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Jernkontoret

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Jernkontoret is the Swedish steel industry association representing trade, energy, and climate interests.

Lobbying Activity

Swedish steel industry calls for realistic EU taxonomy criteria

5 Dec 2025
Topic — The initiative reviews the EU taxonomy environmental delegated act for technical criteria.
Message — Jernkontoret proposes replacing static emission benchmarks with a life cycle approach. They recommend using NACE codes for reporting to align with real-world operations. Finally, they suggest removing operating expenditure reporting requirements for all companies.123
Why — These changes would reduce administrative costs and ensure financial reports accurately reflect revenue.456
Impact — Financial analysts lose specific sustainability data if operating expenditure disclosures are completely removed.7
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Meeting with Karin Karlsbro (Member of the European Parliament, Rapporteur)

4 Dec 2025 · Stålmarknaden

Meeting with Jörgen Warborn (Member of the European Parliament)

12 Nov 2025 · EU trade steel instrument

Meeting with Karin Karlsbro (Member of the European Parliament, Rapporteur)

10 Nov 2025 · Stålmarknaden

Swedish steel association Jernkontoret urges EU-wide criteria for by-products

6 Nov 2025
Topic — The European Commission is consulting on the new Circular Economy Act to enhance sustainable production.
Message — The organization requests the development of EU-wide criteria for by-products and the creation of harmonized scrap standards to improve market transparency. They also advocate for an enabling framework that avoids regulatory duplication while allowing for more flexible, extended storage of recyclable materials.123
Why — These measures would secure a stable supply of materials and reduce the legal complexity of cross-border trade.45
Impact — National regulators lose some autonomy as EU-wide standards replace varying member state criteria.6
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Swedish Steel Industry Urges Standardized Building Climate Rules

30 Oct 2025
Topic — The EU is creating a framework to measure the total climate impact of buildings.
Message — Jernkontoret supports a unified system to improve transparency and climate performance across the EU. They advocate for assessments that include the full building life-cycle and recycling benefits.12
Why — Harmonized reporting would allow the industry to prove the climate benefits of recyclable steel.3
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Jernkontoret urges EU to prioritize industrial competitiveness and low prices

8 Oct 2025
Topic — The EU Electrification Action Plan aims to shift energy demand from fossil fuels to electricity.
Message — Jernkontoret wants lower electricity prices and reduced fees to protect European industrial competitiveness. They oppose new electrification targets, preferring a technology-neutral approach to reach decarbonized power by 2040. The EU should evaluate the pricing system to stop fossil fuels from setting high electricity costs.123
Why — Lower energy costs would prevent carbon leakage and maintain the industry's international market position.4
Impact — Fossil fuel suppliers lose out if the EU moves away from the current marginal pricing model.5
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Meeting with Sofie Eriksson (Member of the European Parliament) and Outokumpu Oyj

8 Oct 2025 · EU:s tullpolitik och påverkan för stålindustrin

Swedish Steel Producers Urge CBAM Expansion to Downstream Products

25 Aug 2025
Topic — Consultation on extending carbon border taxes to downstream goods to prevent industrial carbon leakage.
Message — Jernkontoret requests expanding CBAM to include steel-intensive downstream goods to prevent circumvention through outside processing. They advocate for mandatory default values and improved traceability to ensure environmental integrity.12
Why — This expansion would reduce carbon leakage risks and protect investments in low-carbon steel production.3
Impact — Importers using resource shuffling to avoid certificates would lose their competitive advantage over EU producers.4
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Response to Trade measure addressing the negative trade-related effects of global excess capacity on the EU steel sector

14 Aug 2025

response to the public consultation on the new steel trade measure
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Swedish steel industry urges fair burden-sharing in EU climate policy

