The continuous reduction of the environmental impact of iron and steel processes and its products is currently being led by three key files being the Circular Economy Act (CEA), the Eco-design for Sustainable Products Regulation (ESPR) and its further implementation and the revision of the Iron and Steel Best Available Techniques Reference Document (BREFs).

The CEA is expected to become one of the key industrial policy initiatives shaping the future competitiveness, resilience, and decarbonisation of the EU economy.

“For the EU steel industry, the Act is particularly important because steel is inherently circular: it is permanent, recyclable, and already one of the most recycled materials in Europe, while steel production already relies significantly on circular material flows.”

The CEA is expected to focus on increasing the availability and efficient use of secondary raw materials and by-products, strengthening EU strategic autonomy, reducing dependencies on imports of virgin raw materials, and supporting clean industrial value chains. This is highly relevant for steel producers, especially considering the growing demand for ferrous scrap driven by decarbonisation and low-carbon steel production pathways. For the EU steel sector, a well-designed CEA linked to broader EU objectives could contribute simultaneously to decarbonisation, resource efficiency, industrial competitiveness, energy savings, and the long-term security of strategic secondary raw materials such as ferrous scrap.

The ESPR is a key EU framework intended to improve the sustainability performance of products placed on the EU market by addressing environmental impacts across their life cycle. For the iron and steel sector, identified among the first intermediate product groups under the framework, the Regulation is expected to introduce requirements related to carbon footprint, recycled content, substances of concern, and information sharing through a Digital Product Passport (DPP). Since the Regulation entered into force in July 2024, the European Commission’s Joint Research Centre has progressed the preparatory study for iron and steel products, including work on representative products, classes of performance, life-cycle assessment (LCA), life-cycle costing (LCC), Digital Product Passport, substances of concern, and recycled content methodologies.

EUROFER contributed to the preparatory process by providing technical input and feedback to JRC documents. The 2025–2030 ESPR Working Plan identifies iron and steel among the priority product groups for the first Delegated Acts. The future requirements are expected to be based on the preparatory study and accompanying impact assessment, with adoption of the Delegated Act currently foreseen around Q4 2026–H1 2027, followed by a transition period before application.

The revision of the Iron and Steel BREF has started in 2026 and will last until 2030. The resulting BAT conclusions will be legally binding for the future permits of our companies, being their licenses to operate. Further improvements to the current iron and steel production processes will be rather limited since our companies have further continuously improved their environmental performances up to a level where there is nearly only high hanging fruit left.

Furthermore, the EU iron and steel sector has started with its needed transformation, being the decarbonisation of the sector. Conditions for doing this transformation are far from being optimal – among others global overcapacity, high energy cost, availability of hydrogen etc. - and business cases are uncertain. What is technically and economically viable in regions outside Europe may not be the case in Europe. The BREF revision process should remain technology neutral whilst respecting the so-called integrated approach targeting only the so-called key environmental issues that are relevant for the sector at stake. EUROFER has serious doubts about the effectiveness of the current revision since it has started too soon to effectively deal with the transformation since no solid/robust data - at least covering few years - will be available.