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Hutnicza Izba Przemysłowo-Handlowa

HIPH

Hutnicza Izba Przemysłowo-Handlowa is the main representative body for the Polish steel industry.

Lobbying Activity

Polish steel industry demands rapid trade measures and Ukraine quotas

15 Dec 2025
Topic — The European Commission proposes a new trade measure to tackle global steel overcapacity.
Message — The association calls for adopting the proposal by early 2026 to stop importers from stockpiling. They also request extending the rules to steel derivatives and setting specific import quotas for Ukraine.123
Why — This would stop the erosion of market share and improve domestic production levels.45
Impact — Ukrainian steel exporters would lose their current exemption and face strict volume limits.67
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Meeting with Lukasz Kolinski (Director Energy)

19 Nov 2025 · Situation of the Polish steel industry

Polish Steel Association seeks direct grants in next EU budget

12 Nov 2025
Topic — The EU is planning its next long-term budget to support industrial competitiveness.
Message — The association requests direct grants rather than loans for industrial decarbonisation. They also demand the removal of the 75% aid intensity cap.12
Why — Direct grants would provide the capital needed for decarbonisation while maintaining competitiveness.34
Impact — Global climate efforts suffer if production moves to countries with higher emissions.5
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Meeting with Olga Panagopoulou (Cabinet of Commissioner Piotr Serafin) and ArcelorMittal Poland Spółka Akcyjna

16 Oct 2025 · Discussing the concerns of the steel and metal industry in Poland

Meeting with Krzysztof Hetman (Member of the European Parliament)

16 Oct 2025 · European steel market

Polish steel industry demands lower energy costs for electrification

9 Oct 2025
Topic — The EU Electrification Action Plan aims to accelerate demand-side electrification across sectors.
Message — Polish steel producers request lower energy prices and reduced network fees. They also want continued carbon cost compensation and better investment financing.123
Why — This would protect the sector from global competitors and lower its high production costs.4
Impact — Other electricity consumers may face higher charges if steel plants avoid flexibility costs.5
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Polish Steel Association Urges Higher Aid Limits and Faster Approvals

6 Oct 2025
Topic — EU consultation on revising rules for state aid exemptions to simplify industrial subsidies.
Message — The industry calls for increasing notification thresholds to 150 million euros. They demand raising aid intensity to 65% for environmental investments. The association also requests a fast-track mechanism for strategic projects.123
Why — Increased public funding would offset high technological risks and maintain production within the EU.4
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Polish steel industry demands strict rules for CBAM carbon deductions

23 Sept 2025
Topic — Setting rules for deducting foreign carbon prices from EU carbon border costs.
Message — The association demands that only effective, explicit, and net carbon costs from robust climate frameworks be recognized. They argue that carbon taxes offset by rebates or other energy taxes must be excluded.12
Why — This approach protects domestic steelmakers from competitors using hollow climate policies to bypass costs.3
Impact — Exporters from countries with symbolic climate policies or hidden subsidies will pay higher fees.4
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Polish Steel Association calls for stricter importer carbon benchmarks

23 Sept 2025
Topic — New rules for adjusting carbon border taxes based on free industrial emission permits.
Message — The group demands benchmarks based on the best environmental practices to ensure fair competition. They suggest using scrap-based standards and minimizing emission factors for stainless steel.123
Why — Aligning benchmarks with cleaner processes protects the competitiveness of European steel manufacturers.4
Impact — Foreign producers using carbon-heavy technologies will face higher costs to enter Europe.5
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Polish steelmakers urge stricter carbon border rules to ensure fairness

23 Sept 2025
Topic — The consultation defines the methodology for calculating embedded emissions under the definitive CBAM period.
Message — The association requests that carbon charges be based on the most carbon-intensive production routes to prevent resource shuffling. They also propose a melted and poured approach to accurately identify the origin of steel emissions.12
Why — These rules would protect local manufacturers from unfair competition and lower-priced high-emission imports.3
Impact — Third-country exporters using carbon-intensive methods lose the ability to underreport their actual emissions.45
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Polish steel industry demands EU content rules for corporate fleets

