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European General Galvanizers Association

EGGA

European General Galvanizers Association (EGGA) is the industry organisation for Europe’s general galvanizing sector.

Lobbying Activity

Response to Minimum requirements on environmental sustainability for NZIA public procurement procedures

14 Oct 2025

The galvanizing industry plays a key role in supporting the EUs sustainability and climate objectives by substantially enhancing the durability of steel products through effective corrosion protection. We welcome the opportunity to contribute to the European Commissions public consultation on specifying minimum requirements on environmental sustainability in the public procurement of solar technologies, as part of the Net-Zero Industry Act (NZIA). We believe that embedding durability, reusability, and recyclability into the design of solar photovoltaic systems is vital to advancing circular economy goals and enhancing their overall environmental performance. We encourage the Commission to broaden the scope of the Implementing Regulation to include PV trackers and their specific mounting structures, as they fall within the NZIA scope and measurement methods already exist for them. Our detailed recommendations are provided in the attached document. We remain available to provide any further information or clarification.
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Response to Extension of the scope of the carbon border adjustment mechanism to downstream products and anti-circumvention measures

26 Aug 2025

The batch galvanizing industry is an integral part of the steel value chain acting as a sub-contract provider of long-term corrosion protection for steel products that are used mainly in construction, renewable energy and transport infrastructure sectors. Although our installations processes are not directly within the scope of CBAM assessments, the impact of carbon leakage and associated displacement of steel product manufacturing and fabrication of steel structures beyond the EU is a key issue for our industrys competitiveness. The majority of steel products and structures that are processed by our industry (i.e., manufactured by our customers) are already covered by the 7308 series (and 7326) of HS codes that are included in the Annex I to the CBAM Regulation. Many of these products under 7308, e.g., steel electricity transmission towers and steel mounting structures for solar PV installations are of a downstream type. Our position on a CBAM extension and additional circumvention measures therefore focuses on: 1) THAT THE ANTI-CIRCUMVENTION MEASURES DESIGNED FOR BASIC GOODS, IN PARTICULAR ANY MEASURES TO AVOID RESOURCE SHUFFLING OF LOWER CARBON-INTENSIVE STEEL TOWARDS EU MARKET IMPORTS, ARE ALSO EFFECTIVE FOR 7308 SERIES OF PRODUCTS that may be fundamentally different product types than the other steel basic goods. We consider essential that various anti-circumvention measures designed for basic goods to avoid resource shuffling of lower carbon-intensive steel towards EU market imports, must also be effective for the 7308 series of products that may be fundamentally different product types than the other steel basic goods. These measures should also not introduce unnecessary administrative burdens to importers because those imports may be vital for the competitiveness of the EUs steel product manufacturing sector, including the batch galvanizing industry. The use of country-specific default values for steel carbon intensity, based on the most carbon intensive relevant production route, for all basic and downstream goods would appear the most feasible of the anti-circumvention measures that have been proposed. This measure may be adopted as an interim solution. 2)THAT CERTAIN STEEL INTENSIVE DOWNSTREAM GOODS ARE INCLUDED IN THE EXTENSION OF CBAM, TO COMPLETE THE COVERAGE THAT IS ALREADY PARTIALLY ACHIEVED THROUGH THE 7308 SERIES. The risks of carbon leakage further down the value chain because of CBAM implementation are obvious and real. There is also a risk of resource shuffling across sectors for downstream goods especially for shifting less carbon-intensive steel production towards the products within the 7308 series. We therefore support the proposals of EUROFER for extension to certain steel-intensive downstream goods. We kindly invite you to review our full position paper (attached), which includes the list of HS codes we recommend for inclusion within the scope of CBAM.
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Response to Trade measure addressing the negative trade-related effects of global excess capacity on the EU steel sector

