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Position Paper
An EU industrial policy providing a strong business case for green investment
in Europe
New global reality requires disruptive thinking and innovative measures
Publication date: 23 February 2023
Executive summary
A thriving European steel industry is crucial for the EU’s strategic autonomy and resilience. However, over the past
decade, the EU has shifted from being a net steel exporter to a major net steel importer, losing 30 million tonnes of
sales on the EU and export markets. Additionally, the EU steel industry has lost 26 million tonnes of steel production
capacity and 25% of its workforce.
The EU is facing a new global reality. To ensure that the EU remains competitive in the middle of the greatest
transformation of the industry towards climate-neutrality, it is essential to adopt disruptive thinking, and innovative
measures. Otherwise competitors such as the US and China, are likely to create a more attractive investment and
production environment for green steel, further threatening the EU’s strategic autonomy. The US Inflation
Reduction Act (IRA) alone will provide at least USD 85 billion of funding for steel production and upstream energy
requirements.
Steel is essential for a climate-neutral economy. Renewables, hydrogen, wind and electric vehicles, are all dependent
on steel. It is estimated that more than
74 million tons of steel will be required for the expansion of renewable
energy generation alone, demonstrating that the foundations of the Net-zero Age are made of steel. A successful
EU industrial policy requires a value chain-based approach, with
steel at the core of the Green Deal Industry Plan and as an
integral part of the Net-Zero Industry Act. To transition steel and other energy-intensive industries
towards carbon neutrality and enhance circularity while ensuring the EU industry’s competitiveness is protected,
the following enabling conditions are indispensable:
1. Access to sufficient and
globally cost-competitive fossil-free energy and primary and secondary raw materials
such as
steel scrap, which is strategic.
o The steel industry calls for a thorough impact assessment of all options to marginal pricing in the
electricity market-design including the possibility to adopt non-market-based mechanisms such as
regulated tariffs, also for energy-intensive industries, public guarantee schemes for long-term energy
arrangements such as Power Purchase Agreements (PPAs) and hedging, and a system-efficient
redistribution of revenues to support consumers and investment in renewables.
o The steel sector also asks for the prioritization of supply of hydrogen (H2) and related infrastructure
planning based on the GHG abatement potential, in particular in the initial phase when hydrogen is in
short supply.
2. Better tailored, more certain, clear and flexible
funding and financial incentives across the EU are required, as
well as faster processing of applications. Increased support for the roll-out of low-carbon steel projects rather
than for research and innovation is necessary.
3. Establishment of
lead markets for green steel and products (including low-CO2 steel); this could be achieved
through public procurement, quotas, ambitious GHG thresholds or introduction of GHG pricing for final products
based on their lifecycle emissions.
4.
Trade policy that levels the playing field with global competitors:
o Maintaining the
EU steel safeguard to prevent serious injury as long as the necessary conditions are
met. Promoting an EU-US Global Arrangement on Sustainable Steel that effectively tackles global steel
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excess capacity and incentivises ambitious steel decarbonisation in other regions, with comparable
measures in the US and in the EU.
o Adopting a
solution for EU steel exports before the Carbon Border Adjustement Mechanism kicks in in
2026 to prevent further losses of EU steel exports.
It is also essential to prioritize and mainstream industrial policy and competitiveness while reducing regulatory
burdens in all policy initiatives and legislative proposals, ensuring long-term predictability.
Steel is 100% recyclable without loss of its essential properties, making it a permanent material for the
circular economy. The EU steel industry is the most important recycler in Europe in terms of collection
rate (88%), tonnages (87,8 million in 2021) and value. With steel scrap recycling, the steel sector reduces
the EU’s CO2 footprint by 132 million tons every year, equivalent to the annual related emissionsof 19
million EU citizens. With 60 industrial-scale decarbonisation projects already underway, the steel industry
is on the path to carbon neutrality andaims to cut its emissions by at least another 30% (a reduction of 80
million tonnes of CO2) by 2030.