7 Jul 2025
Topic — Review of EU Emissions Trading System and Market Stability Reserve for 2026.
Message — Jernkontoret requests equal burden-sharing across sectors for the 2040 target, with transport, buildings and agriculture taking larger shares after 2030. They call for a functioning CBAM with export solutions, compensation for indirect electricity costs across all Member States, and cautious handling of biomass use to prioritize high-value industrial applications.123
Why — This would reduce competitive disadvantages for Swedish steel producers facing electricity cost impacts without compensation.45
Impact — Other sectors like transport, buildings and agriculture would face increased emission reduction burdens after 2030.6
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Jernkontoret warns against regulatory burden in decarbonisation act

4 Jul 2025
Topic — The initiative aims to accelerate industrial decarbonisation while supporting European competitiveness and productivity.
Message — Jernkontoret calls for a broad framework avoiding sector targeting while reducing administrative and reporting burdens. They advocate for streamlined permitting processes and the adaptation of water regulations to facilitate industrial transformation. Finally, they recommend using public procurement instead of strict content requirements to build lead markets.123
Why — Streamlined permitting would allow steel companies to accelerate decarbonisation investments and focus on innovation.4
Impact — Environmental groups lose oversight when industrial projects are exempt from impact assessments.5
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Meeting with Bruno Tobback (Member of the European Parliament) and Vinces Consulting and

4 Jun 2025 · Working Breakfast WHAT POLICIES ARE NEEDED TO PROMOTE AFFORDABLE GREEN ENERGY AS A COMPETITIVE ADVANTAGE: SHARED LESSONS FROM SWEDEN AND SPAIN

Meeting with Axel Hellman (Cabinet of Commissioner Jessika Roswall), Luis Planas Herrera (Cabinet of Commissioner Jessika Roswall) and

4 Jun 2025 · Sustainable industry

Meeting with Veronica Manfredi (Director Environment)

4 Jun 2025 · Representatives of Jernkontoret presented the ongoing challenges faced by various industrial sectors regarding obtaining permits under the Water Framework Directive (WFD).

Meeting with Sofie Eriksson (Member of the European Parliament)

5 May 2025 · En ansvarstagande vattenförvaltning i Sverige

Meeting with Tomas Tobé (Member of the European Parliament, Shadow rapporteur for opinion) and Confederation of Swedish Enterprise

27 Mar 2025 · Industrial Policy

Swedish steel industry urges simpler EU taxonomy reporting rules

26 Mar 2025
Topic — The EU is amending taxonomy rules to make sustainability reporting simpler and more cost-effective.
Message — Jernkontoret supports reducing data points and aligning chemical safety criteria with existing EU REACH legislation. They request that reporting covers full industrial activities rather than specific intermediate process steps.123
Why — This would reduce administrative burdens and help companies avoid reporting errors or misunderstandings.45
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Response to European Water Resilience Strategy

4 Mar 2025

A strategy for water resilience is both welcome and central to the major Swedish water stakeholders of which we, the Swedish Steel Industry, are part. Sweden contributes to a significant part of EU's total water resources (20%) and EU's lakes (40%) thus a strategy on water resilience has a tremendous impact on us and should ensure a stable water supply amid climate change. In Sweden, frequent droughts, floods, and rapid temperature increases highlight the need for resilience and preparedness at national and local levels. Please see the attached paper called Towards a water resilient Europe that emphasizes a European water strategy based on five principles. We would like to highlight the importance of considering national, regional, and local conditions and let issues such as water pricing be dealt with at national level allowing for stakeholders to be properly involved at a local level. Agreeing on definitions such as water use and water consumption are also crucial to reach a common understanding and collaborate. Note that in the Swedish steel industry, 80-90% of water used is currently being recirculated, limiting improvement potential. Lastly a strategy for water resilience should assess policy gaps and opportunities for improvement. This analysis should take into account the extensive existing legislation such as the Industry Emissions Directive and the Water Directive. A successful implementation of the EU Water Framework Directive requires reviewing parts that slow down environmental improvements. We look forward to continue the dialogue about water resilience.
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Meeting with Luis Planas Herrera (Cabinet of Commissioner Jessika Roswall)

5 Feb 2025 · Clean Industrial Deal

Meeting with Jessica Polfjärd (Member of the European Parliament) and Byggföretagen

