Ecodesign requirements for iron and steel products

142 submissions in the snapshot (137 from organisations), portal total 142. Feedback list on the portal.

46 of 137 organisation submissions analysed; the model reads them as: opposes 2 supports 4 wants changes 38 2 held back for review (low confidence). 91 without readable text, so not analysed.

• Rockwell Automation Company, USA model reads as: supports source
  • Maintain the scope of the ESPR delegated act strictly limited to intermediate products only.

    This position paper supports maintaining the scope of the ESPR delegated act for iron and steel strictly limited to intermediate products, as defined under Option A of the scope scenarios presented by the Joint Research Centre.

  • Do not extend scope to final products due to exceeding the analytical basis and introducing unaddressed methodological, technical, and enforcement challenges.

    Extending the scope to final products containing steel would exceed the analytical basis of the study and introduce significant methodological, technical, and enforcement challenges that are not addressed in the current evidence base.

  • Reject expansion to final products because product heterogeneity would undermine comparability and legal robustness of requirements.

    Including final steel containing products within the scope of the delegated act would therefore undermine comparability and risk producing requirements that are not technically meaningful or legally robust.

• VDMA Business association, DEU; register: Trade and business associations model reads as: wants changes source
  • Restrict the scope of the Delegated Act exclusively to intermediate iron and steel products placed on the market.

    Against this background, VDMA advocates for a clear limitation of the Delegated Act (DA) on iron and steel to intermediate1 steel and iron products placed on the market.

  • Keep the Digital Product Passport static and avoid cascading DPP obligations along downstream manufacturing chains.

    We therefore support a static Digital Product Passport and static data under the Delegated Act on iron and steel.

  • Exclude final products, components, spare parts, and assemblies from the scope of the Delegated Act.

    Final products (e.g., industrial machinery), components (e.g., electric motor), spare parts (e.g., steel brackets or housing) and assemblies (e.g., bearings) containing steel or iron must remain outside the scope of the Delegated Act.

• Metal Packaging Europe EA Business association, BEL; register: Trade and business associations model reads as: opposes source
  • Exclude rigid steel packaging from recycled-content requirements under ESPR.

    Exclude rigid steel packaging from recycled-content requirement under ESPR.

  • Avoid additional packaging-specific information, Digital Product Passport or substances obligations where these are already governed by the PPWR and other EU legislation.

    Avoid additional packaging-specific information, Digital Product Passport or substances obligations where these aspects are already governed by the PPWR and other EU legislation.

  • Assess circularity at system level and prioritize measures that increase collection, sorting and high-quality recycling of steel packaging.

    Assess circularity at system level and prioritise measures that increase collection, sorting and high-quality recycling of steel packaging.

• BDE Federation of the German Waste, Water and Circular Economy Management Industry Business association, DEU; register: Trade and business associations model reads as: wants changes source
  • Establish classification strictly based on product carbon footprint without sliding scale linking to scrap content.

    Classification of 'green steel' strictly based on the Product Carbon Footprint on a cradle-to-gate basis. No sliding scale linking the permissible emission threshold to scrap content.

  • Establish a binding reduction pathway for emission thresholds in the delegated act.

    The delegated act defining green steel should establish a binding reduction pathway for the emission thresholds.

  • Set significantly more ambitious JRC class definitions to drive steel industry transformation.

    The JRC's proposed class definition must be significantly more ambitious to drive the transformation of the steel industry.

• German Confederation of Skilled Crafts and Small Business (ZDH) Business association, DEU; register: Trade and business associations model reads as: wants changes source
• Schneider Electric Company, BEL; register: Companies & groups model reads as: wants changes source
  • Limit ecodesign requirements for iron and steel to intermediary products only.

    we call the European Commission to limit Ecodesign requirements for iron and steel products to intermediary products only.

  • Avoid requirements focused narrowly on steel production that could create design trade-offs limiting technical performance and safety of electrical products.