There are more than 3,500 grades of steel in use, 75% of which have been developed in the past 20 years
– better-performing, lighter and greener. Steel is at the core of our modern world. It is essential to our
lives and to the green economy, frombikes, trains, cars and e-cars towindmills and solar panels, bridges,
buildings, heating systems, pipes and sanitation, machines, medical equipment, defence, and much more.
The EU steel industry provides 310,000 direct jobs and creates seven additional jobs for each each of them
in the EU economy, totalling 2.5 million jobs1.
New global reality requires disruptive thinking and innovative measures
The European steel industry welcomes the renewed impetus on industrial policy at EU level, including the
European Council Conclusions of 9 February 2023. The “Green Deal Industrial Plan” comes at a time of
great uncertainty to our sector and other industries, with companies under immense pressure to decide
where best to undertake the required investments to decarbonise.
Our global competitors, such as the US, China and India,
are stepping up efforts to create a favourable
investment environment for climate neutrality, including a direct focus on incentivising industrial
decarbonisation projects.
The
US Inflation Reduction Act (IRA) is a prime example. The IRA provides
direct support to the US steel industry’s decarbonisation and renewable energy investments using
significant tax credits, grants and loans subsidising the production and sale of critical steel-intensive
renewable energy systems and infrastructure. It also provides additional steel demand for the US steel
industry, as it discriminates against non-US steel producers – including those from the EU - through its
local-content requirements. We estimate that combined IRA and Department of Energy (DOE) funding will
provide at least
USD 85 billion of funding for steel production and upstream energy. The IRA has the
potential to significantly decrease the cost of green hydrogen by about $3/kg of H2, and up to $4/kg H2
with additional DOE funding secured. As a consequence of IRA/DOE, the
current energy cost gap between
the EU and US could widen by up to 60%. IRA funding has also the potential to decrease costs of Carbon
Capture Utilisation and Storage technologies (CCUS) by between $80 and up to $100 (with additional DOE
funding) per ton of CO2. In the absence of any new mechanisms in Europe, IRA and DOE funding will
undoubtedly create a more competitive investment and production environment for green steel in the
1 The Impact of the European Steel Industry on the EU Economy: An updated and extended analysis, Oxford
Economics, July 2019
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US. This
new global reality demands disruptive thinking and innovative measures from the EU. While
we agree that state aid procedures should be simpler, faster and more predictable, we stress that a real
industrial policy strategy cannot be designed on state aid. We thus call for a comprehensive response at
EU level that would preserve the integrity of the European internal market and provide a long-term
framework that preserves our competitiveness and spurs our transition to a carbon-neutral economy.
Steel is essential for a climate-neutral economy, including Clean Tech and Net-Zero Industry value
chains
The European approach on industrial policy puts great emphasis on Clean Tech sectors and Net-Zero
technologies. Abundant, secure and affordable fossil-free energy is a fundamental element for the future
of the European industry and its economy. Therefore, we support strengthened measures that would
entail a fast deployment of fossil-free energy and hydrogen production, as well as the necessary
infrastructure.
Renewables, hydrogen, wind towers, solar panels, electric vehicles, are all dependent on and interlinked
with steel. Steel is at the foundation of those value chains and they are at the foundation of circular steel
value chains, as we recycle their steel scrap into new products. For every new megawatt (MW) of solar
power deployed, between 35 to 45 tons of steel are required, while each new MW of wind power uses
120 to 180 tons of steel. To achieve the ambitious targets for 2030 set in the RED III proposal and the
REPowerEU plan2, we will need an expansion of installed capacities of the main renewable energy (REN)
sources that would equal to a 300% increase of the current solar PV capacity, and a 250% increase of wind
power3. This means that more than
74 million tons of steel will be required for the expansion of
renewable energy generation alone (16.6 Mt for solar PV and 57.6 Mt for wind power). If we add the
production of renewable hydrogen, the related infrastructure (e.g. pipelines, storage), the transport
sectors and the transport infrastructure, this figure becomes much bigger. This shows that the
foundations of the Net-zero Age are made of steel.
