The Circular Metal Association (CMA) and the German Association for Secondary Raw Materials and Waste Management (BVSE) have called on the European Commission to establish a credible European green steel label based on actual emissions performance.
The associations argued that a green steel classification system should focus on low, traceable and verifiable emissions, with the key criterion being the actual carbon footprint of a steel product rather than the production route used or the pace of decarbonization at individual facilities.
Associations reject sliding-scale methodology
CMA and BVSE criticized proposals for a sliding-scale approach that would adjust emissions thresholds according to the proportion of recycled steel used in production. Under the proposed methodology, production routes using higher volumes of recycled steel would face stricter emissions thresholds, while routes relying less on recycled material would be subject to more lenient requirements.
According to the associations, such an approach could allow steel products with higher actual emissions to receive favorable green classifications while imposing tighter requirements on recycling-based production routes that already achieve significantly lower emissions. They argued that a green steel label should reflect actual environmental performance rather than accommodate existing industrial structures.
Recycled steel recognized as key decarbonization tool
The associations emphasized that recycled steel remains one of the most effective and mature methods for reducing emissions in steel production. They noted that increased use of recycled steel reduces demand for primary raw materials, lowers energy consumption and decreases reliance on iron ore- and coal-based steelmaking processes.
CMA and BVSE also warned that the sliding-scale approach could weaken the effectiveness of public procurement programs and lead-market initiatives. According to the associations, placing products with substantially different carbon footprints into similar performance categories could undermine the credibility of the label and increase the risk of greenwashing.
Support for JRC methodology under ESPR
Instead of the sliding-scale system, CMA and BSE expressed support for the methodology developed by the European Commission’s Joint Research Centre (JRC) under the Ecodesign for Sustainable Products Regulation (ESPR). They stated that the JRC framework, which evaluates products based on carbon footprints and comparable environmental performance classes, should be maintained and made more ambitious to better support steel decarbonization efforts.
The associations also stressed that limitations in steel scrap availability should not be used as a justification for weakening green steel classification standards. While acknowledging that scrap resources are finite, they argued that the environmental benefits of recycled steel should continue to be recognized through improved collection, sorting and processing infrastructure, stronger quality standards, recycling-oriented product design and enhanced secondary raw material markets.
Opposition to scrap export restrictions
CMA and BVSE further cautioned against linking discussions on green steel classifications to proposals for restricting steel scrap exports. The associations stated that scrap is a globally important raw material for lower-emission steel production and warned that export restrictions could distort markets, reduce incentives for scrap collection and discourage investment in processing capacity and quality improvements. They urged European policymakers to exclude sliding-scale approaches from green steel definitions, public procurement frameworks, lead-market initiatives and funding programs.
According to CMA and BVSE, a credible European green steel label should be based on actual and verifiable emissions, recognize the role of recycled steel in decarbonization and involve the recycling sector in future methodological discussions. The associations concluded that the sliding-scale approach should not be revised or rebranded, but abandoned entirely.