    A limited focus on steel production may result in unforeseen design trade-offs, potentially limiting technical performance for electrical products;

  • Consider upstream and downstream market maturity and supply availability before expanding scope, given uncertain policy outcomes.

    A lack of upstream and downstream market maturity including supply availability risk uncertain policy outcomes.

• Julius Blum GmbH Company, AUT model reads as: wants changes source
  • Harmonize product carbon footprint methods and data quality requirements before using PCFs for regulatory performance classes or thresholds.

    Product carbon footprints (PCFs) should not be used for regulatory performance classes or minimum thresholds before methods, system boundaries and data quality requirements are harmonised.

  • Establish ISO 14067 as the mandatory basis for product carbon footprint calculations with clearly defined methodological and data quality requirements.

    ISO 14067 provides an established framework for product carbon footprinting and should serve as the mandatory basis for PCF calculations.

  • Support established chain-of-custody approaches including mass balance methods for recycled content in complex supply chains.

    For recycled content, we support established chain-of-custody approaches, including mass balance, which are already widely used in complex raw material supply chains.

• ArcelorMittal Company, LUX; register: Companies & groups model reads as: supports source
  • For every steel product placed on the market, transparent information should be available regarding its classification and environmental performance metrics.

    For every steel product placed on the market, transparent information should be available regarding its classification, Product Carbon Footprint (PCF), and Recycled Content (RC).

  • Harmonised calculation rules for PCF and RC should be established in alignment with relevant ISO standards.

    To ensure comparability across products and manufacturers, harmonised calculation rules for both the PCF and RC should be established in alignment with relevant ISO standards.

  • The system boundary for greenhouse gas emissions accounting should extend from raw material extraction to the completion of hot rolling.

    Limiting the system boundary to the completion of hot rolling provides an appropriate balance between environmental relevance and practical feasibility.

• EFF - European Foundry Federation NGO, ESP; register: Trade and business associations model reads as: wants changes source
  • Castings should be included within the scope as finished components, since the foundry is the point where environmental footprint is determined.

    It follows that the foundry is the point at which the environmental footprint of the component is determined, and measurement placed anywhere else measures something other than the product.

  • Imported components should be subject to the same measurement, verification and disclosure obligations as European producers.

    A framework that imposes measurement, verification and disclosure obligations on European producers while leaving the imported component outside its scope does not reduce emissions. It relocates them, at the expense of the installations that bear the cost of compliance.

  • Requirements must be verifiable and physically grounded so that operators who have genuinely invested are not undercut by paper-based claims.

    Requirements must be verifiable and physically grounded, so that operators who have genuinely invested are not undercut by those who have only reallocated attributes on paper.

• SUEZ Company, FRA; register: Companies & groups model reads as: wants changes source
  • Integrate both pre-consumer scraps and post-consumer scraps explicitly in the definition of green steel.

    SUEZ asks for integrating both pre-consumer scraps and post-consumer scraps in the definition of 'green steel'.

• Stegra Company, SWE; register: Companies & groups model reads as: wants changes source
  • Establish an ambitious definition of low-carbon steel based on the same methodology as the voluntary label that incentivizes decarbonized production technologies and enters into force simultaneously with the IAA.

    The IAA should clearly define "low-carbon steel" either within the regulation itself or through a delegated act. This definition should be based on the same methodology used for the voluntary label. It should be sufficiently ambitious, reflecting climate performance levels achieved through substantial investments in decarbonized production technologies.

  • Introduce a voluntary label framework with performance classes A through F based on GHG intensity and recycled content in a new Article 10 of the regulation.

    Stegra therefore recommends introducing such a label framework in a new Article 10 of the proposal.

  • Set minimum quota requirements for low-carbon steel in public procurement and support schemes that increase over time based on projected supply.

    Quotas should start at a realistic level and increase over time, based on projected supply.

