-called green-washing.

Filed in German · English published by the European Commission

The Wirtschaftsvereinigung Stahl welcomes the Commission’s efforts to create a single assessment framework for environmental performance of products and services, aiming at cost savings by limiting the number of assessment methods and their communication. An improved evaluation framework could help to achieve a similar assessment for imported products as for products produced in the EU.

Filed in German · English published by the European Commission

The forthcoming Clean Corporate Fleets initiative offers a unique opportunity to establish lead markets in line with the Clean Industrial Deal while accelerating the uptake of clean vehicles. By extending the definition of clean to both the use phase and the production phase, including the use of CO2-reduced steel made in the EU, policymakers can advance Europes climate and industrial objectives in a holistic and…

The steel industry welcomes the draft regulation establishing a framework for setting ecodesign requirements for sustainable products and repealing Directive 2009/125/EC. The ambitious legislative package has the potential to improve the overall sustainability of products and create incentives for more sustainable products and business models.

Filed in German · English published by the European Commission

The German Steel Federation (WV Stahl) welcomes in principle the European Commission's proposal for a sustainable product policy. A product policy based on the three pillars of sustainability can make a significant contribution to achieving the EU's targets in terms of, for example, climate protection, the circular economy and resource efficiency.

According to the German steel industry, the primary objective of European climate policy should first be to promote an international CO2 price. Internationally harmonised CO2 pricing is a crucial framework for the steel industry to combine ambitious climate protection and international competitiveness.

Filed in German · English published by the European Commission

Border Adjustment – A possible building block to prevent carbon leakage Position paper • The decarbonisation of industry in Europe must not be achieved by replacing domestic production with imports with significantly higher CO2 @-@ loads. Protection against carbon leakage must therefore be a key component of industrial and climate policy.

Filed in German · English published by the European Commission

Stand: 19.11.2021 Stellungnahme zum Richtlinienvorschlag der Europäischen Kommission zum Vorschlag der Europäischen Kommission für eine Neufassung der EURichtlinie zur Energieeffizienz, COM (2021)558 Allgemein Die Europäische Union hat sich mit dem Green Deal das Ziel gesetzt, bis 2050 die Klimaneutralität zu erreichen.

Filed in German · English published by the European Commission

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

Please find the full feedback attached. The steel industry in Germany is committed to achieving climate neutrality by 2050. It also intends to significantly reduce its CO2 emissions already in the coming years. Low CO2 steel technologies can save many millions of tonnes of CO2 — under the right policy framework — to enable the steel industry to contribute towards a socially demanded climate neutrality.

Filed in German · English published by the European Commission

From the point of view of the steel industry in Germany, CBAM must be a useful tool to prevent carbon leakage and to accompany investments to decarbonise the steel industry, as the EU has decided that the protection afforded by free allocation to date will soon be fully phased out. However, it is essential that its effectiveness is ensured from the outset by comprehensive rules.

Filed in German · English published by the European Commission

The construction sector is an important market for steel products. These are fully circular. They thus promote the circular economy through options for re-use, reparability or other equivalent characteristics. In addition, the steel sector is constantly developing new solutions to the design ecosystem, with the aim of meeting the requirements of the European Green Deal and the EU Circular Economy Action Plan (CEAP).

Filed in German · English published by the European Commission

According to Wirtschaftsvereinigung Stahl, the CLP Regulation is an important instrument contributing to the implementation in the EU of the Globally Harmonised System of Classification and Labelling of Chemicals (GHS) initiated by the UN.

Filed in German · English published by the European Commission

For energy-intensive commodity industries such as the steel industry, taxation of energy, even if based on CO2 content, is in principle not an appropriate instrument to support the transformation towards low CO2 technologies and climate-neutral energy consumption.

Filed in German · English published by the European Commission

Steel Economic Association 01.04.2020 Opinion on the Inception Impact Assessment on the European Commission’s approach to the revision of the Energy Tax Directive In principle, the Wirtschaftsvereinigung Stahl may also make sense to evaluate the Energy Tax Directive after 17 years and to adapt it to new developments and requirements.

Filed in German · English published by the European Commission

The proposed amendments to the EU Taxonomy Delegated Acts to Regulation (EU) 2021/2139 (Climate Delegated Act) and Delegated Regulation (EU) 2023/2486 (Environmental Delegated Act) represent a pragmatic and necessary step to improve the usability, clarity and practical applicability of the framework and are supported by the steel industry in Germany.

