• A more granular and specifically refined set of circular economy indicators that do not focus only on member states but also on materials is needed to provide more relevant information on circularity. A more appropriate level of details would allow for assessing the progress in selected monitoring areas.
• The European Commission recognises the steel industry as a priority sector for transitioning to a circular and climate-neutral European economy. Therefore, the EU steel industry considers crucial to include specific indicators concerning ferrous scrap and other waste streams for export and import as a key secondary raw material with significant impact on the circular economy and EU’s strategic autonomy. The current approach with summarized waste categories and by-products is not sufficient to reflect its contribution to the circular economy, as different properties and impacts are needed to be assessed first. The distinction of pre-consumer and post-consumer secondary material flows from different market sectors would also help identify areas which need improvement.
• In this framework, the European steel sector would also favour qualitative and quantitative connections (e.g. Sankey diagrams) between various activities and/or resources in order to have a better and more transparent overview of material losses, circularity and mutual dependence. There might be some indicators for this monitoring missing, but datasets shall be refined in order to serve this purpose.

In conclusion, the European Commission revision is a key starting point, but its effectiveness will depend on available data, granularity of indicators and a sufficient degree of relevance to specific circular economy targets. The EU steel sector looks forward to cooperating with the European Parliament and the European Council for improving the current set of circular economy monitoring indicators.