• WWF EPO NGO, BEL; register: Non-governmental organisations, platforms and networks and similar model reads as: wants changes source
  • Exclude fossil fuel-based steel production, particularly coal-based blast furnaces, from best-performing label classes and green procurement eligibility.

    fossil fuel-based steel production, in particular new coal-based blast furnace installations, should not be eligible for the best-performing label classes or for any category used to qualify for green public procurement or public support.

• Ministry of Economic Development and Technology Public authority, POL model reads as: wants changes source
  • Use average EU energy mix as reference value for calculating energy carbon footprint instead of national energy mix.

    PL proposes to use average EU energy mix as a reference value when calculating the energy carbon footprint.

  • Define low-carbon steel based on wider spectrum of environmental, social and corporate governance criteria, not only carbon dioxide emissions.

    Furthermore, PL is of the opinion that the definition of low-carbon steel should not be based only on aspects related to carbon dioxide emissions, but it should cover a wider spectrum of criteria related to environmental, social and corporate governance aspects.

  • Carefully assess whether 18-month transition period is sufficient and evaluate disproportionate impact on SMEs with fewer resources to adapt.

    The implementation of the policy measures considered in the impact assessment may be particularly burdensome for SMEs, which have fewer resources to adapt to the changes than large entities.

• Climate Group (SteelZero initiative) NGO, GBR; register: Companies & groups model reads as: wants changes source
  • Set ambitious thresholds that reflect near-zero steel production aligned with EU climate objectives.

    The top performance class must reflect near-zero steel production, aligned with EU climate objectives.

  • Adopt a sliding-scale approach based on CO2e intensity and recycled content to ensure technology neutrality.

    A CO₂e intensity- and recycled content-based sliding scale is the only fair way to incentivise all decarbonisation pathways - scrap-based, hydrogen-based or renewable-powered - equally.

  • Finalise and implement the ESPR Delegated Act by 2027 to create functioning lead markets.

    We call on the Commission and the JRC to finalise and implement the ESPR Delegated Act, ensuring a functioning certification system and regulation for lead markets by 2027.

• FEDERREC Business association, FRA; register: Trade unions and professional associations model reads as: wants changes source
  • Adopt the JRC methodology for defining low-carbon and green steel.

    À ce jour, FEDERREC considère que l'approche méthodologique développée par le Centre commun de recherche (JRC) dans le cadre des travaux préparatoires à l'ESPR constitue la meilleure voie à suivre.

  • Set more ambitious performance class thresholds with only the top 10% of steel products in classes A and B.

    FEDERREC appelle donc à des classes de performance plus ambitieuses. Seuls les 10 % des produits sidérurgiques les plus durables devraient relever des classes A et B

  • Reject sliding-scale methodology as greenwashing that undermines decarbonization incentives.

    Conformément aux positions publiées précédemment, FEDERREC souhaite rappeler que la méthodologie fondée sur une échelle progressive (« sliding scale ») n'est rien d'autre que du « greenwashing ».

• Mission Possible Partnership NGO, GBR; register: Non-governmental organisations, platforms and networks and similar model reads as: wants changes source
  • Expand requirements beyond partial public procurement and support schemes to cover all relevant public spending and all products placed on the market.

    Expand coverage: extend requirements beyond partial public procurement and support schemes to cover all relevant public spending and to all products placed on the market.

  • Increase low-carbon percentage requirements in products, aiming to match capacity of clean production projects already at Final Investment Decision, for example 40% by 2030 for steel.

    Raise thresholds: increase low-carbon % requirements in products from current levels, aiming to at least match the capacity of clean production projects already at FID. For example, expanding coverage all products placed on the market and increasing the % required to 40% by 2030 for steel would create a demand volume that matches the total clean primary steel capacity at FID.

  • Introduce voluntary carbon intensity labels with performance-based classification system using A-F classes based on product-level emission intensity.

    Introduce voluntary carbon intensity labels, starting with steel. Reintroduce the performance-based classification system, based on a sliding scale approach (as in the previously leaked IAA versions), with A-F classes based on product-level emission intensity.

