Ecodesign requirements for iron and steel products

84 submissions in the snapshot (76 from organisations), portal total 84. Feedback list on the portal.

76 of 76 organisation submissions analysed; the model reads them as: opposes 1 supports 8 wants changes 52 15 held back for review (low confidence).

• The International Council on Clean Transportation NGO, DEU; register: Think tanks and research institutions model reads as: supports source
  • Performance classes should be designed solely on emission intensities of EU steel production.

    the performance classes would have to be designed solely on emission intensities of EU steel production

  • Reserve the best performance classes (A and B) for fossil-free steel.

    the best classes (A and B) can be reserved for fossil-free steel

  • Establish periodic revisions of class thresholds to reflect industry improvements.

    periodic revisions of the classes thresholds would have to be foreseen to mirror the improvements of the steel industry

• Bellona Europa NGO, BEL model reads as: wants changes source
  • Anchor top performance classes to demonstrated near-zero technologies rather than production volume share.

    the top classes of performance must be anchored to demonstrated near-zero technologies rather than to a share of current production volume

  • Calibrate thresholds to products placed on EU market with absolute backstop preventing better classifications based on market changes alone.

    thresholds must be calibrated to products placed on the EU market, since that is what the ESPR governs, with an absolute backstop ensuring a product moves into a better class only when its own emissions fall

  • Require physical correlation and hourly matching for electricity accounting instead of unbundled guarantees of origin.

    unbundled guarantees of origin that are not physically delivered should not be accepted, as they allow declared Scope 2 to be lowered at negligible cost without changing the electricity actually used

• Recycling Europe aisbl Business association, BEL; register: Trade and business associations model reads as: wants changes source
  • Make performance classes substantially more ambitious to ensure only best-performing products receive highest classifications.

    Recycling Europe therefore calls for substantially more ambitious performance classes, ensuring that only the best-performing products benefit from the highest classifications

  • Oppose sliding-scale methodologies that favor primary steelmaking and disincentivize recycled material use.

    Our feedback also reiterates Recycling Europe's opposition to sliding-scale methodologies, which practically favour primary steelmaking while disincentivising the use of recycled materials

  • Require recycled content to distinguish between pre-consumer and post-consumer materials with policy incentives focused on post-consumer.

    To effectively stimulate circularity, recycled content should distinguish between pre-consumer and post-consumer material, with policy incentives focused on the latter

• European Environmental Bureau NGO, BEL; register: Non-governmental organisations, platforms and networks and similar model reads as: wants changes source
  • Design first two performance classes to reflect best possible performance and remain sparsely populated following Energy Labelling Regulation model.

    the first two classes should reflect the best possible performance levels (art. 65(3) ESPR) and include emerging low-carbon technologies; the share of products included therein should mimic the Energy Labelling Regulation model (EU 2017/1369), meaning that they should remain sparsely populated (e.g. <20% of products, with class A <10%)

  • Set threshold between classes B and C at 0.4 tCO2eq./t and restrict first two classes to fossil-free feedstock production routes.

    the threshold between classes B and C should be set at 0.4 tCO2eq./t and the first two classes should include only production routes based on fossil-free feedstocks

  • Include wider environmental footprint assessment beyond carbon, such as energy use, water and air impacts, and waste generation.

    While supporting the selected product aspects, other equally important ones as energy use, impacts on water and air and waste generation are missing

• Environmental Coalition on Standards NGO, BEL; register: Non-governmental organisations, platforms and networks and similar model reads as: supports source
  • Focus initially on carbon footprint with later complementary requirements for water and energy.

    ECOS supports an initial limitation to carbon footprint, which should later be complemented with water and energy consumption information requirements under the reviews mandated by art. 8(l)

  • Information requirements should cover carbon footprint, substances of concern, and recycled content at batch level without averaging.

    They should cover the carbon footprint, substances of concern, and recycled content at batch level. It is key that information requirements are representative of the narrowest level possible, without possibility to average at the scale of the firm

  • Reduce the transition timeline from 8 years to 4 years for SoC(b) alignment with GHS.

    We do not support the 8 years transition timeline for SoC(b) not yet aligned in GHS; we recommend 4 years transition timeline

• Saint-Gobain PAM Company, FRA; register: Companies & groups model reads as: wants changes source
  • Include cast iron products in the delegated act as intermediate products with measurable indicators and performance classes.

    cast iron products be properly addressed within the iron & steel ESPR delegated act as intermediate product, including measurable indicators (PCF, recycled content) and environmental performance classes

  • Use representative data covering the full range of EU and third-country production routes and decarbonization technologies.

    covering EU and in third countries, the full range of production routes, emerging decarbonization technologies and data derived from the EU ETS database

  • Include cast iron product performance information (durability, repairability, recyclability) in future Digital Product Passport delegated acts.

    information relating to product performance, including durability, service life, repairability, potential for reuse, recyclability, actual circularity, and the presence and release of substances of concern, should be included in the DPP

• Micro company, PRT Company, PRT model reads as: wants changes source
  • Require digital product passports to expose canonical serialisation, cryptographic digest, and signature bound to an identified economic operator for verifiability.

