OpenLobby.EU
Explore

EUROSLAG

EUROSLAG

EUROSLAG is the European association of organizations and companies concerned with all aspects of manufacturing and utilization of ferrous slag products.

Lobbying Activity

Response to Circular Economy Act

3 Nov 2025

EUROSLAG is an European association with 26 members from 16 countries, which is doing lobbying and communication on the slag-based by-products from the steel industry. These building materials and fertilisers from the steel industry have already made an major contribution to the conservation of natural resources (2000-2025(EU27 + UK) : 1.2 billion tons of natural rock substituted and 400 million tons of CO2 emissions avoided. Some comments and proposals for the CEA: 1. To improve the utilization of slag based by-products, which account for 85% of the steel industry by-products and residues, we definitely need a change in the environmental performance measurement of these materials. The aim must be to come to leaching values rather than to total content limit values. We have basically established this in Germany for road construction applications and we are working on this also for cement and concrete applications in an alliance with non-ferrous slag producers and the ashes from municipal waste management. You all are well aware of the precautionary principle, which has to be revised and overcome. To us, its one of the biggest obstacles for circular economy! 2. We should reconsider the Recycled Content point. Basically a good idea to come up with an own quota for secondary raw materials and by-products on this. But how practical are these quotas for minerals used in road construction and cement/concrete? Right now, the secondary raw materials share (incl. recycled construction materials and by-products) on this biggest material stream in Europe is about 20%. Potential to increase this share might come to a limited extent from recycled construction materials. Slag based by-products do already have a utilization rate of 95% and there will be less and different slag in a transformed steel industry. We are doing a lot of research on this together with the industry. Supply of ashes from coal combustion will sharply decrease due to the climate policy based regulatory framework. 3. Instead, and we have been working on this quite successfully at national level in Germany, we should address the need for a prioritization of secondary raw materials abd by-products in public tenders. We face the problem that these materials are sometimes not allowed in public tenders (national and regional level). If just primary raw material is part of the tender about 70% of the demand for construction materials comes from public tenders we will not have circular economy! Based on a legal opinion commissioned by the FEhS-Institute, the waste management act in Germany was revised adding a new paragraph, which sets up basically a prioritization of secondary raw materials and by-products in public tenders at national level. I am happy to explain more on this, if you are interested. We have gone the same way European level a couple of years ago. Our aim has been to make the Commission to revise the Public Procurement Directive accordingly. I have attached the policy paper of the legal opinion on this to this email. The Commission told us that they would prefer to discuss this at sectoral level. When it comes to the construction materials, there is the opportunity to work on this in the context for the revised Construction Products Regulation (CPR). According to the Commission, a public consultation amongst other issues on public procurement in the construction sector will start in November. 4. Regarding the harmonization of the "end of waste / by-products criteria" we should revise the WFD and especially the environmental performance criterium first. The current wording of Art.4 and 5 WFD requires to adopt the most stringent environmental criterium of EU 27 as a minimum requirement of a harmonized solution. As a consequence, it will become more than difficult to get the by-product status according to these harmonized criteria. Whats more, existing beneficial regulations in Member States would be jeopardized.
Read full response

Response to Evaluation of the Fertilising Products Regulation

18 Sept 2025

please see attached file
Read full response

Response to Soil Health Law – protecting, sustainably managing and restoring EU soils

2 Nov 2023

On behalf of FEhS-Institut and EUROSLAG we would like to take position on the Commissions proposal for a European Directive on Soil Monitoring and Resilience (Soil Monitoring Law). In Europe, agriculturally used soils are highly fertile due to geology, topography, climatic conditions as well as physical and chemical properties. This soil fertility must be protected for future generations. To maintain soil fertility and thus agricultural productivity in the long term, efforts must be made to minimize net land consumption especially of the most productive agricultural land on the one hand. In this regard, the draft lacks obligations for the member states to take effective measures against increasing land consumption. On the other hand, good agricultural practices must be promoted to secure soil functions and at the same time productivity. Soils are extremely heterogeneous and soil conditions may change within meters completely (particle size distribution, bulk density, porosity, humus content, etc.). Thus, rigid limit values for certain soil descriptors are not uniformly applicable to all European soils. On the contrary, a dynamic system is needed representing the entire natural range of soils and the respective soil descriptors. Therefore, we suggest not to define fixed limit values but to establish a framework in which Member States shall define science-based target ranges for the soil districts and the soil descriptors. These target ranges shall take the current natural conditions into account. This is especially important for maintaining an optimal soil pH, extractable phosphorus content, soil nitrogen content and soil organic matter content in agricultural systems. These parameters are of great importance to soil fertility and depend on each other. I.e., without sufficient nutrient input or optimal soil pH, soil organic matter status wont be hold or built up. On the contrary, a lack of nutrients will decrease yields, soil organic matter and finally soil fertility. In this regard, we propose to delete the limit values for extractable phosphorus content of Annex I part b and to allow scientifically approved national phosphorus recommendation systems consisting of minimum and maximum requirements as well as approved and validated analytical methods (Annex II Part b). Determining extractable phosphorus content according to Olsen is by far not suitable and validated in all Member States. We recommend amending Annex I Part b and Annex II Part b. Secondly, we would like to address that heavy metals are naturally occurring elements in soils and just the simple presence is no evidence for a contamination: An important legal task of soil protection is to prevent from harmful changes in the soil (see for example German Federal Soil Protection Act - BBodSchG). The prerequisites for this are: Knowledge and characterization of the typical background concentration of the respective metal in the respective soil and its assessment. In this context, it must be clearly distinguished between natural presence of elements and a contamination which is of anthropogenic origin. In addition, natural background values are in many cases higher - depending on the parent material for soil formation and soil genesis - than arbitrarily defined precautionary values. The inorganic substances (metals) are mainly due to the parent material of soil formation, while organic pollutants are almost exclusively due to human activities. Thus, we propose to complement Annex I part b of the directive that limit values for heavy metals shall not be lower than the natural background values of the soil districts. This clarification will avoid soil districts to be classified as contaminated although no human activity has influenced the respective ecosystem. Besides, we like to note that the unit µg per kg recommended in Annex I Part B is not suitable since heavy metal concentrations soils are in the range of mg per kg. We recommend amending Annex I Part B.
Read full response