10 Jan 2025 · Chemical and climate policy

Meeting with Jessica Polfjärd (Member of the European Parliament) and Teknikföretagen

9 Jan 2025 · Chemical policy

Meeting with Dan Nica (Member of the European Parliament) and The European Steel Association and

20 Nov 2024 · Debate on the European Steel Industry

Meeting with Jessica Polfjärd (Member of the European Parliament)

15 Nov 2024 · Water resilience

Meeting with Hildegard Bentele (Member of the European Parliament, Shadow rapporteur) and European Environmental Bureau and

16 Oct 2024 · Surface water and groundwater pollutants

Meeting with Alice Teodorescu Måwe (Member of the European Parliament)

9 Oct 2024 · Lunch event together with Swedish and Finnish Steel and Metal value chain representatives

Meeting with Tomas Tobé (Member of the European Parliament)

16 May 2024 · Industry Policy

Swedish steel association urges flexible ETS free allocation rules

29 Dec 2023
Topic — The consultation updates rules for free carbon permit allocation under the ETS.
Message — The group suggests excluding crisis-affected years from the baseline production calculation. They also request more time to implement energy efficiency audit recommendations.12
Why — This would prevent a decrease in free carbon allowances due to temporary production drops.3
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Swedish steel sector demands further cuts to reporting burden

7 Jul 2023
Topic — New EU standards for companies to report environmental, social, and governance sustainability information.
Message — Jernkontoret calls for further streamlining of reporting obligations to reduce the administrative burden on companies. They request clearer guidelines for value chain reporting and the use of competitiveness checks for new rules.12
Why — These changes would lower compliance costs and protect the global competitiveness of steelmakers.34
Impact — Transparency advocates and investors would receive less detailed data from industrial companies.5
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Response to Ecodesign for Sustainable Products - Product priorities

12 May 2023

Jernkontoret welcomes the opportunity to give feedback on product priorities under the Ecodesign for Sustainable Products Regulation (ESPR). Steel produced in the EU plays a crucial role in achieving the challenging goals of the EU Green Deal and transitioning to a circular European economy. Jernkontoret support the submission provided by Eurofer (https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/13682-New-product-priorities-for-Ecodesign-for-Sustainable-Products/F3415566_en). In short we ask the Commission to consider the following key messages: Steel should be prioritised under the ESPR Work plan. It is necessary to assess steel as an intermediate product, as well as its contribution within end products or applications, to fully cover the unique properties and performance steel can bring. It is important to set minimum environmental sustainability performance requirements based on lifecycle impacts and assessed by a common lifecycle assessment method such as Product Environmental Footprint (PEF). ESPR requirements should be coherent with other legislation concerning product life cycle and ensure a level playing field for products and materials on the EU market. The use of secondary materials (scrap) should be recognised under the ESPR. However, it is equally important to also foster the appropriate recovery of scrap and secondary raw materials. Their additional availability (in volume and quality) is key to increasing recycled content, recyclability and reducing emissions. The use of steel industry by-products should be recognised and incentivised as a contribution to the circular economy, as they displace the use of primary materials. The creation of lead markets is indispensable to boost the demand for steel products with a reduced carbon footprints.
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Meeting with Dan Nica (Member of the European Parliament)

3 May 2023 · Industrial Emissions Directive

Jernkontoret slams recycled content targets for steel in EU Taxonomy

1 May 2023
Topic — The EU is defining sustainable economic activities for investment purposes under the Taxonomy.
Message — The organization objects to mandatory recycled content targets for metals in construction. They urge alignment with existing chemical laws to ensure consistency and facilitate easier compliance for operators.12
Why — The association would avoid sourcing constraints caused by the limited global scrap supply.34
Impact — Regulators lose a specific mechanism to mandate higher recycled content in buildings.5
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Meeting with Erik Bergkvist (Member of the European Parliament)

8 Mar 2023 · Möte

Meeting with Dan Nica (Member of the European Parliament)

1 Feb 2023 · Industrial Emissions Directive

Meeting with Heléne Fritzon (Member of the European Parliament)