    We suggest the delegated act require that a passport for iron and steel expose three things alongside its content: a canonical serialisation, so that the same data always produces the same bytes; a cryptographic digest computed over those bytes; and a signature bound to an identified economic operator.

  • State a retention horizon explicitly in the act for digital product passport data rather than assuming harmonised standards supply one.

    We suggest the act state a retention horizon explicitly rather than assume a harmonised standard supplies one.

  • Express data requirements at the level of data to be conveyed rather than specific serialisation format to support multiple data models including Asset Administration Shell.

    We suggest the requirements be expressed at the level of the data to be conveyed rather than the serialisation that conveys it, so that an Asset Administration Shell submodel and a JSON-LD passport can both satisfy the same obligation.

• The Japan Refrigeration and Air Conditioning Industry Association (JRAIA) Business association, JPN; register: Trade and business associations model reads as: opposes source
  • Do not extend the scope of ecodesign requirements for iron and steel to final products.

    The scope of the Ecodesign requirements for Iron & Steel should not be extended to final products

  • Conduct further study including the final products industry before any expansion of scope to final products.

    Further study including the final products industry is necessary to expand the application to final products.

• Schneider Electric Company, BEL; register: Companies & groups model reads as: wants changes source
  • Limit ecodesign requirements for iron and steel products to intermediary products only.

    Building on our experience, we call the European Commission to limit Ecodesign requirements for iron and steel products to intermediary products only.

• Tamini Company, ITA model reads as: wants changes source
  • Design ecodesign requirements to account for existing supply chain bottlenecks and limited supplier availability.

    any ecodesign requirements applicable to steel should be designed in a manner that takes existing supply chain bottlenecks into account

  • Provide greater clarity regarding the scope and applicability of requirements to ensure consistent implementation.

    Greater clarity regarding the scope and applicability of such requirements is essential to ensure their consistent implementation

  • Align ecodesign requirements with CBAM Regulation to avoid overlapping economic burdens and trade restrictions.

    Tamini also considers that the eco-design requirements for steel and iron products should be aligned with the CBAM Regulation to avoid overlaps in the event of resolutions that impose economic burdens

• GARANT Maschinenhandel GmbH Company, DEU model reads as: wants changes source
  • Establish standardized data formats, interoperable systems and easy digital reuse of information along supply chains.

    However, this requires standardised data formats, interoperable systems and easy digital re-use of information along the value chain

    machine translation by the Commission, original in DE
  • Make requirements interoperable with existing and future regulatory frameworks to limit administrative burden and avoid double reporting.

    In order to limit the administrative burden on businesses, the requirements of the delegated act should, as far as possible, be made interoperable with existing and future regulatory requirements

    machine translation by the Commission, original in DE
  • Clearly regulate and limit access rights in Digital Product Passports to what is necessary for legitimate purposes.

    Access rights in future Digital Product Passports should therefore be clearly regulated and limited to what is necessary

    machine translation by the Commission, original in DE
• Stegra Company, SWE; register: Companies & groups model reads as: wants changes source
  • Base the framework on expected market availability from projects under construction and credible planned investments, not current market volumes.

    The definition should not be designed primarily around the volumes of low-emissions steel available on the market today.

  • Set the initial procurement quota below 25% rather than lowering the ambition of carbon emissions-performance thresholds.

    If necessary, the initial quota should be set below 25% rather than lowering the ambition of the carbon emissions-performance thresholds.

  • Introduce a substitution multiplier to allow highest-performing classes to count more towards procurement targets.

    A substitution multiplier (introduced in the IAA or the ESPR delegated act) could, for example, allow volumes from the highest-performing classes to count more towards procurement targets than steel that only meets the minimum threshold.

• Luossavaara-Kiirunavaara AB (LKAB) Company, SWE; register: Companies & groups model reads as: wants changes source
  • Performance thresholds must be ambitious and reward first-movers in low-carbon steel production.

    The performance thresholds must be ambitious and reward first-movers;

  • Emissions scope must be considered from cradle to gate in carbon footprint calculations.

    Emissions scope must be considered from cradle to gate;

  • Information in the Digital Product Passport must be comparable, traceable, easy to understand and based on robust verified data.

    Information in the Digital Product Passport (DPP) must be comparable, traceable, easy to understand and based on robust verified data.

• voestalpine AG Company, AUT model reads as: wants changes source
  • Carbon footprint methodology should build on and align existing regulatory frameworks to create one consistent set of precise accounting rules without duplicate reporting.

    The carbon footprint methodology should build on and seek alignment of existing regulatory frameworks to create one consistent set of precise accounting and verification rules to ensure a level playing field and accurate, comparable results without duplicate reporting.

  • Recycled content must be calculated using a robust input-based approach with a clearly harmonised methodology leaving no room for different interpretations.

    ReCo should be calculated using a robust input-based approach that can be based on EN ISO 14021 and EN 45557; however, it is essential that the Commission clearly defines a harmonised methodology, leaving no room for different interpretations and ensuring that declared recycled content values are consistent and comparable across the market.

  • Performance classes should be ambitious, technologically neutral, predictable, and consistent with the whole legal framework.

    Performance classes should be ambitious enough to create lead markets for low-carbon steel and incentivise the decarbonization of all products while remaining technologically neutral, predictable over time and consistent with the whole legal framework, especially with the PCF calculation methodologies used.