8 Sept 2025
Topic — EU initiative setting minimum zero-emission vehicle targets for large corporate vehicle fleets.
Message — The organization requests that the regulation includes sustainability and EU content requirements for materials like low-CO2 steel. They argue for a focus on upstream embedded emissions rather than just tailpipe performance to support industrial objectives.12
Why — This would secure a stable market for high-cost green steel and protect multi-billion euro investments.34
Impact — Foreign steel producers would lose market access due to new EU-specific content and climate requirements.56
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Polish Steel Association urges stable ETS aid for industry

5 Sept 2025
Topic — The European Commission is updating state aid rules for indirect carbon cost compensation.
Message — The association demands that current compensation structures and efficiency benchmarks remain unchanged until 2030. They insist budget increases must accompany any expansion of eligible sectors.123
Why — This would shield steel producers from stricter efficiency standards and protect their current subsidies.4
Impact — New sectors may receive insufficient aid if national budgets do not increase accordingly.5
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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 Polish Steel Association (HIPH) fully supports the development and implementation of a new, effective and comprehensive EU steel trade instrument to replace the current safeguard measure, which expires in June 2026. This new mechanism is essential in light of the ongoing global excess steelmaking capacity, the increasing risk of trade diversion to the EU market, and the urgent need to secure stable conditions for the green transformation of the European steel industry. It is important to underline that the current steel market crisis is structural and long-term in nature. This is primarily due to persistent and substantial steel overcapacity in China. The issue is further exacerbated by the spill-over effect of dumped Chinese steel flooding third-country markets, prompting local producers to aggressively export their excess capacity into the EU market. The new trade measure must fundamentally address the global overcapacity problem and must not be considered interchangeable with other instruments such as CBAM or product-specific anti-dumping measures. It should have a comprehensive and systemic character, covering all core steel products as well as downstream and semi-finished products (steel derivatives) used in the production of final goods. This is necessary to prevent circumvention and the displacement of import pressure further along the value chain a trend already threatening EU downstream manufacturers. Furthermore, the measure should apply universally to all third countries, without exemptions or suspensions, to ensure fairness, market transparency, and effectiveness. Any exemptions (including the current suspension for Ukraine) would create imbalances within the internal market and weaken the measures integrity. Mechanisms must be included to prevent disruptions in national markets and guarantee a fair distribution of import volumes across Member States. We therefore support the proposed reform of the existing safeguard measure based on revised tariff-rate quotas (TRQs). The current mechanism has proven insufficient, as evidenced by the erosion of EU steel producers market share. The new trade instrument should aim to restore a sustainable level of capacity utilisation in the EU, which is essential for profitability and investment in decarbonisation technologies. HIPH calls for significantly reduced TRQ volumes to reflect realistic and sustainable import shares in the market. Target import shares should be set at 15% for flat carbon and stainless steel products, and 5% for long carbon products. Moreover, the current 25% out-of-quota tariff should be increased to effectively deter excessive imports. The new measure should also consider the level of protection applied by the US under Section 232, ensuring a level playing field globally. We would like to emphasise that a well-calibrated TRQ system as opposed to a blanket tariff allows for continued steel supply based on demand and mitigates the risk of shortages, while still offering a strong protective function for EU industry. This approach is not protectionist, but rather a necessary response to structural global distortions that threaten the survival of key EU industrial capacities. We call to ensure that the new measure reflects a value chain perspective. Stakeholders across the steel ecosystem including downstream sectors recognise the need for a strong trade instrument that addresses both excess capacity and the costs of decarbonisation. These are complementary challenges, and the trade instrument must be one pillar alongside CBAM and industrial policy to support a viable and climate-resilient European steel industry. In conclusion, HIPH supports the introduction of a new, comprehensive trade defence mechanism based on reduced and fair TRQs, a higher out-of-quota tariff, and no country-specific exemptions, as a vital tool for securing the future of steelmaking in Europe and safeguarding the integrity of the entire industrial value chain.
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Polish Steel Association urges non-repayable grants for decarbonization