18 Aug 2025

The EU batch galvanizing industry comprises approximately 700 installations that are strategically located across all EU Member States to provide sub-contract, long-term corrosion protection for steel components, products and structures that are manufactured in the EU. Our sector processes ~ 7 million tonnes of manufactured steel products annually. Our position on the proposed replacement of the existing steel safeguard measures and the introduction of a new trade defence measure is based on two fundamental realities: 1. The future of the entire EU steel value chain, including the batch galvanizing sector, depends on a viable EU steel production sector that is properly shielded from the global issues of overcapacity of steel production. Unless the steel production sector is provided with the means to achieve the level of 85% production capacity utilisation that is envisaged in the Steel Action Plan, it will be impossible to realise the investments in decarbonisation and innovation that is required to ensure the future of the entire steel value chain. 2. The health of the batch galvanizing sector is directly dependent on the competitiveness of the EUs manufacturing and fabrication of steel end products. Manufacturers, especially small steel fabricators, require access to steel at competitive prices, with adequate availability and with minimal administrative burden. Downstream steel-intensive end products, that are already subject to high levels of lower cost import competition, should be protected from the inevitable effects of diversions of steel trade flows towards end products, that will arise through the imposition of trade defence measures for crude, intermediate and finished steel products and the recent inclusion of these end products in the US tariff measures. Most of these steel end products are imported into the EU in the galvanized condition. The proposed trade measures will require a carefully devised approach that takes account of both above considerations. SPECIFIC RECOMMENDATIONS: 1. To include steel end products in the new measures and avoid circumvention. To include customs codes 7308 (Structures and parts of structures, etc.); 7316 (anchors, etc.) and 7326 (other articles of iron or steel) for which significant effects of low-cost imports are observed. Further extension of the scope to be derived from a careful evaluation of the full Chapter 73 of the customs codes. If necessary, to identify and implement more precise customs codes for steel structures or end products, such as steel mounting structures for solar PV systems that may not be adequately identified within the Chapter 73 series. 2. To simplify administrative burdens and recognise that there is a justifiable trade in certain steel products and grades that may be in short supply. The existing quota system is burdensome for SMEs in the steel product manufacturing sector and should be simplified in any new system that is introduced
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Response to Revision of the Standardisation Regulation

21 Jul 2025

The European General Galvanizers Association (EGGA-Galvanizing Europe) is the federation of the national galvanizers associations within Europe. Our industry comprises about 700 general galvanizing plants (mostly SMEs) that provide long-term durability for a wide range of steel products. We are extensively involved in European standardisation for steel products, corrosion protection, sustainability and other topics. We are one of the small number of industry associations that are designated a CEN Partner and have been closely involved in all aspects of standardisation, in particular those aspects related to the Construction Products Regulation. Our experience allows us to offer this feedback to the proposed revision of the Standardisation Regulation 2012/2012: (1) The fundamental basis of the current standardisation system that is built on consensus building and transparent stakeholder engagement must be retained whilst seeking a faster and more efficient way to deliver standards. These principles of consensus building are especially vital for the competitiveness of SMEs. Alternative solutions may have a disproportionate adverse effect on SMEs. (2) The current weaknesses of the system of developing and delivering Standardisation Requests to CEN can be improved, in particular by ensuring greater awareness of the importance of Standardisation Requests throughout the supply chain and to ensure effective industry engagement in the Commissions activities at an early stage. The current difficulties for the Standardisation Request for Structural Metallic Products under the CPR is an example of the inefficiency in the standardisation systems support for policy implementation that arises through inadequate industry engagement. (3) We are cautious about the Commissions proposed Common Specifications as an alternative to the current standardisation system. The Commissions initial proposals lack clarity and do not appear to address the underlying causes of the delays and inefficiency that is sometimes observed in the current system, in particular the procedure for development Standardisation Requests and the reviews conducted for HAS assessments. We should not divert attention from solving these issues within the existing system that is otherwise mainly fit for purpose.
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Response to Industrial Decarbonisation Accelerator Act