• maki Consulting GmbH Company, DEU; register: Companies & groups model reads as: wants changes source
  • Test alternative methodological approaches including continuous benchmarks and explicit primary/secondary production sub-indices.

    An absolute cradle-to-gate Product Carbon Footprint is essential for downstream product accounting. It should not, however, be the sole measure of steelmaking decarbonisation performance because it conflates process improvement with access to a constrained scrap pool. The current approach is argued to invite greenwashing, dis-benefit EU producers, is environmentally ineffective and inefficient. We recommend comparing two alternatives: a continuous benchmark conditioned on scrap share and an explicit system with separate primary/ore-based and secondary/scrap-based sub-indices.

  • Require reporting of all Environmental Footprint impact-category results and EN 15804 indicators from the outset.

    All individual Environmental Footprint impact-category results and downstream-relevant EN 15804 indicators should be reported from the outset.

  • Ensure Digital Product Passport interoperability across multiple EU regulations and product systems.

    Digital Product Passport data must be technically, semantically and organisationally interoperable across the Ecodesign for Sustainable Products Regulation, Construction Products Regulation, Packaging and Packaging Waste Regulation and downstream product systems.

• Ocelářská unie Business association, CZE model reads as: wants changes source
  • Support EUROFER's position on balancing environmental and economic considerations in the Impact Assessment.

    The Czech Steel Union fully supports EUROFER's position.

• Bundesgremium Außenhandel Österreich Business association, AUT; register: Associations and networks of public authorities model reads as: wants changes source
  • Place data delivery obligations exclusively with primary producers.

    We call for the data obligation to lie exclusively with primary producers (the huts principle),

    machine translation by the Commission, original in DE
  • Eliminate parallel reporting obligations to avoid duplication.

    for there to be no double burden as a result of parallel reporting obligations,

    machine translation by the Commission, original in DE
  • Establish realistic transitional periods and test periods without penalties for DPP implementation.

    and for realistic transitional periods and a test period of at least two years without penalties to be introduced for the DPP.

    machine translation by the Commission, original in DE
• BASF Company, DEU; register: Companies & groups model reads as: wants changes source
  • Maintain technology-neutrality and build requirements on existing industrial data systems.

    future requirements should remain technology-neutral, build on existing industrial data systems and avoid disproportionate administrative burden.

  • Harmonize carbon-footprint methodologies and recognize established chain-of-custody approaches.

    Carbon-footprint methodologies require further harmonisation before being used as regulatory benchmarks. For recycled-content accounting, recognised chain-of-custody approaches, including mass-balance systems, should be accepted.

  • Base DPP requirements on existing traceability practices with appropriate granularity and data protection.

    DPP requirements should be based on existing traceability practices, use the lowest feasible granularity level and ensure robust protection of confidential business information through role-based access rights.

• Industrieverband Schneid- und Haushaltwaren e.V. - IVSH Business association, DEU; register: Trade and business associations model reads as: wants changes source
  • Design the Digital Product Passport to be robust, practical and interoperable to reduce duplicate reporting.

    When designed in a robust, practical and interoperable manner, the DPP can become an important enabler for efficiency, simplification and the reduction of duplicate reporting obligations across supply chains

  • Apply a strict 'collect once report once use many times' principle across supply chains.

    the application of a strict "collect once report once use many times" principle

  • Ensure proportionality for SMEs in implementation of sustainability requirements.

    the importance of proportionality for SMEs

• Windmöller & Hölscher SE. Co. KG Company, DEU model reads as: wants changes source
  • Ensure requirements' benefits are proportionate to their collection and administrative burden.

    Die Anforderungen müssen jedoch so ausgestaltet werden, dass ihr Nutzen in einem angemessenen Verhältnis zum Erhebungs- und Verwaltungsaufwand steht

  • Apply proof obligations to export products only if comparable requirements exist in target markets or EU market access is affected.

    Um Wettbewerbsnachteile zu vermeiden, sollten Nachweispflichten für Exportprodukte nur gelten, wenn vergleichbare Anforderungen im Zielmarkt bestehen oder ein EU-Marktzugang betroffen ist

  • Avoid component-level documentation requirements for complex machinery due to unmanageable data burden.

    Bei Windmöller & Hölscher enthalten große Maschinen mehrere zehntausend Stahlkomponenten. Eine Nachweisführung auf Einzelkomponentenebene könnte daher 10.000 bis 20.000 Datensätze bzw. Produktpassreferenzen je Anlage erzeugen

• MINISTRY OF INDUSTRY Public authority, ESP model reads as: wants changes source
  • Expand the scope of representative products to cover the 70% of Spanish production currently excluded.

    this list must be expanded because approximately 70% of Spanish productionparticularly carbon long products manufactured via the electric arc furnace (EAF) routecurrently remains outside these categories

  • Structure classification by steel families with similar characteristics rather than overly specific intermediate products.

    classification should be structured by steel families with similar metallurgical characteristics and footprint profiles

  • Keep top performance classes A and B sufficiently ambitious to drive real decarbonisation investment.

    Class A and B must remain sufficiently ambitious and be associated with real and substantial decarbonisation efforts, ensuring the system drives investment rather than merely describing the status quo

• EFF - European Foundry Federation NGO, ESP; register: Trade and business associations model reads as: wants changes source
  • Include iron and steel castings as intermediate products within the scope of the regulation.