8 Jul 2025
Topic — An evaluation of the EU Innovation Fund's support for industrial climate action.
Message — The association requests that funding primarily take the form of non-repayable grants. They call for simplified application procedures to support long-term strategic investments. The steel sector should be explicitly recognized as a priority within the fund.12
Why — This would alleviate the industry's inability to finance expensive low-emission technology independently.3
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Polish Steel Association urges no further cuts to free allowances

8 Jul 2025
Topic — The consultation reviews the EU emissions trading system and the market stability reserve rules.
Message — The association calls for maintaining free CO2 allowances and financial help for high electricity bills. They also request preserving fair competition rules for factories using electric furnaces.12
Why — This would lower production costs and protect the industry from international competition.34
Impact — Non-EU steel producers lose their competitive advantage over energy-intensive European factories.5
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Polish Steel Association Urges Shift to Direct Decarbonization Grants

12 May 2025
Topic — Evaluation of the Modernisation Fund’s rules to support climate action and industrial transition.
Message — The association requests that industrial decarbonization be classified as a priority to improve funding predictability. They also argue that only direct grants can support the sector's green transition.12
Why — Grants would reduce financial risk and provide the stability needed for long-term industrial modernization.34
Impact — Foreign steel exporters would lose their competitive edge as Polish mills receive direct subsidies.5
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Meeting with Krzysztof Hetman (Member of the European Parliament)

11 Feb 2025 · Situation of european steel industry

Meeting with Ditte Juul-Joergensen (Director-General Energy) and European Chemical Industry Council and

28 Jan 2025 · Competitiveness, Clean Industrial Deal and energy and their impact on European industry.

Response to Establishment of the CBAM Registry

26 Nov 2024

As the Polish Steel Association (HIPH), we would like to present our position on the public consultation regarding the draft Regulation on the CBAM Registry. The draft Regulation offers a critical opportunity to reflect on the design and functionality of the electronic infrastructure necessary for the implementation of the Carbon Border Adjustment Mechanism (CBAM). While it is essential to maintain the confidentiality of sensitive business information, a high level of transparency in the CBAM Registry is crucial for public scrutiny and input. This transparency can lead to more robust and well-considered policies. We have serious concerns about the expected lack of transparency in the CBAM Registry, especially when compared to the EU Emissions Trading System (EU ETS) Registry. The current CBAM legal framework, particularly article 21 of the draft CBAM Registry Regulation and article 14 of the basic CBAM Regulation 2023/956, effectively deems all information in the CBAM Registry as confidential. The Commission would only publish an annual report on total aggregated emissions by CBAM goods. In contrast, the EU ETS Registry Regulation 389/2013 (Annex IX) provides public access to most relevant information, including contact details of European installations and details on total emissions and free allocation for each installation. This high level of transparency is linked to Directive 2003/4/EC on public access to environmental information, which is explicitly referenced in the ETS Registry Regulation. However, no such reference is included in the Draft CBAM Registry Regulation. We urge EU institutions to revise the draft CBAM Registry Regulation and review the relevant provisions of the basic CBAM Regulation during the 2025 revision. It is essential to ensure that the CBAM registry is as transparent as the EU ETS Registry. For instance, this consistency requires that contact details of CBAM declarants and third-country operators, as well as total emissions and total available CBAM certificates for each of them, are made publicly accessible.
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Meeting with Marlena Maląg (Member of the European Parliament)

16 Oct 2024 · Problems of the steel industry sector

Meeting with Mirosława Nykiel (Member of the European Parliament)