Response to Agronomic efficiency and safety criteria for by-products in EU fertilising products

17 Dec 2021

Initially, the aim of Regulation 2019/1009 was to improve marketability of by-products and recycling materials on the single market and to strengthen circular economy. The draft delegated act on by-products (CMC 11) to amend Regulation 2019/1009 follows this idea and opens the FPR to by-products. Simultaneously, this draft delegated act introduces new limit values for naturally occurring elements (total chromium and vanadium) that preclude the use of slags as fertiliser. EUROSLAG rejects the proposed limit values for total chromium and vanadium since these limits result in excluding proven lime fertiliser from the single market. This would be a contradiction to circular economy and the ambition to conservation of resources. Ferrous slags from the steel production have been used for decades as lime fertiliser in agriculture in quantities of more than 500,000 tonnes per year. The equivalent amount of lime would have to be replaced by natural lime from new quarries. Cr and V are natural elements and common in soils, especially in soils derived from volcanic rock. Cr and V from ferrous slags do not pose a risk to natural soils since they appear in the same stable forms as natural Cr and V. These natural forms are neither mobile, nor plant available, nor toxic. During elaboration, EUROSLAG has repeatedly highlighted these facts to the JRC and the DG GROW’s fertiliser team without this information being heeded. An actual risk assessment based on field tests, realistic application rates and considering natural background values has not taken place. A sound deduction of limit values was not published. EUROSLAG strongly recommends withdrawing the proposed limits for total Cr and V and to hold on the rules laid down in ANNEX I PFC 2 which were agreed during the trilog negotiations! In this regard we refer again to the Commissions file note on chrome from 23rd November 2016 testifying ferrous slags harmlessness. EUROSLAG is a European association with 26 members from 16 countries, which is doing lobbying and communication on the slag-based by-products from the steel industry. These building materials and fertilisers from the steel industry have already made an important contribution to the conservation of natural resources for many decades.
Read full response

Response to New EU Soil Strategy - healthy soil for a healthy life

2 Dec 2020

EUROSLAG represents the manufacturers and processors of slag in the iron and steel industry. One important application is the use of certain slags as lime fertilizers to improve soil fertility and soil health. EUROSLAG welcomes the new initiative of the EU commission to develop a New Soil Strategy on EU level to protect soil fertility and to fight against soil degradation in Europe. All soil functions shall be in a healthy condition. Problem: Soil acidification is recognized by the scientific community to be at the source of raising soil problems. A well-balanced pH value of the soil is therefore the basis for maintaining soil fertility. Surveys and studies in several European countries showed that many agricultural and forestal used soils did not show optimal pH values and were not in a soil fertility optimum. For these reasons, acidification, soil pH management and liming are also very important and shall be include in the New Soil Strategy. Main Objectives: • Recognize soil acidity as a soil threat and stop or reduce the further soil acidification, • Sustainable soil management must include an optimal soil pH value • Soil pH value must be an important parameter of soil quality and fertility, • Adequate advice and information for farmers on the link between lime supply and soil protection, • Research funding regarding the long-term ecosystem relevant lime effects. By mentioning the problems and soil threats (erosion, soil contamination, soil sealing, desertification, salinisation) the problem soil acidification is not mentioned. An optimal acidity level of the soil is significantly influencing soil fertility, soil biology and nutrient utilization efficiency of plants. Soil structure is also optimized thanks to an adequate supply of calcium. Professional lime fertilisation is an important component of environmentally friendly, sustainable agriculture. Better soil conditions will directly result in more sustainable farming practices. EUROSLAG like to express the need to officially recognize soil acidification as threat to European soils. The new Soil Strategy shall increase awareness on the soil acidity is-sue and provide incentives to farmers. Sustainable soil managing practices, such as liming already exist and are widely available.
Read full response