    We ask that castings be addressed within this act as an intermediate product.

  • Define low-carbon steel based on verified emissions intensity of the installation on a cradle-to-gate basis using primary data.

    The threshold should rest on the verified emissions intensity of the installation, on a cradle-to-gate basis and using primary data.

  • Ensure data verified under CBAM or existing Environmental Product Declarations can be reused and align definitions across instruments.

    Data verified under CBAM or existing Environmental Product Declarations must be reusable.

• SUEZ Company, FRA; register: Companies & groups model reads as: supports source
  • Adopt the methodological approach developed by the Joint Research Center for defining green steel in the framework.

    As of today, SUEZ has identified the methodological approach developed by the Joint Research Center (JRC) in the context of the ESPR preparatory work as the best way forward.

  • Establish product carbon footprint as the defining product parameter while avoiding distorting factors and green-washing risk.

    It rightly acknowledges the product carbon footprint as the defining product parameter, thus refraining from introducing any distorting factors and avoiding the risk of green washing.

  • Stimulate uptake of recycled materials to reduce EU dependency on primary raw materials with high environmental footprint.

    Moreover, by stimulating the uptake of recycled materials, it has the potential to reduce the EUs dependency on primary raw materials with a high environmental footprint.

• Terna SpA Other, ITA model reads as: wants changes source
  • Design ecodesign requirements considering existing supply chain bottlenecks and clearly specify their scope and application.

    Therefore, any ecodesign requirements applicable to steel should be designed in a manner that takes existing supply chain bottlenecks into account and should clearly specify their scope and application.

  • Give careful consideration to potential economic impact on end-users, particularly regarding investment capacity for infrastructure deployment.

    Furthermore, when implementing any measures, careful consideration should be given to their potential economic impact on end-users.

• Derichebourg Environnement Company, FRA; register: Companies & groups model reads as: wants changes source
  • Make the performance classes for intermediate steel products more ambitious than currently proposed.

    in its current form, the classes of performance for the selected intermediate steel products are not sufficiently ambitious.

  • Adopt JRC methodology that rewards circularity and uptake of recycled materials while remaining technology-neutral.

    This methodology has several key advantages: it rewards circularity and the uptake of recycled materials, is technology-neutral, and has the potential to drive decarbonization.

• Nickel Institute Business association, CAN; register: Self-employed individuals model reads as: wants changes source
  • Ensure ecodesign requirements reflect the diversity of steel grades and applications including high-performance alloyed steels.

    It is therefore essential that any Ecodesign requirements reflect the diversity of steel grades and applications.

  • Base definitions on technology-neutral and material-neutral lifecycle assessment principles with transparent and verified environmental data.

    The Nickel Institute therefore recommends that any definition be technology-neutral and material-neutral, based on transparent lifecycle assessment principles and verified environmental data.

  • Incentivize high-quality recycling and material retention rather than maximizing recycled content irrespective of performance outcomes.

    Ecodesign requirements should therefore incentivise high-quality recycling and material retention rather than focusing exclusively on maximising recycled content irrespective of performance outcomes.

• BMW Group Company, DEU model reads as: wants changes source
  • Clarify whether vehicle components and the wider automotive supply chain are covered by the vehicle exclusion from ESPR.

    This should be clarified.

  • Ensure the low-carbon steel definition is practical, technology-open, and based on actual CO reductions while avoiding unintended consequences for the automotive value chain.

    The definition must therefore be practical, technology-open and based on actual CO reductions, while avoiding unintended consequences for the automotive value chain.

• Gonvarri Corporacion Financiera Company, ESP; register: Companies & groups model reads as: wants changes source
  • Ensure that sustainability objectives in the ESPR are compatible with effective protection of business confidentiality, trade secrets and free competition.

    we believe it is essential that these objectives are compatible with the effective protection of business confidentiality, trade secrets and free competition within the European market.

• Micro company, BEL Business association, BEL model reads as: wants changes source
  • Design the transition to maintain competitiveness of the entire European value chain, including downstream industries such as electric motor manufacturing.

    this transition must be designed in a way that the competitiveness of the entire European value chain, including downstream industries such as electric motor manufacturing.

  • Avoid strengthening the European steel industry at the expense of downstream manufacturers and provide protection against carbon leakage across the value chain.

    Future regulation should consequently avoid strengthening the European steel industry at the expense of downstream manufacturers and should provide effective protection against carbon leakage across the value chain.

• SIRK NORGE Business association, NOR; register: Trade and business associations model reads as: wants changes source
  • The definition of low-carbon steel should include high post-consumer recycled content to prevent primary material reliance.

    We urge the Commission to ensure that the definition of low-carbon steel includes high post-consumer recycled content to prevent primary material reliance

  • Regulatory frameworks should clearly distinguish between pre-consumer production scrap and post-consumer waste to ensure market incentives support collection and recycling.

    It is critical that regulatory frameworks clearly distinguish between pre-consumer production scrap and post-consumer waste, ensuring that market incentives directly support the collection and recycling of end-of-life products from post-consumer waste

  • Data requirements should target producers, while requirements for collectors and recyclers should focus on workable, batch-level reporting.