15 Oct 2024 · Challenges of the industry in the European context

Meeting with Marcin Sypniewski (Member of the European Parliament)

1 Oct 2024 · Introductory meeting

Meeting with Jerzy Buzek (Member of the European Parliament)

19 Mar 2024 · Polish industry

Response to European Critical Raw Materials Act

25 Nov 2022

The steel industry welcomes the European Commissions initiative to secure the sustainable access to critical raw materials. This is necessary to support the EU ambition to be the first climate neutral continent, to lead the digital decade and to be sure that the future of industry is made in Europe. The steel industry, as a backbone of the EU economy, can also significantly contribute to meeting the challenging Green deal targets, while delivering technologies and solutions to transform EU into a competitive, low-carbon economy. In particular, the transition to a low carbon and circular economy will make secondary raw materials increasingly important. We thus believe the time has come to include ferrous scrap, an essential secondary raw material, in the list of CRMs. At the same time, the threat posed by Russia to Europe's security teaches us that Europe must use your own primary as well as secondary sources of materials so as not to be exposed to the blackmail of others countries and maintain growth and remain globally competitive. It should be emphasized that the availability of secondary raw materials recovered from waste is essential for the EU to meet its demand and reducing dependence on imports of primary raw materials from other regions. In this context, ferrous scrap is a particularly valuable resource for the EU steel industry, helping to reduce consumption primary raw materials and has the potential to reduce emissions by 1.4 to 5 tonnes of CO2 per tonne of steel produced, dependingon the grade of steel and the steelmaking process. Ferrous scrap is by far the most exported waste from the EU, accounting for more than half of all exported waste, with a very worrying increase in the volume of exports in recent years (+113% in 20152021), reaching a historical maximum in 2021. It can be estimated that almost 20% of scrap generated in the EU leaving Europe. A number of measures are needed to ensure the effectiveness of the rules and to contribute to the objectives of both the EU Circular Economy Action Plan and the EU's green deal. Steel scrap is the basic raw material for production in electric steelworks (EAF) and a significant one, several percent additive in integrated metallurgy (BF/BOF). In Poland alone, we process over 6 million tons of steel scrap per year. Unfortunately, exports of scrap from the European Union amount to as much as 20 million tons per year. Furthermore, the list of critical raw materials needs to be extended to additional primary raw materials in order to prevent most likely future shortages that can have significant impact on key EU industries and thus affect the EU economy and its priority sectors. Materials that should be added to the list of CRMs given their criticality to the European steel industry include ferrous scrap, nickel, manganese.
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Meeting with Jerzy Buzek (Member of the European Parliament, Rapporteur)

6 Sept 2022 · "Fit for 55" and gas&hydrogen package

Response to Guidance on accelerating permitting processes for renewable energy projects and facilitating Power Purchase Agreements

12 Apr 2022

The Polish Steel Association (hereinafter: "HIPH", "Association") represents the steel industry in Poland. With reference to the invitation to submit comments in the public consultation, the Association submits its feedback and requests to consider it in the future guidelines. General Notes: 1. Increasing the production of electricity from RES is the most important objective, because of the favorable price and low carbon footprint of green energy. The Association supports changes to simplify the investment process for renewable energy sources. 2. In Poland, long administrative procedures and the problem of renewable energy investments’ localization are the greatest barrier to these investments. In 2017-2019 practically no new wind projects were implemented, and it is not better now either. 3. In Poland, many regulations need to be amended: the Act on investment in wind power plants, the Acts regulating spatial policy and land use, and the Acts regulating the process of obtaining administrative permits. 4. At the European Union level, guidelines should be introduced to facilitate the location of investments throughout the country, e.g. each municipality should designate an area for investment in renewable energy sources and special facilities for investment in selected areas, e.g. special zones or post-industrial areas or other areas that can serve these investments. Locations would be agreed with selected municipalities. For this purpose, a system of incentives for municipalities financed from the central level should be created. 5. Administrative permits should be easy to obtain. Instead of a building permit, where possible, we propose to use a notification formula. 6. The Association believes that the fastest way to create additional renewable energy capacity is to build new photovoltaic facilities under a simplified investment process for photovoltaic facilities that meet the following conditions: 1) connection to the recipient's grid (in the formula of direct line or self-production), 2) energy consumption for the recipient's needs - the projected annual production should not exceed 20% of the recipient's annual consumption. Projects that meet these criteria should be subject to special exemptions in terms of obtaining permits in the investment process, e.g. the municipal council adopts a resolution on determining the location of the investment or refusing to determine the location of the installation within 60 days from the date the investor submits the application for determining the location of the investment. Instead of the requirement to obtain a construction permit decision, we recommend to implement a notification formula. Generating installations meeting the above criteria should be exempted from the obligations imposed by the Network Code For Requirements For Grid Connection (RfG), in the procedure provided by Article 60 of Regulation 2016/631.
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Polish steel industry demands free carbon allowances until 2030