Steel must be at the core of the Green Deal Industry
Plan and should be
included in the Net-Zero Industry Act.
Low carbon technologies for the transition
and production of green steel,
together with the related infrastructure, should also benefit from faster
and simplified permitting procedures, and not be limited to a restricted number of sectors. The Act
should aim at identifying and reducing the overall regulatory burden in Europe on industry, including the
steel sector.
The European steel industry is one of the most advanced sectors in terms of decarbonisation projects. We
have currently over 60 industrial scale projects ready to be scaled up before 2030. These projects would
require a total CAPEX of approximately €30 billion and a total OPEX of at least €53 billion (pre-crisis
forecast). In addition, their implementation would entail an increase of energy needs by 165 TWh of
electricity, of which 93 TWh is for hydrogen production and 75 TWh would be for other production
processes. Some of these investment projects are at serious risk of being undertaken outside the EU.
Access to cost-competitive and fossil-free energy
Today, the steel industry consumes around 75 TWh of electricity annually. Of these, about 55 TWh are
purchased from the grid and the remaining is produced from on-site waste gases generated in primary
steel making. Access to cost-competitive and fossil-free energy is of paramount importance for today’s
2 European Commission, “REPowerEU: Joint European Action for More Affordable, Secure and Sustainable Energy”,
Communication, March 8, 2022, available a
t: https://eur-lex.europa.eu.
3 The EU’s Plan to scale Up Renewables by 2030: Implication for the Power System, Briefings de l’IFRI, Center for
Energy and Climate, available a
t https://www.ifri.org (estimated wind power capacity in 2030: about 420 -480 GW;
estimated solar PV capacity in 2030: about 380 – 410 GW)
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competitiveness and for the future transition of the steel industry and other Energy-Intensive Industries
(EIIs). For EIIs cost-competitive energy means energy at “globally” competitive prices.
The current economic situation is very urgent and
without dedicated solutions to provide relief for EIIs,
the ongoing de-industrialisation of Europe, triggered by the high energy prices will continue, while
decarbonisation will be hindered.
The
revision of the Electricity Market Design (EMD) directive is an opportunity to secure cost-competitive
fossil-free electricity.
All options to reform the EMD, and in particular concerning the short-term markets
and pricing models should be considered and assessed by the Commission, which should strive at
benefitting European consumers from an ever increasing share of fossil-free generation in the markets.
Alongside, the reform should also
improve access to long-term contracts (i.e., Power Purchase
Agreements (PPAs) and hedging contracts) for EIIs, and to promote
demand response measures
exclusively on a voluntary basis where these are technically feasible and cost-efficient. PPAs are linked
to the short-term market pricing signals and unable to effectively provide a structural solution for EIIs,
unless the price in short-term markets are back to pre-crisis level. Moreover, access to PPAs for EIIs is
hampered by economic and financial barriers, limiting their potential to unlock investments and deliver
additional electricity at affordable levels. Financial instruments such as public guarantee schemes would
support long-term energy offtake agreements for fossil-free electricity and hydrogen. The reform should
also guarantee an effective redistribution of excess profits to sustain EIIs affected by unbearable energy
prices and to spur investment in additional capacity required by 2030 and 2050 . Other non-market-based
instruments to support the competitiveness of industry exposed to global competition on energy cost
should be also allowed at national level, such as
regulated electricity tariffs for EIIs, or exemptions and
derogations from levies and taxes.