    Data requirements should target the start of the product life cycle (producers), while requirements for collectors and recyclers must focus on workable, batch-level reporting

• The Confederation of Swedish Enterprise Business association, SWE; register: Trade and business associations model reads as: wants changes source
  • The delegated act should focus on iron and steel intermediate products as identified in the ESPR Working Plan.

    A clear and proportionate scope is essential. The delegated act should focus on the iron and steel intermediate products identified in the ESPR Working Plan

  • The framework must be interoperable with ETS, CBAM, CPR, CSRD and Environmental Product Declarations.

    In particular, the framework must be interoperable with ETS, CBAM, CPR, CSRD and Environmental Product Declarations

  • The Digital Product Passport should build on existing information rather than create a new reporting layer.

    The Digital Product Passport should build on existing information rather than create a new reporting layer

• Eurovent Business association, BEL; register: Trade and business associations model reads as: wants changes source
  • The scope of the delegated act should be maintained on iron and steel intermediate products only, in line with the ESPR Working Plan.

    maintain the scope of the upcoming ESPR Delegated Act on iron and steel intermediate products only, in line with the ESPR Working Plan

  • DPP obligations should not be extended to final products containing iron or steel at this stage.

    refrain from extending DPP obligations to final products containing iron or steel at this stage

  • Any future consideration of downstream products should be supported by a dedicated impact assessment and meaningful consultation with affected industries.

    ensure that any future consideration of downstream products is supported by a dedicated impact assessment and meaningful consultation with the affected industries

• Polish Steel Association (HIPH) Business association, POL; register: Trade and business associations model reads as: wants changes source
  • A single, harmonised definition of low-carbon steel should be established and consistently applied across all relevant EU legislation.

    one of the key elements of the delegated act should be the establishment of a single, harmonised definition of low-carbon steel, consistently applied across all relevant EU legislation, including the ESPR, the Industrial Accelerator Act, the Construction Products Regulation, the EU ETS and CBAM

  • The Product Carbon Footprint methodology should be harmonised across frameworks to avoid multiple calculations and duplicate reporting obligations.

    the Product Carbon Footprint (PCF) methodology should be harmonised across these frameworks to avoid multiple carbon footprint calculations for the same product and eliminate duplicate reporting obligations

  • The methodology for environmental performance classes should be based on verified industrial data, remain technologically neutral, and assess all steel production routes equally.

    The methodology for environmental performance classes should be based on verified industrial data, be regularly updated and remain technologically neutral, assessing all steel production routes under the same principles

• Asociácia priemyselných zväzov a dopravy Business association, SVK model reads as: wants changes source
  • Clarify whether requirements will apply to steel producers or also to downstream users and component producers.

    We therefore consider it crucial for the European Commission to clarify in a timely manner whether future requirements will be directed primarily at steel and steel intermediates producers or whether they will also be passed on, to a certain extent, to producers, suppliers or buyers of steel components and finished products containing steel.

    machine translation by the Commission, original in SK
  • Align requirements, definitions and methodologies with existing EU regulatory frameworks.

    From the perspective of steel users, we recommend that the upcoming requirements, definitions and methodologies be aligned as much as possible with existing or upcoming EU regulatory frameworks.

    machine translation by the Commission, original in SK
  • Ensure the delegated act does not create disproportionate administrative burden for downstream steel users.

    The envisaged delegated act should bring legal clarity and support the decarbonisation of the steel value chain, while not creating a disproportionate administrative burden for downstream steel users that do not have direct control over primary steel production or over all data in the supply chain.

    machine translation by the Commission, original in SK
• Verband der Automobilindustrie Business association, DEU; register: Trade and business associations model reads as: wants changes source
  • Clarify whether the vehicle exemption covers vehicle components and the entire automotive supply chain.

    Vehicles are excluded from the scope of the ESPR, but it remains unclear whether this exemption also covers vehicle components and the entire automotive supply chain. This should be clarified.

    machine translation by the Commission, original in DE
  • Reject mandatory material use quotas for the automotive industry.

    In principle, we reject mandatory material use quotas for the automotive industry, as the emissions trading system already regulates the decarbonisation of materials.

    machine translation by the Commission, original in DE
  • Support market-based approaches for voluntary accounting of low-carbon materials in CO2 fleet regulation.

    The market-based approach of voluntary accounting for low-carbon materials as flexibility in the CO2 fleet regulation for cars and vans supports the transformation of the automotive industry. We therefore welcome this flexibility.

    machine translation by the Commission, original in DE
• SolarPower Europe NGO, BEL; register: Trade and business associations model reads as: wants changes source
  • Recognize credible market-based renewable electricity procurement mechanisms including PPAs and Guarantees of Origin.

    In particular, the methodology should recognise credible market-based renewable electricity procurement mechanisms, including Power Purchase Agreements (PPAs) and Guarantees of Origin (GOs), subject to appropriate verification and traceability requirements.

  • Build on JRC's electricity hierarchy and allow verified renewable procurement to be reflected in carbon footprints.

    The methodology should therefore build on the JRC's original electricity hierarchy and allow appropriately verified procurement of renewable electricity to be reflected in product carbon footprints, the use of safeguards will be essential to ensure the integrity of renewable energy claims.