17 Nov 2021
Topic — The EU is consulting on a mechanism to price carbon imports.
Message — The association demands full free carbon permits until at least 2030. They also want the mechanism to cover electricity costs and protect European exporters.123
Why — Retaining free allowances would prevent a multi-billion euro cost burden.4
Impact — Foreign producers would face tougher default carbon penalties and potential bans.56
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Polish steel industry urges protection for free carbon allowances

8 Nov 2021
Topic — The European Commission is revising the Emissions Trading System to meet 2030 climate goals.
Message — The industry wants to keep 100% free allowances while introducing the carbon border tax. They also oppose making free allowances conditional on mandatory energy efficiency investments.12
Why — This would reduce regulatory costs and protect the industry's competitiveness during the energy transition.3
Impact — Climate goals may suffer if free allowances are provided without requiring energy efficiency improvements.4
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Meeting with Jorge Pinto Antunes (Cabinet of Commissioner Janusz Wojciechowski), Maciej Golubiewski (Cabinet of Commissioner Janusz Wojciechowski) and The European Steel Association

19 Oct 2021 · Impact of the proposed amendments to the EEAG on the competitiveness of the Polish steel industry

Response to Revision of the Communication on important projects of common European interest

21 Dec 2020

Today, companies cannot invest in low CO2 technologies in steel that will entail an increase in production costs, as there is no market that would factor in the extra cost of low CO2 steel vis-à-vis conventional steel products with similar properties. Elements that would increase substantially operational costs of low CO2 technologies are for example the use of new energy carriers and feedstocks, such as renewable energy and hydrogen. This would apply to technological pathways Carbon Direct Avoidance and Smart Carbon Usage in steel. The IPCEI Guidelines shall allow financing of projects at full industrial scale and provide adequate financial support of eligible costs, reflecting in particular higher operational costs. The following modifications are proposed: Include – under point 23 - a general compatibility criterion “conversion to low CO2 production”, according to which support for additional investment and operating costs with an aid intensity of 100% is expressively permitted under the state aid rules. For projects, which invest into installations with a long lifetime, the funding gap calculation should not be made across the full lifetime of the investment (point 31), but rather be confined to the duration of the project. The Communication specifies that First Industrial Deployment (FIDs) does not entail “mass production” nor “commercial activities” (footnote 1, Annex). This is highly problematic, as the successful deployment of low CO2 steel production necessitates testing and implementation at industrial scale. Given the high technological and financial risk that is intrinsic to projects introducing new process technologies at such a massive scale as it is required in the steel industry, it is particularly important to allow IPCEIs to cover the entire period of the investment (economical lifetime of a project), which for steel is usually up to 20 years. Against this background it should be provided that “mass production and commercial activities are allowed for at least the first 10 years of operation and/or as long as the production is characterised by an innovative element”. Synergies between public funding under an IPCEI and other funding programs at EU and national level (e.g. EU Innovation Fund) could prove an additional factor for a success demonstration of low CO2 technologies in energy intensive industries. The combination of the different instruments could provide both the necessary pool of resources, lowering at the same time the economic risk intrinsic to such projects. Therefore, the co-financing requirement of the beneficiary should be extended by the option of co-financing by other funds. Specifically, a provision should be added to clarify that it is allowed without any restriction to consider the relevant costs of project proposals submitted to the EU Innovation Fund, as being equivalent to and compatible with the IPCEI funding gap methodology calculation. Under point g) of the Annex on eligible costs, the Communication allows for the financing of CAPEX and OPEX of FIDs projects until "as long as the industrial deployment follows on from an R&D&I activity ". This misses the point, because obstacles to decarbonisation of production processes are not only of technical nature (which should be overcome by R&D) but also necessitate to develop viable business models in the context of international competition. This is true to all low CO2 technologies (e.g. hydrogen-based metallurgy, process integration, CCU and “recycled carbon products”). Point 31 of the Communication does not provide detailed information on the calculation of the funding gap. Guidelines and other supporting documents – case examples - could be instrumental in ensuring better application of the IPCEI Communication, including on questions such as how to integrate projects under an IPCEI, co-financing from other EU programs. Define in the Communication a harmonized methodology for monitoring and reporting of the funds obtained under IPCEIs.
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Response to Climate change mitigation and adaptation taxonomy