• Climate Leadership Coalition behalf of Near-Zero Emissions Steel Initiative NGO, FIN; register: Trade and business associations model reads as: wants changes source
  • Set thresholds that clearly separate low-carbon and near-zero emission steel from conventional fossil-based production to create lead market signals.

    it should set thresholds that clearly separate low-carbon and near-zero emission iron and steel from conventional production.

  • Apply different tailored methodologies for carbon steel and stainless steel due to their fundamentally different emissions profiles and drivers.

    Different steel product groups have fundamentally different emissions profiles, so the ESPR label should apply tailored methodologies

  • Follow a sliding-scale approach for carbon steel aligned with the Low Emission Steel Standard rather than the JRC lifecycle approach.

    The ESPR environmental performance requirements should follow a sliding-scale approach aligned with the Low Emission Steel Standard (LESS), rather than the JRC's lifecycle approach.

• Bayerischer Handwerkstag e.V. (BHT) Business association, DEU; register: Trade and business associations model reads as: wants changes source
  • Exempt handcrafted individual items and small series from Digital Product Pass requirements.

    Handwerkliche Einzelanfertigungen und Kleinserien sind ausdrücklich von der Pflicht zur Erstellung eines eigenen DPP auszunehmen.

  • Conduct concrete investigation into impacts on SMEs, competitiveness, compliance costs and administrative burden in the impact assessment.

    Aus Sicht des Bayerischen Handwerks ist es entscheidend, dass in der Folgenabschätzung den Auswirkungen auf KMU, insbesondere im Hinblick auf ihre Wettbewerbsfähigkeit, den entstehenden Befolgungskosten und anfallenden Verwaltungsaufwand, besondere Aufmerksamkeit gewidmet wird.

  • Integrate existing established standards such as EN material test certificates into the DPP to digitalize existing data.

    Um die Digitalisierung vorhandener Daten zu fördern und einen Mehrwert für Betriebe zu schaffen, sollte der DPP bekannte und bewährte Nachweise wie EN-υτφτψ-Zeugnisse integrieren.

• APPLiA Home Appliance Europe Business association, BEL; register: Trade and business associations model reads as: wants changes source
  • Limit scope to iron and steel intermediate products, excluding final products and components.

    The scope of the Delegated Act should be limited to iron and steel intermediate products placed on the EU market. It should not extend, whether directly or through a transfer-of-responsibility mechanism, to final products or to the components and spare parts used in their manufacture.

  • Conduct dedicated assessment of interactions with EU Emissions Trading System, Carbon Border Adjustment Mechanism, and product-specific ecodesign requirements.

    Before any extension of scope is contemplated, the Commission should carry out a dedicated assessment of how this measure interacts with the EU Emissions Trading System (ETS), the Carbon Border Adjustment Mechanism (CBAM), and product-specific ecodesign requirements.

  • Do not introduce Substances of Concern concept; keep REACH Regulation as sole regulatory framework.

    The Substances of Concern (SoC) concept should not be introduced under the ESPR. The REACH Regulation should remain the sole regulatory framework for the restriction and disclosure of substances in articles.

• Steel For Packaging Europe Business association, BEL; register: Trade and business associations model reads as: opposes source
• Climate Action Network (CAN) Europe NGO, BEL; register: Non-governmental organisations, platforms and networks and similar model reads as: wants changes source
  • Align the green and low-carbon steel label with EU climate targets for 2040 and 2050.

    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 investments in real decarbonisation solutions rather than encouraging the status quo.

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

  • Follow a science-based transparent process without industry bias and with inclusive stakeholder participation.

    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.

• Volkswagen AG Company, DEU; register: Companies & groups model reads as: wants changes source
  • Reject mandatory material-use quotas for the automotive industry.

    As a matter of principle, we reject mandatory material-use quotas for the automotive industry, as the Emissions Trading System already regulates the decarbonization of materials.