Hydrogen and electricity, next to bioenergy, are fundamental elements of the decarbonisation strategy of
the steel industry, however until 2035 their availability in industrially useful quantities will be scarce. The
ongoing revision of the Renewable Energy Directive and the Hydrogen and Decarbonised Gas Market
Package should strive at
achieving production of cost-competitive hydrogen and fossil-free electricity in
the EU, while ensuring their uptake by EIIs. By promoting a
prioritisation of supply of H2 and
infrastructure development based on the highest Greenhouse Gases (GHG) emissions abatement
potential, policy makers can ensure that the transition of hard-to-abate sectors such as steel to low carbon
technologies will not be delayed. This principle should also be reflected in the design of the Hydrogen
Bank. The recently adopted
delegated act on renewable hydrogen contains improvements to the initial
proposal. However, its impact should be regularly and thoroughly assessed to remove potential barriers
to the production of fossil-free hydrogen, electricity and bioenergy in the EU. It is also important that the
required additional fossil-free energy production capacity for industry is thoroughly assessed and mapped
throughout the transition.
A European approach to incentivize investments in low carbon technologies
While cost-competitive energy is fundamental for being competitive today, the roll-out of new
technologies also requires the right financial incentives. The US IRA will deploy nearly USD 400 billion over
the coming decade, as a comprehensive package that will substantially lower energy prices for US energy
intensive industries, including for the production and use of green hydrogen. The European Union has
launched several programmes that provide financial support to decarbonisation projects at EU and
national level over the past years. Although these programmes collectively account for a substantial and
comparable level of resources, they are fragmented and in most cases difficult to access. Short-timelines
for application and expenditure often do not match the time required for obtaining a permit by a company
and the long lifecycle of decarbonisation projects in energy-intensive industries such as steel. Overly
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restrictive criteria that hinder technology neutrality or do not allow for a step-wise approach in terms of
GHG abatement are another obstacle experienced by companies.
A re-think of existing funding and
financial programmes is necessary to ensure that available resources can be used in synergy and that
programmes are simplified and easy to access, which should result in a more certain access to funding
for companies.
Support for the roll-out of technologies at industrial scale – going beyond R&D&I - should
be significantly increased, focusing not only on CAPEX but also on access to cost-competitive energy
and hydrogen. The incentives provided under the IRA translate into reduced cost production for less CO2-
intensive production, as compared to the current level of cost production of conventional technologies.
Current limitations on the calculation of the funding gap in the EU need to be addressed,
matching the level of incentives provided by our international competitors. We welcome the proposal of President
von der Leyen of a
European Sovereignty Fund as one of the structural solutions for strategic sectors
under the Green Deal Industrial Plan
. Contracts for Difference and public guarantees should be
considered among the potential
solutions to provide cost-competitive hydrogen and electricity. The
proposal of a pilot programme under the
Hydrogen Bank granting a fixed premium for each kg of
renewable hydrogen produced over a period of ten years is a good example of how support can be
effectively designed and is welcomed by industry. However, this programme needs to be significantly
expanded in terms of budget, while also
ensuring that the support benefits industrial end-users.
Increased financing of programmes that would speed up the implementation of the hydrogen
infrastructure, such as
Connecting Europe Facility should be considered as well.
Lead markets for green steel and products (including low-CO2 steel) Significant market
instruments are needed to drive up demand for steel products with reduced CO2
emissions, but higher production costs. In order for these green steel products to be competitive on the
market with conventional steel products, the major steel consuming sectors should be able to valorise the
procurement of greener products. The Communication on the Green Deal Industrial Plan calls for
stimulating the demand for net-zero products at large scale. This is a good basis to establish
lead market
incentives which could include the use of relevant criteria in public procurement, quotas, ambitious
GHG thresholds and the introduction of GHG pricing for final products based on their lifecycle emissions.
Whilst similar incentives are envisaged in proposed product policies, such as the Ecodesign for Sustainable
Products Regulation and the revised Construction Products Regulation, it is not yet clear how this will
work in practice in the context of an overall strategy, taking into account the simultaneous deployment
of low CO2 steelmaking technology.
The
Eco-design for Sustainable Products Regulation (ESPR) will prove crucial for the future definition of
green steel and promotion of its unique performance, sustainability and circularity. Steel should be
recognised as a permanent material, since it is not being consumed just used over and over again.