8 Jul 2025

The galvanizing industry enhances the circularity and durability of Europes steel products, benefiting the EU climate goal. We are committed to decarbonisation and call for a supportive policy framework not limited by current EII classifications. The IDAA has high potential as a key Clean Industrial Deal tool, supporting industrial decarbonisation while preserving global competitiveness. We especially value its ability to streamline administrative procedures and boost investment. Europes galvanizing industry is concerned that policy focus remains limited to core Energy-Intensive Industries (EIIs), excluding less energy-intensive installations within EII value chains from support. If this distortion is not corrected, downstream SMEs and mid-caps risk becoming decarbonisation laggards and contributing more to final product emissions. We urge the Commission to address this in its proposal, especially regarding funding thresholds, policy scope, and enabling conditions, ensuring these are not confined by EII definitions that exclude SMEs and mid-caps in those supply chains. DETAILED RECOMMENDATIONS 1. Targeted action is needed to boost grid capacity and ensure stable, secure, affordable electricity. Support tools must be available to all energy-reliant sectors, including SMEs and mid-caps beyond traditional EIIs. The galvanizing sector lacks access to affordable, decarbonised energy. Electrification, especially via electric furnaces, is a practical and cost-efficient path. Key barriers include: Insufficient grid capacity: Many sites can't connect due to grid limits. Installations outside EII definitions are often deprioritised. High and volatile electricity prices: Marginal pricing and taxes cause instability. Support (State aid, grants, CCfDs, PPAs) should extend beyond large EIIs. Limited supply reliability: Gas remains more dependable; recent outages show risks amid rising electricity demand. 2. Energy-dependent installations outside conventional EII definitions must have the flexibility to adopt the most suitable decarbonisation technologies and receive appropriate support. While electrification is viable for the galvanizing sector, lower-intensity companies often lack access to electricity, as priority goes to others, pushing them toward less suitable alternatives. It is ineffective to steer these sectors toward specific green technologies based on infrastructure-driven policies, especially when solutions are not technically compatible or economically viable. 3. Permitting processes for industrial energy access and decarbonisation must be faster, more certain, and consistent across Member States. Companies in the galvanizing sector face complex, lengthy procedures. Planning objections delay investment and slow decarbonisation. These issues vary by region, causing uneven progress. Few countries issue permits quickly; they should take no longer than four months. Mechanisms must limit unjustified objections once standards are met, ensuring legal certainty and timely investment. 4. Deliver lead markets for low-carbon steel products with minimum EU content while avoiding conflicts with downstream methodologies in other legislation. Creating lead markets for low-carbon products can boost investment via a voluntary label. If label boundaries align with ETS and CBAM at the intermediate product stage, conflicts with other declarations (e.g. Global Warming Potential in Construction Products Regulation) can be avoided. Clear interface design is essential to prevent conflicting values and unnecessary reporting burdens.
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Response to Implementing Act on non-price criteria in renewable energy auctions

21 Feb 2025

EGGA-Galvanizing Europe welcomes the opportunity to provide feedback to the European Commission's public consultation on the Implementing Act (IA) on non-price criteria (NPC) for renewable energy auctions under the Net-Zero Industry Act (NZIA). In this context, we strongly support SolarPower Europes (SPE) position, particularly on the following critical points: 1) HARMONIZED IMPLEMENTATION ACROSS EUROPE: We recommend that NZIA provisions on non-price criteria in auctions be implemented consistently across all Member States. A clear European framework should be developed for this purpose. 2) BALANCED APPROACH BETWEEN RESILIENCE AND DEPLOYMENT: Regarding Article 7 on resilience contribution, we observe that the current draft does not differentiate between resilience as a pre-qualification (eligibility criterion) and resilience as an award criterion. We recommend implementing resilience as a pre-qualification criterion for components that are already manufactured in Europe (an example is that of solar mounting structures and trackers). This will help safeguard and strengthen existing European manufacturing capabilities. We recommend using resilience as an award criterion in cases where manufacturing capacity is currently absent in Europe and should be encouraged. This balanced approach will foster industrial resilience without jeopardizing the rapid deployment of renewable energy projects. 3) RECOGNITION OF EU/EEA MANUFACTURED PRODUCTS: Award criteria for products manufactured in EU or EEA have not been considered, despite this being essential for EU producers. We encourage the Commission to recognize and award additional bonus points for products that are manufactured within the EU or EEA (i.e., to award additional bonus points compared to those given for components simply sourced from non-dominant countries). This would incentivize local production and contribute to the long-term sustainability of European renewable energy supply chains. We are concerned that the proposed measures may not be sufficient to meaningfully enhance the Union's resilience. IN THIS CONTEXT, WE SUGGEST MAKING THE FOLLOWING REVISIONS: 1) Regarding Article 7(1, point a and f), we suggest that if the Commission determines that over 50% of the supply of any net-zero solar technologies within the Union originates from a single third country, the relevant authorities shall exclude from the auction any bids containing mounting structures and/or trackers from that third country and, in any case, ensure that the 50% limit is never exceeded. 2) Regarding Article 7 (last paragraph), we suggest removing the 85% threshold, particularly its application to components that can be produced in Europe (i.e., solar mounting structures and trackers). For such components, the 50% limit should never be exceeded. This revision is necessary to safeguard EU manufacturers against the flood of low-cost imports from countries that dominate the EU market for these components.
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Meeting with Jens Geier (Member of the European Parliament)