• bauforumstahl e.V. Sohnstraße 65 40237 Düsseldorf Business association, DEU; register: Trade and business associations model reads as: wants changes source
  • Define CO2-reduced steel products based on GWP-total limits across life-cycle modules A1 to A3 according to DIN EN 15804+A2 in relation to scrap content.

    Das angebotene Stahlmaterial gilt als CO₂-reduziert, wenn das in der EPD ausgewiesene GWP-total für die Module A1 bis A3 die nachfolgende bauforumstahl-Linie nicht überschreitet.

  • Require proof of environmental performance via valid Environmental Product Declarations (EPDs) according to DIN EN ISO 14025 and DIN EN 15804+A2.

    Der Nachweis ist durch eine gültige Umwelt-Produktdeklaration, EPD, nach DIN EN ISO 14025 und DIN EN 15804+A2 zu führen.

  • Permit recognized alternative evidence such as a certified product carbon footprint or LESS category C or better.

    Ein LESS-Zertifikat, vorzugsweise Kategorie C oder besser, gilt als alternativer Nachweis.

• RTE is the French electricity transmission system operator, managing over 105,000 km of high and extra-high voltage lines and more than 50 interconnections. RTE does not purchase steel, but rather finished products made of steel or containing steel (B2B). Company, FRA; register: Companies & groups model reads as: wants changes source
  • Clear requirements on the carbon footprint and recycled content of iron and steel products should be based on internationally recognised standards.

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

  • Access to primary data across the entire iron and steel value chain should be prioritised.

    RTE calls for prioritising access to primary data based on international recognised standards across the entire iron and steel value chain

  • The initiative must be accompanied by appropriate enforcement measures to safeguard effective decarbonisation and European competitiveness.

    This initiative must be accompanied by appropriate enforcement measures to safeguard effective decarbonisation and European competitiveness

• Transport & Environment NGO, BEL; register: Non-governmental organisations, platforms and networks and similar model reads as: wants changes source
  • From 2035 onwards, only fossil-free primary steel should qualify for low-carbon steel credits.

    Focus the mechanism on the cleanest steel pathways. From 2035 onwards, only fossil-free primary steel should qualify.

  • The Commission should adopt a clear methodology under the ESPR and secondary legislation by the end of 2026 to define low-carbon steel.

    Define eligible low-carbon steel strictly and quickly. The Commission should adopt a clear methodology under the ESPR and secondary legislation by the end of 2026 to define "low-carbon" steel, in order to give investors and carmakers regulatory certainty.

  • Primary steel should be prioritised and combined with post-consumer scrap in the credit calculation methodology.

    Primary steel should be prioritised, combined with post-consumer scrap.

• Future Cleantech Architects NGO, BEL model reads as: wants changes source
  • Include direct electrification routes like molten oxide electrolysis and iron ore electrowinning in assessments of future steel production pathways post-2035.

    These electrification pathways represent promising long-term options, post-2035, for primary iron production in regions with abundant low-cost clean electricity and deserve to be taken into consideration when assessing future steel production pathways.

  • Adopt a sliding scale approach for the steel label based on verified GHG intensity and scrap content rather than route-based distinctions.

    FCA views the sliding scale approach, like the one proposed by ResponsibleSteel (Figure 1), as the most sensible option, evaluating steel production based on verified GHG intensity and the share of scrap content, rather than relying on route-based distinctions.

• Bellona Europa NGO, BEL; register: Non-governmental organisations, platforms and networks and similar model reads as: wants changes source
  • Ensure the label significantly differentiates between best and worst performers rather than clustering most EU production in top classes.

    A distribution in which the great majority of EU production already sits in the top two classes cannot satisfy either requirement, because there is no significant improvement left to signal within the green band.

  • Set performance thresholds anchored to quantified 1.5°C-compatible declining trajectories rather than current market distribution.

    Thresholds anchored to a 1.5°C-compatible trajectory: Credible schemes set out explicit, quantified declining thresholds rather than describing today's market.

  • Extend GHG accounting coverage to Scope 1, 2 and upstream Scope 3 using CO2-equivalent across all greenhouse gases.