• Climate Action Network (CAN) Europe NGO, BEL; register: Non-governmental organisations, platforms and networks and similar model reads as: wants changes source
  • Align the low-carbon steel label with EU climate targets for 2040 and 2050 and existing policy framework.

    Climate integrity and policy consistency: the label needs to be aligned with the EU climate targets for 2040 and 2050 as well as with the existing industrial policy framework.

  • Ensure the label supports real decarbonisation solutions rather than the status quo.

    Credibility: it needs to be supporting investments into real decarbonisation solutions, not encouraging the status quo with current production technologies

  • Ensure drafting is transparent, participatory, science-based and includes all stakeholders without favoring particular routes.

    Transparency: the drafting process and its updates should be transparent and participatory, following a science-based process without endorsing industry-led standards favouring either route, and including all stakeholders such as industries, academia, trade unions and civil society organisations.

• ResponsibleSteel NGO, CAN; register: Non-governmental organisations, platforms and networks and similar model reads as: supports source
  • Require comprehensive emissions reporting covering Scope 1, 2, and 3 to capture upstream raw material and alloying-element emissions.

    The methodology underpinning iron and steel emissions reporting must require reporting of Scope 1, Scope 2, and Scope 3 emissions, so upstream raw material and alloying-element emissions are captured.

  • Adopt a scrap variable scale for the steel label rather than a single recycled-content percentage to reflect differing input-scrap ratios.

    We recommend the steel label incorporate a scrap variable scale, rather than a single recycled-content percentage, reflecting the differing input-scrap ratios achievable considering the heterogeneity in scrap availability.

  • Include broader ESG metrics alongside carbon footprint such as water use, biodiversity, and social-labour indicators.

    We recommend the framework include broader ESG metrics alongside carbon footprint (e.g. water use, biodiversity, social/labour indicators), so operators are not incentivised to optimise carbon at the expense of other sustainability dimensions.

• industriAll Europe Trade union, BEL; register: Trade unions and professional associations model reads as: supports source
  • Ensure the delegated act contributes to decarbonisation, circularity, European industrial capacity and Just Transition for workers.

    The delegated act should contribute not only to decarbonisation and circularity, but also to strengthening European industrial capacity and ensuring a Just Transition for workers

  • Include a strong social dimension in sustainability with workers' rights and social dialogue at the core.

    Sustainability must include a strong social dimension, with quality jobs, workers' rights, social dialogue and industrial sustainability at its core

  • Ensure coherence of the delegated act with the EU's broader industrial policy framework.

    the need for coherence with the EU's broader industrial policy framework

• Iberdrola S.A. Company, ESP; register: Companies & groups model reads as: wants changes source
  • Assess ecodesign requirements within a broader industrial competitiveness framework with affordable energy prices and support for electrification.

    Ecodesign requirements for iron and steel products should not be considered in isolation, but as part of a wider policy framework aimed at strengthening the competitiveness of European industry.

  • Introduce compensation and cost redistribution mechanisms targeted at final consumers alongside ecodesign measures.

    Compensation and/or cost redistribution mechanisms including measures targeted at final consumers

  • Fully recognize renewable Power Purchase Agreements combined with Guarantees of Origin as valid means of demonstrating electricity decarbonisation.

    The carbon footprint methodology will be a central element of the future framework. It should fully recognise renewable Power Purchase Agreements (PPAs) combined with Guarantees of Origin (GOs) as a valid means of demonstrating electricity decarbonisation.

• ASD Europe Business association, BEL model reads as: wants changes source
  • Take due account of the specific characteristics of the A&D sector in developing the requirements.

    we urge the Commission to take due account of the specific characteristics of the A&D sector.

  • Consider sector-specific timelines and pathways for the A&D sector to avoid supply chain disruptions and product obsolescence.

    To ensure that sustainability and circularity objectives can be achieved without unintended consequences on the functioning of the A&D sector, it will be important to consider sector-specific timelines and pathways.

• FEDERREC Business association, FRA; register: Trade unions and professional associations model reads as: supports source
  • Establish an ambitious framework with robust methodology for green steel and transparent information requirements throughout the value chain.

    An ambitious framework under the Ecodesign for Sustainable Products Regulation (ESPR) is essential to decarbonise the steel sector and increase its circuslarity.

    machine translation by the Commission, original in FR
  • Use JRC methodology that values circularity and recycled materials while maintaining technology neutrality.

    This methodology has several major advantages: it values circularity and the use of recycled materials, is technologically neutral and has the potential to drive decarbonisation.

    machine translation by the Commission, original in FR
• The Japan Electrical Manufacturers’ Association（JEMA） Business association, JPN model reads as: wants changes source
  • Do not expand the scope of the delegated act to final products containing iron and steel.

    We believe that the scope of the delegated act should not be expanded to final products containing iron and steel.

  • Any scope expansion must be based on clear product definitions and dedicated impact assessment, while avoiding duplicative requirements.

    Any consideration of such an expansion should be based on clear product definitions and a dedicated impact assessment, while avoiding duplicative requirements.

• DIN Deutsches Institut für Normung e. V. Other, DEU; register: Other organisations, public or mixed entities model reads as: wants changes source
  • European standardization should play a central role in implementing the delegated act.