22 Jan 2025 · Exchange on expectations for the Commission Work Programme

Meeting with Christian Ehler (Member of the European Parliament)

16 Jan 2025 · Net-Zero Industry Act

Response to European Critical Raw Materials Act

30 Jun 2023

EGGA welcomes the Commissions initiatives to propose a comprehensive approach to scale up and accelerate the supply of primary and secondary raw materials in the EU and to address strategic dependencies through the proposed Critical Raw Materials Act. The general (batch) galvanizing industry provides the most effective long-term corrosion protection for steel products through the application of a metallurgically-bonded coating of zinc metal. It is a service that is applied after manufacture of the product and normally on a sub-contract basis. The coating ensures many decades of maintenance-free durability for vital net-zero technologies, such as solar power installations and wind energy equipment. A galvanized coating is sufficiently durable and robust to provide corrosion protection across more than one product lifecycle. Both zinc and steel are recovered at eventual end-of-life. Zinc is the main raw material used in the galvanizing process. Zincs durability, abundance and established recycling routes define it as a material that is highly compatible with the circular economy. EGGAS POSITION IN SUMMARY: (1) MATERIALS SHOULD NOT BE ADDED TO THE CRM/SRM LISTS THAT HAVE NOT DEMONSTRATED SIGNIFICANT SUPPLY RISK ; (2) SUBSTITUTION OBLIGATIONS (AND LINKED REGULATORY CRITERIA) SHOULD NOT BE APPLIED TO MATERIALS WITH LOWER LEVELS OF SUPPLY RISK The intended focus of the Act is, quite correctly, on raw materials deemed to be at a high level of supply risk that may also be of vital importance to strategic sectors, such as renewable energy, defence or health. EGGAs observations regarding the lists of CRMs and SRMs are that (i) there is a lack of transparency regarding the methodology for selection of SRMs and (ii) it appears that a raw material that has not demonstrated a high level of supply risk, according to the Commissions currently established methodology, may be arbitrarily identified as a SRM and, de facto, allocated to the list of CRMs. Our concerns at this lack of transparency and the apparent possibility to add raw materials that are at significantly lower levels of supply risk relate to the obligations, also set out in the proposal, for substitution of CRMs and SRMs. Such substitution obligations may lead to unnecessary substitution activities with consequent market distortion for users of those materials. The Commission proposal does not distinguish between CRMs and SRMs with regard to obligations on substitution because the underlying rationale is that a SRM also has a high level of supply risk. It would be inappropriate for the following aspects of the proposed Act to apply to SRMs that have no demonstrated or forecast high level of supply risk: (a) Article 19. 3 that requires a stress test for SRM supply chains (including downstream use), including availability of substitute materials; (b) Article 25. 1 that requires national programmes that increase the substitution of critical raw materials in applications. EGGA would be especially concerned if it were it to be suggested to add zinc metal to the list of CRMs/SRMs in the proposed Regulation. Although recognised as of strategic economic importance, zinc has demonstrated a low level of supply risk under previous editions of the EU List of Critical Raw Materials that have been published since 2011. Our concerns also extend to the direct links between identified CRMs and sustainability assessment within the proposed Ecodesign for Sustainable Products Regulation (ESPR): There are certainly significant threats to the viability of zinc production in Europe arising from excessive electricity costs and a need to ease permitting of new mine projects. However, EGGA believes that materials that are vital for net-zero technologies should be considered within the proposed Net-Zero Industry Act. The JRC Foresight Report (January 2023) identified zinc as a non-critical raw material that has importance for 4 out of 5 of the renewable energy sectors under study.
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Response to Net Zero Industry Act