    Coverage should extend to Scope 1 and 2 plus upstream Scope 3, expressed as CO₂-equivalent across all greenhouse gases rather than CO₂ alone.

• Carl Zeiss AG Company, DEU; register: Companies & groups model reads as: wants changes source
  • Introduce proportionality thresholds comparable to those used under CBAM to avoid disproportionate administrative burden for low-volume imports.

    In addition, consideration should be given to introducing proportionality thresholds comparable to those used under CBAM.

• Nickel Institute Business association, CAN; register: Self-employed individuals model reads as: wants changes source
  • Focus initial DPP requirements on data that is available, verifiable and actionable.

    The first generation of DPPs should focus on a limited number of data elements that are already supported by mature methodologies and available within existing company systems.

  • Use the DPP as a tool for regulatory simplification rather than adding another reporting layer.

    The DPP should become a vehicle for regulatory simplification rather than an additional reporting layer.

  • Align DPP implementation timelines with regulatory readiness to avoid feasibility risks.

    The current implementation timeline creates uncertainty because key elements of the future DPP ecosystem remain under development.

• European Steel Processors Associations (ESPA) Business association, BEL; register: Trade and business associations model reads as: wants changes source
  • Use verified product-level PCF as the primary climate-performance indicator.

    Use verified product-level PCF as the primary indicator of climate performance, based on a harmonised and transparent methodology applied consistently across all production routes.

  • Keep recycled content separate as a measurable indicator rather than adjusting PCF.

    Treat recycled content as a separate and measurable product-level indicator, rather than incorporating circularity into, or using it to adjust, the Product Carbon Footprint.

  • Prioritize verified PCF information over simplified A-E performance classifications.

    Prioritize verified product-level PCF over simplified performance classes.

• German Steel Association Business association, DEU; register: Trade and business associations model reads as: wants changes source
  • Cover a broader range of intermediate steel products beyond the five product groups proposed.

    The classes of performance must cover the broadest possible range of products. A reduction to only five product groups, as proposed in the JRC report, is not sufficient

  • Apply sliding-scale for product groups with high EAF market share and non-sliding scale for others based on 75% threshold.

    The classes of performance should differentiate between product groups using a sliding-scale threshold approach and those using a non-sliding scale, with the 75% EAF market production share serving as the guiding criterion

  • Ensure transformation pathways are realistic for companies investing in DRI-EAF and decarbonization technologies.

    Companies investing billions of euros into DRI-EAF, new heating furnaces or other transformation projects must have a realistic pathway to achieve lead-market relevant classes.

• MedTech Europe Business association, BEL; register: Trade and business associations model reads as: wants changes source
  • Ensure ecodesign requirements maintain full consistency with Medical Devices Regulation and IVDR requirements.

    Ensures full consistency with the Medical Devices Regulation (MDR) and the In Vitro Diagnostic Medical Devices Regulation (IVDR);

  • Keep the scope of the initiative limited to main intermediate iron and steel products.

    Maintains the scope of this initiative strictly on the main intermediate iron and steel products;

  • Ensure compliance obligations for ecodesign requirements remain with steel producers and material suppliers.

    Ensures that compliance obligations arising from ecodesign requirements remain with steel producers and material suppliers;

• voestalpine AG Company, AUT model reads as: wants changes source
  • Allow flexibility within physical boundaries, particularly for sites operating parallel steelmaking processes, using a mass balance approach at site level.

    Flexibility is required within the physical boundaries (scope), especially when different steelmaking processes are operated in parallel on one site. Based on the EU ETS Monitoring Regulation a there so called "mass balance approach", at least on site level, should be followed.

  • Clarify how individual products or product groups will be identified in detail and how uncovered products will be treated to ensure legal certainty and predictability.

    Please, clarify how individual products or product groups will be identified in detail and how products not being covered will be treated in order to allow for legal certainty and predictability.

  • Provide a specific Digital Product Passport for intermediary products, including the possibility to transmit voluntarily additional information for effectiveness and efficiency.