The German Steel Federation supports the overall goal of conservation biological diversity in order to achieve sustainable economic activity. Stable ecosystems and their goods and services are important not only for ecological, but therefore for economic and social development. However, the specific situations in the variable member states must be taken into account.

Filed in German · English published by the European Commission

Against the background of the goal of greenhouse gas neutrality, the steel industry in Germany is determined to successfully lead the transformation towards climate-neutral and sustainable steel production and to become the technology leader for innovative and climate-friendly production processes.

The iron and steel industry in Germany supports the efforts of the Commission to achieve a higher level of air quality and reduce negative impacts on, and risks to human health and the environment. With this intention the iron and steel industry in Germany promotes the Industrial Emission Directive (IED) which provides ambitious and notably explicit rules on permitting, operating and decommissioning of industrial…

“Climate neutrality by 2050” set the European Union as a target in the Green Deal. Batteries in particular play an important role here in the overall context. The steel industry also wants to contribute to the Green Deal: Through transformation of primary steel production, maximum use of secondary raw materials in production, innovation and evolution of steel grades — and an efficient circular economy.

Filed in German · English published by the European Commission

The Wirtschaftsvereinigung Stahl welcomes the fact that the European Commission checks the weights and dimensions of heavy-duty vehicles. From the perspective of WV Stahl, harmonisation of the maximum permissible weight to 44 tonnes in the EU could lead to clear benefits for climate protection, transport policy and free movement of goods.

Filed in German · English published by the European Commission

Stand: 08.07.2021 Stellungnahme Richtlinienvorschlag der Europäischen Kommission „Corporate Sustainability Reporting Directive, (CSRD-E)“ Hintergrund Mit dem Green Deal wird u.a. eine Transformation der Wirtschaft in Richtung Nachhaltigkeit angestrebt.

Filed in German · English published by the European Commission

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

We are pleased to take the opportunity to communicate our thoughts on the revision of Directive 2014/95/EU within the framework of the consultation. First, the results of the study mentioned in section D should be evaluated.

Summary The intention of the proposal, in particular as regards the circular dynamics of end-of-life vehicles, is generally supported. Emphasis should be placed on the design of the future rules on the use of recycled materials in accordance with Article 6.

Filed in German · English published by the European Commission

Wirtschaftsvereinigung Stahl welcomes the Commission’s efforts to reform the ELV Directive, including with regard to electro-mobility requirements. The Commission considers three options: • Improving the implementation and enforcement of the ELV Directive without changing its provisions • Targeted amendment of the ELV Directive by aligning it with EU waste legislation • Revision of the ELV Directive through…

Filed in German · English published by the European Commission

Stand: 23.05.2023 Stellungnahme Net-Zero Industry Act Allgemein Allgemeine Bewertung Die Stahlindustrie in Deutschland begrüßt den Vorschlag zum Net-Zero Industry Act (NZIA) als einen wesentlichen Baustein des Green Deal Industrial Plans (GDIP) und als einen ersten konkreten Ansatz, den Green Deal um eine industriepolitische Komponente zu erweitern.

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

According to Wirtschaftsvereinigung Stahl, REACH is an important tool to improve chemical safety. By 2010, the German and European steel industry had already registered most of the substances it placed on the market or imported. The information submitted in the context of the registration allows for a better assessment of the properties of the substances than was the case before the entry into force of REACH.

Filed in German · English published by the European Commission

This statement was submitted by the German Steel Association. The German Steel Association is the voice of the steel industry in Germany, which has set itself the goal of climate-neutral pro-duction by 2045 and thus saving a third of total industrial greenhouse gas emissions.

The steel industry welcomes the revision of the Waste Shipment Regulation (AbfVerbV) and the publication of a draft by the European Commission. However, substantial changes are needed to ensure the effectiveness of the over-ridden rules when moving outside the EU in order to safely achieve the objectives of the EU Circular Economy Action Plan and the EU Green Deal, e.g.

Filed in German · English published by the European Commission

In general, the steel industry supports the European Commission’s efforts towards a European Green Deal and the planned measures to transform into a clean and circular economy. It is also acknowledged that waste management challenges must not be exported to third countries. However, this must not lead to a general ban on exports of waste, as it may make sense to treat waste in third countries.