27 Jun 2023

EGGA - Galvanizing Europe welcomes the opportunity to contribute to the further development of the Commissions proposal for a regulation on establishing a framework of measures for strengthening Europes net-zero technology products manufacturing ecosystem - a Net Zero Industry Act. The general (batch) galvanizing industry provides the most effective long-term corrosion protection for steel products, through the application of a metallurgically-bonded coating of zinc metal. It is a service that is applied after manufacture of the product and normally on a sub-contract basis. The coating ensuring many decades of maintenance-free durability for vital net-zero technologies, such as solar power installations and wind energy equipment. A galvanized coating is sufficiently durable and robust to provide corrosion protection across more than one product lifecycle. Both zinc and steel are recovered at eventual end-of-life. EGGA supports the objectives of the proposal and agrees that the regulation should focus solely on the eight identified strategic net-zero technologies - including solar PV and wind turbine technologies. EGGAs requests that the manufacture of steel components, including the galvanizing of those components, should be clearly identified as part of the net-zero manufacturing supply chain. Constraints in manufacturing capacity, investment and availability of a suitably skilled workforce in the manufacture of steel components, such as the support structures of solar PV panels, create similar threats to the scale-up of renewable energy as for the manufacture of the panels themselves. Imports to the European Union of solar panel support structures from China and other third countries has been steadily increasing at the expense of intra-EU manufacture. Although the Commission's Explanatory Memorandum suggests that the proposed Act refers also to the main upstream components that are central to the respective technologies, we have proposed in the attached document certain amendments to the legislative proposal to make clear the objective of increasing the manufacturing capacity of ALL components in the supply chain for these net-zero technologies that are heavily, or increasingly, dependent on imports.
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Response to Ecodesign for Sustainable Products - Product priorities

12 May 2023

European General Galvanizers Association welcomes this opportunity to contribute to the development of the Ecodesign for Sustainable Products Regulation regarding both prioritisation of product groups and the application of horizontal criteria. The attached document provides details of EGGAs response to the Commissions Call for Evidence on New Product Priorities for Ecodesign for Sustainable Products. The general (batch) galvanizing industry provides the most effective long-term corrosion protection for steel products, through the application of a metallurgically-bonded coating of zinc metal. It is a service that is applied after manufacture of the product and normally on a sub-contract basis. Applications include ensuring many decades of maintenance-free durability for vital net zero technologies, such as solar power structures and wind energy equipment. A galvanized coating is sufficiently durable and robust to provide corrosion protection across more than one product lifecycle. Both zinc and steel are recovered at eventual end-of-life. EGGA supports the objectives of the proposed Ecodesign for Sustainable Products Regulation and the fundamental approach to focus on the products with highest environmental impact and greatest potential for improvement in their sustainability. The observations and recommendations in our submission have been prepared in response to the JRC Science for Policy Report: Ecodesign for Sustainable Products preliminary study on new product priorities of January 2023 and draws on our experience in life cycle studies, environmental product declarations and sustainability assessment across the various product groups for which galvanized coatings are applied. EGGAs main request is that opportunities for improvement in product sustainability through optimisation of corrosion protection services are properly recognised when addressing priority product groups. We welcome inclusion of durability as priority horizontal measure and agree with the JRC remark that Durability measures would also have a positive effect in reducing the environmental impacts of the consumption in scope across all impact categories. However, the proposed approach to durability has a significant omission there is no direct reference to the need for optimal levels of corrosion resistance of the product. Resistance to corrosion is the primary determinant of durability for a wide range of products that may become subject to prioritisation. Actions under the ESPR to improve corrosion resistance will have direct positive impact on durability. We recommend that Corrosion Resistance to be added to the list of provisions associated with Durability of Function and Resistance to stresses or ageing mechanisms. Furthermore, criteria should be added that encourage the use of methods of corrosion protection that will facilitate reuse and will provide long-term durability over more than one life cycle of the product.
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Response to Review of the Construction Products Regulation