18 Dec 2020

Polish Steel Association welcome the legislative attempts to mobilise investment in the EU to achieve sustainable growth in line with the Union’s climate goals and its Paris Agreement commitments. A common EU taxonomy for sustainable finance could play an important role in this process if drafted in a way that takes the specific characteristics of the affected industries into account, based on robust scientific evidence. This should certainly be the case with the steel industry, which has the greatest potential to reduce carbon emissions volumes of any productive industry, and in which environmental performance can only be evaluated by considering its overall production value chain. Unfortunately, the draft Commission delegated act (setting the technical screening criteria against which an operation’s climate mitigation and adaptation ability is evaluated) narrowly focuses on only some parts of the steel production’s CO2 emissions. The main reason is that unlike for other sectors, the steel Hot Metal benchmark does not take all direct emissions into account due to the huge exported volume of waste gases, due to ETS free allocation rules reasons.
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Response to Revision of the Energy and Environmental Aid Guidelines (EEAG)

9 Dec 2020

Polish Steel Association is a non-profit trade organization of steel manufacturers and steel processing plants that represents Polish steel industry. We promote all initiatives supporting energy-intensive sectors of the European industry. Polish steel sector is currently facing an unfair competition from third countries’ producers unhindered by the regulatory costs related to climate policy, such as EU ETS system. Even under the current EUA price, extra direct and indirect emission costs already manifest in relocation decisions of European steel producers. The projected increase in ETS cost will only deteriorate the situation of the steel industry and inevitably lead to an increased carbon leakage. In the Inception Impact Assessment, the European Commission states that the Fitness Check has shown that it is unclear whether the existence of reductions for EIUs has led to the introduction of more ambitious renewables policies. The Polish Steel Association would like to point out that the analyses, that were carried out in the Fitness Check, were very simplified and do not justify such a strong statement. In particular, this conclusion fails to take into account important factors such as - in the Polish case - the changes in renewable support system and discontinuation of the old systems. The Commission should seek to substantially expand the analysis beyond the results of the Fitness Check, taking into account a wider range of factors and data. In Poland, the reductions of energy charges for EIUs have significant importance for the introduction of an ambitious climate policy. However, current EEAG does not directly allow to grant the EIUs reductions in charges other than the RES. The European Commission should investigate the link between the reduction in fees on the basis of the EEAG and the development of other support mechanisms, especially including the impact of extending the reductions on capacity mechanisms financing. The Commission should also assess potential impact of broader and more flexible clause in section 3.7 of the EEAG. In the Inception Impact Assessment, the Commission considers amending the EIUs reduction regulation, in particular in form of: changing the list of eligible sectors in the EEAG, introducing some form of environmental conditionality and increasing of the consistency with the new state aid rules for indirect costs compensation for the fourth trading period of the EU ETS. All changes in the list of eligible sectors and rules for granting support carried out by the Commission should be based on detailed exhaustive analyses, built on clearly defined data with an indication of their sources, collection period and methodology. The steel industry is facing decarbonization and technological transformation. Nevertheless, the transformation process is extremely difficult in terms of financing investments, maintaining international competitiveness and technological challenges. The EIUs may not be able to cope with this challenge alone. The Commission should analyze the existing forms of support for EIUs in the context of the decarbonization and transformation of their production sites.
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Polish steel association urges continued free carbon permits