Alignment and coherence with current legislation is essential as well as setting relevant performance and
information requirements within it. The revision of the
Construction Products Regulation should align as
closely as possible to the ESPR, as steel is supplied into all product markets, not just construction. The
setting of minimum environmental performance requirements is the right step to create a level playing
field in the construction market among all member states.
Ensuring open and fair trade Between 2009 and 2020 the
EU steel industry has lost 26 million of tonnes of permanent steel capacity
production, and 80 000 direct jobs, which equals to
25% of our workforce. At the same time,
the EU
shifted from being a net steel exporter into becoming a major net steel importer, losing 30 million tonnes
of sales on the EU and export markets. In the same period EU steel import volumes have doubled to 30
million tonnes.
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Global excess steel capacity has been a major cause for this situation and since the introduction of the
US Section 232 steel measure in 2018 it has only worsened. The OECD estimates global excess capacity at
around 563 million tonnes in 2022 and predicts that global steelmaking will further increase by almost
6% over the next 3 years.
Since the elements that justified the extension of the EU steel safeguard measures in 2021 are still
persisting, and have even worsened – in particular overcapacities and exposure to injury - it is
necessary
to continue the EU’s steel safeguard to prevent serious injury for as long as the necessary conditions
are met. Moreover, the IRA’s domestic steel content requirements could further enhance steel trade
deviation flows from the US to the EU. The envisaged EU-US Global Arrangement on Sustainable Steel to
effectively tackle global steel excess capacity and incentivise ambitious steel decarbonisation in other
regions, has to foresee comparable measures in the US and in the EU.
It is important to note that the large safeguard quotas do not replace the continued need for punctual
antidumping actions if the conditions on a product and country-specific level are present. Reacting
promptly to distorting steel imports by
applying the full scope of the modernised Trade Defence
Instruments is crucial for the EU steel industry.
New tools are necessary that can effectively tackle distortions from imports and guarantee access to
export markets: by making effective use of the
EU’s Enforcement Regulation to allow the use of sanctions
when third countries adopt illegal measures; by
enforcing reciprocity where third countries deny access
to their markets, such as in restrictive public procurement regimes; by ensuring through conclusion of
new
Free Trade Agreements (FTAs), or revision of existing ones, access to markets and compliance with
EU standards on competition and state aid. In general, FTAs should be equipped with a stronger dispute
settlement and powerful enforcement mechanisms, including the ability to impose prompt and effective
remedies.
Now is the time to actively promote industrial competitiveness
The US IRA shows that it is possible to have a proactive, structural, carbon-neutral industrial policy centred
on incentives and industrial competitiveness, rather than relying primarily on obligations and targets
complemented by insufficient and fragmented support. This approach should be taken by example rather
than being seen as a threat. Our vision has to nurture
international competitiveness and level-playing
field. By
mainstreaming and promoting these principles in all relevant policy areas and legislative
proposals, we will be able to formulate legislation that delivers on climate change policy, while
achieving prosperity for society. They should be better embedded in the work organisation and planning
of the European Commission and other institutions, including best practices such as a methodical use of
impact assessments.
Effective carbon leakage instruments
The steel sector has the highest risk of carbon among EIIs. The political agreement on the
Carbon Border
Adjustment Mechanism (CBAM), which will gradually complement and later replace the Emissions
Trading System (ETS),
entails a delicate transition phase for energy-intensive industries as regards the
level playing field with third countries. CBAM can only partially prevent carbon leakage, and only on the
internal market. The
solutions for the export market have to be introduced before the CBAM fully kicks
in in 2026, otherwise we
risk losing €45 billion of EU steel exports and consequently related production
capacity and jobs. Moreover, the
environmental integrity and effectiveness of this instrument will be
further tested during its implementation via secondary legislation; therefore carbon measurement
methodology, default values and anti-circumvention measures have to be in place and effective to
ensure
that CBAM is watertight.