12 Jul 2022

RESPONSE TO PUBLIC CONSULTATION - EUROPEAN GENERAL GALVANIZERS ASSOCIATION REVISION OF THE CONSTRUCTION PRODUCTS REGULATION (2022/0094) 12 JULY 2022 IMPORTANCE OF THE CPR The European General Galvanizers Association (EGGA) represents approx. 600 industrial operators (mostly SMEs) that provide the service of sub-contract application of long-term protective zinc coatings for steel products (ie., hot dip galvanizing). Over 80% of the steel products processed by the galvanizing industry are construction products that are within the scope of the existing Construction Products Regulation (CPR) and are placed on the EU internal market by our customers (the product manufacturer). The CPR has high importance for our sector because: 1. We believe that the provisions of the CPR should ensure that the importance of optimal corrosion protection in achieving the highest levels of durability and reuse of construction products is properly recognised. 2. Any requirements for information to be included in Declarations of Performance and/or Conformity have implications for sub-contract services beyond any requirements and administrative burdens that are placed directly on the product manufacturer. GENERAL REMARKS – STANDARDISATION AND DELEGATES ACTS We support the position submitted by Construction Products Europe with regard to the use of standardisation as a relaible basis for the internal market for construction products. We share their concerns at the envisaged use of Delegated Acts in delivering the objectives of the CPR and the need to limit, wherever possible, the circumstances where such Acts are used. We do not repeat the rationale for those concerns here. ENVIRONMENT AND SUSTAINABILITY - DURABILITY Our most significant concern within the proposal is that the durability of construction products has taken a lower prominence within obligations on manufacturers. Durability is no longer associated with the requirements related to the sustainable use of natural resources (Annex 1 A. 1.8). This represents a lost opportunity to drive the greater circularity of construction products. For example, Article 22 states that products should be designed in such a way that ‘their durability does not fall beyond the average durability of products of the respective category’. This obligation lacks ambition and will not drive change. More durable products are replaced less often and are more suited to reuse. Similarly, Annex 1 C.2.1 refers to ’maximising durability’ but also refers to average life span and the definition of this requirement lacks clarity. EGGA would welcome the opportunity to work with the Commission to enhance the aspects of the proposal related to durability. We have extensive expertise in this field. ENVIRONMENT AND SUSTAINABILITY – REUSE We welcome the greater emphasis on reuse of construction products, but question if the objectives of Article 5 (Ecodesign requirements) of the Commission’s “Proposal for a Regulation establishing a framework for setting ecodesign requirements for sustainable products” (2022/0095) are similarly implemented in the CPR proposal. The CPR proposal contains no clear obligation for design for reuse. ENVIRONMENT AND SUSTAINABILITY – EN 15804 & EPDS The role of EN 15804 and the existing system of Environmental Product Declarations in fulfilling the environmental aspects of the Declaration of Performance should be made clear. This is especially important with regard to the choice of indicators to be declared – where EN 15804 and any product-specific cPCRs currently provide greater clarity than Annex 1, Part A of the proposal - where the phrase ‘to the extent possible..’ will be open to wide interpretation when determining which indicators are considered sufficiently reliable to form part of a Declaration of Performance. Further Information: Murray Cook Executive Director mcook@egga.com
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