26 Nov 2020
Topic — The EU is reviewing its emissions trading system to meet higher 2030 climate targets.
Message — The association calls for continued protection through free emission permits and warns against including transport or buildings in the ETS. They argue that the burden of increased climate goals should fall on non-industrial sectors.123
Why — This would reduce compliance costs and maintain the industry's competitiveness against foreign rivals.45
Impact — Households and the transport sector would face higher costs to meet climate targets.6
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Response to Sustainable Products Initiative

16 Nov 2020

The main goal of the circular economy should be supported, i.e. increasing the use of secondary raw materials, and thus reducing the amount of waste directed and deposited in landfills. Creating a catalog of critical secondary raw materials toi be considered that should be governed by other / separate rules than for waste in order to increase their use. One of the examples of secondary raw materials that could be included in such a catalog is steel scrap, which is a key raw material for the steel industry, and thus must meet certain parameters. It is advisable not to establish additional indicators - measures in the field of circular economy should be based on a simple model and constitute an incentive to use secondary raw materials. Additional, very often complicated indicators, associated with a huge amount of paperwork and a lot of bureaucracy, can discourage companies from moving to a circular economy. "Product as a Service and Extended Producer Responsibility" This is a very difficult issue and, in our opinion, it is impossible to apply in all industries, especially if the products have a global reach, such as in the case of steel. At the same time, extending the life cycle of products, which is one of the main goals of the circular economy, is aimed at reducing the negative impact of products / products on the environment. This may be different for products / articles with a short life cycle. In our opinion, "product as a service" should be dedicated to this second category of products / articles. "Sustainable Products Policy Initiative" Much emphasis should be placed on identifying the available production processes / technologies that enable the use of secondary raw materials. An important aspect that allows the use of recyclable materials is the issue of eco-design of products. In our opinion, product features are a secondary aspect. In the first place, it is necessary to refer to the production processes / technologies that will be the driving mechanism of changes in various industries. "General comment on indicators" In terms of developing appropriate indicators, which, as mentioned above, should not be another "obligation" for entrepreneurs. In our opinion, the indicators should refer to the possibility of replacing primary (natural) raw materials with secondary raw materials, taking into account the technical possibilities of their use. It is also worth considering taking into account already functioning mechanisms / indicators, e.g. ecological certificates in construction, incl. in the field of obtaining raw materials for building materials, also taking into account waste recycling, i.e. the LEED multi-criteria building assessment system (Leadership in Energy and Environmental Design) and the multi-criteria building certification system BREEAM (Building Research Establishment Environmental Assessment Method). Energy use of waste as an activity in line with the waste management hierarchy and in line with the activities of circular economy It is also worth indicating the possibility of waste management, including those that should be sent to landfills due to the lack of possibility of their further use, and in accordance with the waste management hierarchy. Therefore, the possibility of energy use of waste (for the production of electricity and heat) in existing industrial installations should be considered as an activity in line with the concept of circular economy. On the one hand, the proposed approach will allow for "closing" the circulation and proceeding in accordance with the principles of the waste hierarchy, and on the other hand, it will allow for the reduction of natural resources used for energy purposes.
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Response to Climate change mitigation and adaptation taxonomy