    Please, provide for a specific DPP also for intermediary products, especially iron and steel, including the possibility to transmit voluntarily additional information in order to allow for legal certainty, predicatability and best possible effectiveness and efficiency.

• Fundación Ecología y Desarrollo NGO, ESP; register: Non-governmental organisations, platforms and networks and similar model reads as: wants changes source
  • Set threshold between classes B and C at 0.4 tCO2e/t and ensure first two classes include only fossil-free production routes.

    The threshold between classes B and C should be set at 0.4 tCO2e/t, and the first two classes must include only fossil-free production routes.

  • Set installation-specific minimum environmental performance threshold to exclude worst products by carbon intensity and target the BF-BOF route.

    The minimum environmental performance threshold (MEPT) should already exclude the worst products by carbon intensity from the Single Market. It should be installation-specific and target the BF-BOF route.

  • Complement information requirements with missing product aspects including energy use, water and air impacts, and waste generation beyond current focus.

    While we support the selected product aspects, other equally important ones (energy use, impacts on water and air, and waste generation) are missing.

• Siemens Energy Company, DEU; register: Companies & groups model reads as: wants changes source
  • Exempt or provide special treatment for magnetically highly efficient GOES grades from mandatory carbon-footprint thresholds.

    Siemens Energy proposes that magnetically highly efficient GOES grades should either be exempted from minimum carbon-footprint thresholds or be subject to a specific treatment under the ESPR Delegated Act.

  • Exclude high-purity GOES from mandatory recycled-content minimum requirements due to electrical performance conflicts.

    Siemens Energy proposes that high-purity GOES should be excluded from mandatory recycled-content minimums.

  • Apply information-only requirements instead of mandatory thresholds for GOES.

    For GOES, Siemens Energy recommends applying information-only requirements.

• thyssenkrupp Steel Europe AG Company, DEU; register: Companies & groups model reads as: wants changes source
  • Use a CO2 intensity and recycled content-based sliding scale system rather than static thresholds for steel decarbonisation.

    We recommend a CO2e intensity- and recycled content-based sliding scale (steel decarbonisation scale) rather than a purely static threshold system.

  • Allow companies to report differentiated product values for integrated production sites within the ESPR framework with transparent methodology.

    Companies should be allowed to report these differentiated product values within the ESPR framework, provided that the underlying methodology is transparent, verifiable and limited to physically connected production processes.

  • Base recycled content definition and calculation methodology on ISO 14021 standard.

    For the calculation of recycled content, we recommend basing the definition and calculation methodology on established standards, in particular ISO 14021.

• Systemiq Company, GBR; register: Companies & groups model reads as: wants changes source
  • Separate the standard for ore-based ironmaking from steelmaking and certify each on its own terms.

    This paper proposes a way out of the impasse: separate the standard for ore-based ironmaking from the standard for steelmaking and certify each on its own terms.

  • Certify primary iron emissions intensity separately to target the largest source of emissions.

    By certifying the emissions intensity of primary iron separately from the emissions of the steelmaking step, the sector can target the largest source of emissions without forcing scrap-based and ore-based producers into a single contested benchmark

  • Have iron carry its own certified emissions grade at the point it enters a steel mill.

    In practice, this means iron would carry its own certified emissions grade at the point it enters a steel mill, and steelmakers would be judged solely on the emissions they add from that point on.

• Bayerisches Staatsministerium für Umwelt und Verbraucherschutz Public authority, DEU model reads as: wants changes source
• Environmental Coalition on Standards NGO, BEL; register: Non-governmental organisations, platforms and networks and similar model reads as: wants changes source
  • Implement classification using a sliding scale with more classes at higher recycled content.

    In our concept, reported below, we reduce the amount of classes that correspond to products having a higher share of recycled content, i.e., at higher recycled content only classes are available.

  • Develop differentiation for long and flat steel products based on EN 10079:2007 standard definitions.