    European standardization should play a central role in implementing the delegated act

  • European standards should provide technical specifications, test methods and verification procedures for consistent implementation across the Single Market.

    European standards should provide the technical specifications, test methods and verification procedures needed for consistent implementation across the Single Market

• APPLiA Home Appliance Europe Business association, BEL; register: Trade and business associations model reads as: wants changes source
  • The scope of the iron and steel ESPR measure should remain strictly limited to intermediate products.

    the scope of the iron and steel ESPR measure should remain strictly limited to intermediate products

  • The impact assessment should account for competitiveness of EU industry and potential consequences for finished goods markets.

    The impact assessment should properly account for the competitiveness of EU industry, including determining the potential consequences for the market of finished goods on a requirement-by-requirement basis

  • Substance-related restrictions should remain within REACH legislation.

    keeping substance-related restrictions within REACH

• İstanbul Chamber of Industry Business association, TUR model reads as: wants changes source
  • Follow a balanced and phased approach allowing sufficient time for industry adaptation.

    It is expected that the development and implementation of requirements for iron and steel products will follow a balanced and phased approach, allowing sufficient time for industry to adapt.

  • Consider technical feasibility, product diversity, supply chain conditions, standards, investment needs and impacts on competitiveness.

    Particular consideration should be given to technical feasibility, product diversity, supply chain conditions, applicable standards, investment needs and potential impacts on production costs and international competitiveness.

  • Provide appropriate support mechanisms to help with a smooth transition.

    Appropriate support mechanisms would also contribute to a smooth and effective transition.

• Japan Business Council in Europe Business association, BEL; register: Trade and business associations model reads as: wants changes source
  • Avoid data parameters favoring particular production processes and recognize complementary roles of Blast Furnace and Electric Arc Furnace.

    Second, regarding the classification of low-carbon steel, data parameters that structurally favour a particular production process should not be adopted. The framework should recognise the complementary roles of the Blast Furnace (BF) and Electric Arc Furnace (EAF) processes and appropriately reward decarbonisation efforts in the BF process, which remains essential for the production of high-performance steel products.

  • Avoid excessive emphasis on Recycled Content and consider different production routes.

    JBCE also considers that excessive emphasis on Recycled Content may not fully reflect the environmental performance, technical requirements and functional characteristics of different steel products and production routes.

• Climate Leadership Coalition (CLC) behalf of Near-Zero Emissions Steel Coalition NGO, FIN; register: Trade and business associations model reads as: wants changes source
  • Design a framework that rewards early investment in viable breakthrough technologies while remaining dynamic and scalable.

    To ensure these technologies define the future of Europe's steel sector, the ESPR must design a framework that rewards early investment in viable breakthrough technologies, while remaining dynamic and scalable.

  • Avoid weak environmental performance thresholds that would undermine the transition to near-zero solutions.

    Weak thresholds for the steel classes of environmental performance, such as the ones proposed by the Joint Research Centre (JRC) study, risk undermining the transition to near-zero solutions.

  • Develop separate approaches for carbon steel and stainless steel due to fundamental production process differences.

    Due to fundamental differences in the production processes, there needs to be separate approaches for carbon steel and stainless steel in the label.

• Badische Stahlwerke Business association, DEU; register: Companies & groups model reads as: wants changes source
  • Ensure methodologies are technology-neutral and build upon existing regulatory data and verification systems including EU ETS and CBAM.

    Methodologies should be technology-neutral and reflect actual environmental performance. Existing regulatory data and verification systems, including EU ETS and CBAM, should be used wherever possible to ensure consistency and avoid duplicate reporting.

  • Approach minimum recycled-content requirements cautiously, recognizing constraints in scrap availability and quality for EAF-based producers.

    However, minimum recycled-content requirements should be considered cautiously. Scrap-based EAF production already relies structurally on ferrous scrap, while the availability and particularly the quality of suitable scrap are increasingly important constraints.

  • Set Digital Product Passport requirements at product or model level rather than batch or item level to reduce administrative burden.

    For mass-produced long steel and construction products, highly granular batch- or item-level requirements could create considerable administrative burden without corresponding environmental benefits. An appropriate product/model-level approach should therefore be preferred wherever possible.

• Vana Company, NLD model reads as: wants changes source
  • Ensure that sustainability requirements are economically viable for businesses.

    For the sustainable steel to be business-sustainable, there should be serious incentives and not only to the producer, it shall effect the price.

  • Adopt a holistic sustainability approach that goes beyond carbon reduction.

    Manufacturing should be as sustainable as possible but with every aspect, with thoughtful resource uses, sustainable technologies, not limited with CO2 shall lower the negative impact on everything and not harm ecosystems...

  • Include business and economic sustainability of workers in sustainability requirements.

    But also shall help society -not only with eco-friendliness and lower CO2- but also sustainability of businesess, which is sustainability of the peoples economical resources.

• RTE Company, FRA; register: Companies & groups model reads as: wants changes source
  • Establish clear requirements on carbon footprint and recycled content based on international standards.

    RTE calls for clear requirements on the carbon footprint of iron and steel products based on international standards and on the recycled content

  • Ensure environmental performance is measurable, objective, verifiable and comparable across suppliers.