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Ensuring the access to raw materials to enable steel contribute to the Circular Economy
Every year, the steel sector recycles millions of tonnes of ferrous scrap recovered from processing and
end-of-life products and is constantly engaged in the re-use and recycling of most of the industrial residues
generated with steel.
Steel scrap generated in the EU should be considered as a strategic resource. Its
use is essential not only to the completion of the EU’s circular economy, but also in supporting the EU’s
CO2 reduction objectives. Exporting EU waste challenges to third countries not adhering to similar
environmental, health and safety and social standards hampers the same environmental and climate
change objectives of the EU. Export of scrap has been increasing over the past years, reaching almost 20
million tonnes in 2021. But as we transition to low-carbon technologies, we expect shortages for scrap
before 2030, as current scrap levels will not fulfil the demand. Stronger monitoring and audit system,
along with well-defined and relevant environmentally sound management criteria and
tougher anti-
circumvention measures under the Waste Shipment Regulation would ensure the availability of
secondary raw materials, supporting the decarbonisation of the EU steel industry.
The upcoming
Critical Raw Material Act (CRM Act) is another opportunity to address availability and
sourcing of primary and secondary raw materials and reduce EU dependency on several critical raw
materials. This can be achieved by
including on the list of Critical Raw Materials key primary raw
materials, such as
nickel and manganese, and other
critical secondary raw materials such as ferrous
scrap in the EU. If not addressed, their shortages can have a significant impact on key EU industries.
Industrial Emissions Directive
Permits are the licenses to operate, without it a company cannot run any business. EU companies can
obtain a permit only if compliant with very strict requirements, which are greatly based on the respect of
Best Available Techniques (BAT) in a defined industrial activity. The
Industrial Emissions Directive (IED)
has proven very efficient over the past ten years at protecting human health and the environment by
reducing harmful industrial emissions across the EU. The
IED should stay focused on its main objective,
identifying and promoting what is currently best in industry, and not aim at inducing decisions on
companies as regards future technological pathways. Existing and effective EU legislation aimed at
reducing GHG emissions or implementing circularity should not be substituted by the IED.
Industry needs
legal certainty when it comes to permits and to be able to freely choose the most suitable technology
for their decarbonisation, independently from permit requirements. If too prescriptive or with a too
wide-ranging scope, the IED could actually hinder innovation and decarbonisation. If there are new
binding limits on environmental performance based on a common process for a common product, this
will hamper product and process development and as such innovation. Furthermore, binding energy
consumption levels may prevent the roll-out of technologies that can achieve deep GHG abatement but
require more and not less energy, such as those based on electrification or hydrogen use.
Young steelmakers for a future-oriented European steel industry
Investing in human capital is vital for attracting motivated and qualified people to help transform the steel
industry. The steel sector is a force for good and essential for the green transition, where
young
steelmakers can make a difference. The third pillar of the Green Deal Industrial Plan is rightly about
developing the skills for a just transition. However, it is
imperative for stakeholders to cooperate in
providing adequate training and academic opportunities and to ensure the EU nurtures homegrown
talent whilst avoiding ‘expertise leakage’. The Pact for Skills, which is part of the European Skills Agenda,
is a first step into the right direction. The European steel industry is currently developing a project in the
framework of the European Commission’s Blueprint Skills Agenda, the so-called “European Steel Skills
Agenda and Strategy (ESSA)”. The project foresees cooperation between all relevant stakeholders to
implement concrete actions to satisfy short- and medium-term skills needs, including upskilling and
reskilling.
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Conclusions
The European steel industry urges the EU institutions and the Member States to endorse the
aforementioned recommendation and facilitate the establishment of a
policy framework to enable the
development and scaling up of low-carbon technologies in steel production by 2030. Additionally, it is
imperative to establish a level playing field for steel companies in relation to their global competitors. The
steel industry's success in achieving climate neutrality will depend on collaborative efforts between
policymakers, businesses and other stakeholders to overcome challenges and seize opportunities in the
transition to the Net-zero Age.
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