    Alternatively, the Commission could develop a differentiation applied to long and flat steel products' level, building on the definitions of 'flat and long' products found in standard EN 10079:2007 - Definition of steel products.

  • Ensure the labeling approach covers a broader market scope to prevent confusion for excluded products.

    ECOS warns that the current approach proposed by the JRC based on a market segmentation into 5 different labels with a scope of less than 50% of the total placement on the market risk creating confusion and uncertainty (e.g., for the products currently excluded).

• LESS AISBL Business association, BEL; register: Trade and business associations model reads as: supports source
  • Establish a European steel classification and labelling system that creates transparency and supports decarbonization of the steel industry.

    A European steel classification and labelling system should create transparency for customers while providing a robust framework that supports the decarbonisation of the steel industry.

  • Calculate product-specific greenhouse gas emissions using harmonised system boundaries extending from raw material extraction through completion of hot rolling.

    For classification purposes, specific greenhouse gas emissions should be calculated using a harmonised system boundary extending from raw material extraction to the completion of hot rolling.

  • Establish harmonised calculation rules for Product Carbon Footprint and Recycled Content aligned with relevant ISO standards for comparability.

    To ensure comparability across products and manufacturers, harmonised calculation rules for both the PCF and RC should be established in alignment with relevant ISO standards.

• The Japan Iron and Steel Federation Business association, JPN model reads as: wants changes source
  • Ensure BF-BOF route progressive emissions reductions are appropriately recognized within the framework during the transition.

    The BF-BOF route will therefore remain necessary during the transition towards decarbonization, and its progressive and additional emissions reductions should be appropriately recognised.

  • Introduce indicators measuring actual emissions reductions achieved rather than focusing solely on recycled content or absolute PCF values.

    Rather than focusing solely on recycled content or absolute PCF values, it is important to introduce indicators that assess the actual emissions reductions achieved through decarbonisation investments.

• Ecologistas en accion NGO, ESP; register: Non-governmental organisations, platforms and networks and similar model reads as: wants changes source
  • Producers must provide clear, reliable, harmonized information on carbon footprint, energy consumption, water use, and scrap composition.

    Producers should therefore provide clear, reliable and harmonised information on the carbon footprint, energy consumption and water use associated with steel products in order to support informed decision-making and reduce environmental impacts. Information on the composition of the scrap used is equally important, as it is essential for improving recyclability and strengthening circularity.

  • Steel buyers must have access to information on scrap origin and whether it derives from pre-consumer or post-consumer sources to promote higher-quality recycling.

    Steel buyers should have access not only to information on the final composition of the product, including its recycled content, but also to information on the origin of the scrap and whether it is derived from pre-consumer (post-industrial) or post-consumer sources.

  • Digital Product Passport and supporting data infrastructure must be interoperable, shared and easily accessible to facilitate information exchange and transparency.

    The Digital Product Passport and the supporting data infrastructure should be interoperable, shared and easily accessible in order to facilitate information exchange, improve market transparency and support informed purchasing decisions.

• Circularise Company, NLD model reads as: supports source
  • Maintain traceable material data across transformations as EU regulatory instruments begin to rely on product-level information.

    The central implementation question is whether that information will remain

• UNESID. spanish steelmaking and steel transformation association Business association, ESP; register: Trade and business associations model reads as: wants changes source
  • Develop a harmonised methodology for carbon accounting to support credible emission reductions and provide clear demand signals.

    A harmonised methodology can support credible reductions and demand signals.

  • Avoid imposing rigid scrap quality legislative requirements as these would require inefficient processes and increase preprocessing costs.

    An legislative demand upon scrap quality would require inefficient processes which would increase the cost of the preprocessing.

  • Recognize that alloying elements such as nickel, chromium and molybdenum provide specific properties and are recovered through correct scrap management, not hindering recycling.

    Alloying elements such as Ni, Cr or Mo are not "substances hindering recycling"; they provide specific properties and are recovered through correct scrap sorting and melt-shop management.