Filed in German · English published by the European Commission

The forthcoming revision of the Regulation on CO emission standards for new cars and vans provides an opportunity to create lead markets for low-emission steel produced in the EU, which supports the call for a more flexible policy approach to decarbonising road transport. While electrification will be the dominant path to zero-emission mobility, reducing the CO2 footprint of the production phase is the next step.

In the context of this draft amendment to the Regulation on Land Use and Forestry for 2021-2030 (LULUCF), the European Commission proposes to combine a stricter contribution from the LULUCF sector as a further step in reducing greenhouse gas emissions from agriculture beyond CO2 emissions with the land use, land use change and forestry sector, thereby creating a newly regulated land sector that covers emissions and…

Filed in German · English published by the European Commission

23.05.2023 Stellungnahme Reform der Gestaltung des EU-Strommarkts (Änderungen der Verordnung (EU) 2019/943 (Elektrizitätsverordnung), der Richtlinie (EU) 2019/944 (Elektrizitätsrichtlinie) und der Verordnung (EU) Nr.

Filed in German · English published by the European Commission

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

The German Steel Association welcomes the Commissions initiative to facilitate the shipment of certain non-hazardous waste streams for recovery between Member States. The proposal is an important step towards reducing administrative barriers and advancing a genuine Single Market for secondary raw materials.

The revision of the Air Quality Directive and its daughter directives aims to merge them into one directive in order to bring EU air quality standards more in line with WHO recommendations, further improve the regulatory framework and provide more support to local authorities in their efforts to achieve cleaner air.

The Air Quality Directives set common methods for monitoring, assessing and informing about air quality in the European Union and set air quality targets to avoid, prevent or reduce harmful effects on human health and the environment as a whole. The steel industry supports a sustainable policy to protect humans and the environment from the harmful effects of pollutants.

The steel industry welcomes the Commission’s initiative to revise the basic Regulation (EC) No 1907/2006 (REACH) on the European Chemicals Agency (ECHA). In parallel with the ongoing development of chemicals and substance legislation, ECHA has been increasingly assigned tasks and competences.

Filed in German · English published by the European Commission

Opinion for Roadmap “EU environmental law – better access to justice (updating legislation)” Ref. Ares(2020)1406501-06/03/2020 In principle, the Aarhus Convention and the granting of a right to environmental protection are to be supported. However, the limits of European Union primary law and the separation of powers, as well as the provisions of the Aarhus Convention itself, must be respected.

Filed in German · English published by the European Commission

A recently carried out suitability test (assessment) of the EU water legislation showed that these legal provisions are complete their purpose, according to the European Commission (COM) on its website ‘Integrated water management — revised lists of pollutants in surface water and groundwater’. The German Steel Federation (WV Stahl) supports this general assessment of the EU requirements in water law.

Filed in German · English published by the European Commission

The steel industry in Germany is operating and supporting an effective and sustainable circular economy in order to use and recover its materials in the most efficient way. The main focus is on the material steel which can be recycled infinite times as well as the recovery of iron from the residues of iron and steel production.

The European steel industry is transforming towards low-carbon production, making steel scrap a critical strategic resource for decarbonisation. As demand for scrap is projected to grow from 88 million tonnes in 2021 to over 100 million tonnes by 2030 , securing domestic scrap availability is essential.

The European steel industry fully supports the Net-Zero Industry Act (NZIA) as a key driver for accelerating clean technology deployment. Steel is an essential material for the EU economy as well as a strategic industrial and net-zero enabling material, indispensable for EU climate neutrality and serving as a core input for solar, wind, hydrogen and grid infrastructure.

The steel industry in Germany promotes the objectives and contents of the existing Industrial Emissions Directive (IED) with its ambitious and clear rules for the permitting and operation of industrial installations.

The establishment of the European Pollutant Release and Transfer Register (E-PRTR) aims to facilitate public access to information on global environmental issues through an appropriate environmental information system.

The German Steel Association (Wirtschaftsvereinigung Stahl) welcomes the European Commissions initiative to reform defence and security procurement. A strong and resilient industrial base is a core prerequisite for defence capability and strategic autonomy; the steel industry is an indispensable pillar of this base.

The 8th Environment Action Program with its long-term vision and the environmental policy priorities pursued together with the Green Deal is intended to support the EU's joint commitment to a “green” recovery and the associated transformation of its economy for a sustainable future. Sustainability and sustainable management are key concerns of steel companies in Germany.