    Defining these requirements is necessary to ensure that environmental performance is measurable, objective, verifiable, and comparable across suppliers for the same functional need

  • Prioritise availability of reliable, transparent, verifiable and harmonised data before implementing performance classes.

    The priority should remain the availability of reliable, transparent, traceable, verifiable and harmonised data across the value chain

• EPEE Business association, BEL; register: Trade and business associations model reads as: wants changes source
  • Ensure greater clarity, sequencing and coherence with existing legislation before requirements can be meaningfully assessed.

    EPEE wishes to highlight a number of areas where greater clarity, sequencing, and coherence with existing legislation are needed

  • Establish legal certainty in the definition of key terms across the regulation.

    EPEE underlines the importance of legal certainty in the definition of key terms

  • Provide clear allocation of compliance obligations across the long and fragmented supply chain.

    a clear allocation of compliance obligations across a long and fragmented supply chain

• POSCO Company, KOR; register: Companies & groups model reads as: wants changes source
  • Phase and implement recycled content rules pragmatically reflecting operational realities.

    Recycled content rules should be phased and pragmatic.

  • Phase DPP requirements with international standard alignment and recognition of equivalent data formats and existing systems.

    DPP requirements should be phased, interoperable and aligned with internationally recognized standards, while allowing the recognition of equivalent data formats and existing systems.

  • Conduct item-by-item economic assessment of each proposed measure including impacts on SMEs and compliance costs.

    POSCO strongly recommends an item-by-item economic assessment of each proposed measure.

• Jernkontoret - Swedish iron and steel producers' association Business association, SWE; register: Trade and business associations model reads as: wants changes source
  • Support harmonised methodologies for environmental reporting across EU legislation to ensure comparability and avoid conflicting results.

    Jernkontoret supports harmonised methodologies for reporting the environmental impact of iron and steel products across relevant EU legislation to ensure comparability, avoid conflicting results and minimise unnecessary administrative burden.

  • Ensure product legislation takes a lifecycle perspective and recognizes that environmental performance depends on application.

    Product legislation must have a life cycle perspective and recognise that the environmental performance of steel depends on its application.

  • Support enabling conditions such as fossil-free energy at competitive costs and efficient permitting.

    It must also be supported by enabling conditions such as fossil-free energy at competitive costs and efficient permitting, to realise these decarbonisation efforts.

• Ministry of Economics of the Republic of Latvia Public authority, LVA model reads as: wants changes source
  • Ensure alignment with CBAM framework, proper treatment of secondary raw materials, avoidance of duplicative data requirements, and proportionate treatment of SMEs and small-series production.

    we raise several considerations regarding alignment with the CBAM framework, the treatment of secondary raw materials, avoidance of duplicative data requirements, and proportionate treatment of SMEs and small-series production.

• ESWET - European Suppliers of Waste-to-Energy Technology Business association, BEL; register: Trade and business associations model reads as: wants changes source
  • The methodology defining low carbon steel should fully reflect the climate benefits of secondary metals, including those recovered from waste-to-energy residues.

    considers it essential that the methodology underpinning the definition of low carbon steel fully reflect the climate benefits of secondary metals, including those recovered from WtE residues

• The European Steel Association (EUROFER) Business association, BEL model reads as: wants changes source
  • Support objectives of transparency, emissions reduction, circularity and lead markets for low-carbon steel.

    EUROFER supports the objectives of improving transparency, reducing greenhouse gas emissions, strengthening circularity, and developing lead markets for low-carbon steel.

  • Ensure Impact Assessment carefully weighs environmental benefits against administrative costs, complexity and competitiveness.

    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.

• Turkish Steel Producers Association NGO, TUR model reads as: supports source
  • Base the ESPR framework on technology neutrality, harmonised methodologies, open and competitive markets, practical transition periods, and equal treatment of Customs Union partners.

    We believe that an ESPR framework based on technology neutrality, harmonised methodologies, open and competitive markets, practical transition periods, and equal treatment of Customs Union partners will make a significant contribution to building stronger, more resilient, and more sustainable industrial value chains across Europe.

• Ministry of Economic Development and Technology Public authority, POL model reads as: wants changes source
  • Apply an appropriate and level methodology for accounting emissions from energy used in steel production.

    To ensure a level playing field for all operators in the EU market, it is essential to apply an appropriate methodology for accounting for emissions from the energy used in the production of iron and steel products.

  • Allow operators to use either EU average energy mix or individual site calculations with guarantees of origin and PPAs.

    the optimal solution would be for all operators to adopt the EUs average energy mix or, alternatively, to calculate emissions from energy consumption at the level of the individual production site, with the option of taking into account guarantees of origin and PPAs.

• Micro company, BEL Business association, BEL model reads as: wants changes source
  • Ensure the methodology properly recognizes the contribution of ferro-alloys as essential inputs to steel production.

    In particular, the contribution of ferro-alloys, which are essential inputs to steel production, needs to be properly recognised.

  • Avoid creating incentives to substitute European-produced inputs with high-carbon imports while strengthening European value chains.

    The methodology should avoid creating unintended incentives to substitute European-produced inputs with high-carbon imports and should contribute to strengthening the competitiveness and resilience of European industrial value chains.

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