22 Apr 2020

Polish Steel Association as a member of The European Steel Association, EUROFER, welcomes the opportunity to contribute to the Commission’s Inception Impact Assessment on the EU Taxonomy for Sustainable Finance. The contribution is evident in the many value chains that rely on steel, and can be demonstrated through integrating lifecycle approaches such as Life Cycle Assessment. It is essential that technical screening criteria for sustainable finance follow the requirements of article 11a and article 14 (f) of the Regulation, which emphasise the necessity of “taking life cycle into account, including evidence from existing life cycle assessment, by considering the environmental impacts of the economic activity itself, as well as of the products and services provided by that economic activity, notably their production, use and end-of life”. A summary of our main concerns is listed below: • Using genuinely an integrated lifecycle approach to take into account steel as an enabler for CO2 mitigation in multiple value chains. • Using the principles of standard EN 19694-2, developed with a mandate from the EU Commission, to assess relative performance in place of unsuitable ETS benchmarks where lifecycle approach is not available. • Greater coherence with other approaches, such as those used in the EU Innovation Fund. • Securing the eligibility of EAF steel production without excluding different steel qualities, like stainless steel, due to the threshold proposed on scrap sourced iron content in final products. • Adding CCU to the list of low carbon breakthrough technologies and taking all sources of hydrogen - as well as from iron and steel production – into consideration. • Make allowances for the fact that the decarbonisation pathway for steel will not be linear, requiring step changes and investments spanning several decades.
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Response to EU rules on industrial emissions - revision

17 Apr 2020

Polish Steel Association(HIPH) shares the joint position of the European steel sector. Due to the COVID-19 pandemic, many steel operators cannot effectively contribute to Commission activities or are simply not available. Therefore, this contribution cannot comprehensively reflect the full view of the sector. While you will find in annex our detailed feedback on the aspects to take into account when considering options to improve the industrial emissions framework, our general messages can be summarised as follows: • With the publication of an inception impact assessment before the publication of the Ricardo study or Commission Staff Working Document, the European Commission is contradicting its own 'evaluate first' principle set out in its Better Regulation Guidelines. • It is important that the Commission informs stakeholders well in advance and considers longer response times so that industry can effectively contribute while addressing crisis-related matters at the same time. • The assessment of the consistency between the IED, Circular Economy (CE) and climate neutrality set out in the EU Green Deal (EGD) should not compromise the key objective of the IED, which is to prevent or limit pollution into the environment from processes in an integrated way. • A review of the Seville process could solve most of the issues identified by the IED evaluation, e.g. climate, energy and circular economy. • Legal certainty should be ensured throughout the revision process. To this end, no new BREF review cycle should be initiated until a revised IED enters into force.
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Response to Carbon Border Adjustment Mechanism

30 Mar 2020

The development of an effective carbon border adjustment is essential as basis for the transition to carbon neutrality of the steel sector production in Europe and a crucial cornerstone of European Green Deal success. To get that right, the following documents are attached, which we request to take into account in the assessment and policy: • Steel sector EUROFER paper on border adjustment and carbon leakage measures; • Legal note by 3 law firms on carbon border adjustment & the summary page of this document; • Steel sector EUROFER annex to the consultation on draft ETS Guidelines - to highlight that steel is at very high risk of carbon leakage
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Meeting with Andrzej Celinski (Cabinet of Commissioner Elżbieta Bieńkowska), Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska), Tomasz Husak (Cabinet of Commissioner Elżbieta Bieńkowska)

9 Jul 2019 · Steel

Meeting with Elżbieta Bieńkowska (Commissioner) and

4 Sept 2018 · Exchange of views on current topics

Meeting with Elżbieta Bieńkowska (Commissioner) and

21 Jan 2016 · Situation of the steel sector in Poland and its future in the European and world market