24 Jan 2023 · Industriutsläppsdirektivet - Svenskt Näringsliv/Jernkontoret

Response to European Critical Raw Materials Act

24 Nov 2022

Key message Enhance the opportunities for exploration and extraction in general in the EU. Critical Raw Materials are often extracted as a by-product of base metal and iron. Access to many of these metals will become scarcer in the future. The scope of the CRM Act should therefore be widened Strengthen the EUs critical raw materials value chainby promoting extraction of minerals in general rather than defining and granting certain projects a particularly favourable treatment Make possible increased business driven diversification of source of supply. Business are best tasked to assess and arrange their value chains. The CRM Act should support this by facilitating the emergence of new trade routes globally Avoid hitting companies with administrative burdens in the form of monitoring and mandatory informationcollection. The act is interlinked with several other current or coming European legislation. It is crucial that these are synchronized, and that double regulationis avoided. The existence of strategic reserves should be a national issue primarily based on national security Promote the material-efficient recycling of critical raw materials.
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Meeting with Jessica Polfjärd (Member of the European Parliament)

12 Oct 2022 · Fit for 55 (EU climate policy)

Meeting with Tomas Tobé (Member of the European Parliament, Rapporteur for opinion)

12 Oct 2022 · Industrial Emissions Directive

Response to Review of the Construction Products Regulation

5 Jul 2022

Jernkontoret, the Swedish iron and steel producers' association, supports the overall problem description in the proposal. "Greening" of construction products have an important role in the transition to circular economy and decreasing climate impact. Harmonised legislation at EU-level is needed to create an inner market with fair competition. National initiatives can lead to different requirements on reporting and assessment in different member states. This will make reporting more complex and require more resources for companies (thereby decreasing the incentives to develop products with lower environmental impact). We therefore welcome that the new proposal for Construction Products Regulation (CPR) also comprises harmonized requirements related to environmental performance. We are looking forward to seeing the future development of the proposal. Our additional comments at this point are found below. Coordination with other product legislation Jernkontoret welcomes that the proposal contains suggestions on coordination with other product legislation. Especially the proposal on Ecodesign for Sustainable Products Regulation (ESPR), described in policy option D, and to learn from the current Ecodesign directive and the work in EU Environmental Footprints (PEF/OEF) when developing harmonized method for assessing environmental performance of products in a lifecycle perspective. Method for assessing environmental performance of products in a lifecycle perspective Jernkontoret believes that the method for assessing environmental performance of intermediate products, like steel, should be based on the same principles/framework regardless of whether the material is used in a car, a building or other application. Great effort has been put into making the environmental footprints method applicable for different materials e.g., the "Circular Footprint Formula" (CFF) take drivers/barriers for increased recycling of each material into account. For many metal products it is the supply of material for recycling, not the demand, that is a barrier. Setting requirements on "recycled content" would therefor not increase the recycling in total, only shift it to certain products (for which product legislation applies). EN 15804, the currents standards prescribed for developing an environmental product declaration for construction products, is not fully compatible with the results from a PEF. Jernkontoret supports continued work to further harmonize the EU product legislation in order to make results from prescribed methods comparable. 3D-printing, reuse and manufacturing on the construction site Jernkontoret welcomes that the proposal comprises 3D-printing and opens for CE-labelling of products that are reused, remanufactured or products manufactured on the construction site. This opens a possibility for increased resource efficiency (for steel), by using new technology and using products longer. Administration and digital product passports Jernkontoret appreciates that the proposal put emphasis on making the administrative burden as small as feasible possible for all actors. We agree that digitalization/digital product passports can contribute to this. Digital product passports can also contribute to carry important information – on content, use, installation, dismantling etc. – available along the value chain, and make it available when needed. This is especially important for long lived products. However, it is important that the information is only accessible for the "right" actors, and to protect confidential business information.
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Jernkontoret warns new emission rules hinder steel industry innovation

20 Jun 2022
Topic — This initiative updates industrial emissions legislation to support a cleaner environment and health.
Message — The group suggests postponing negotiations until related climate laws are finished. They want current standards to remain valid and energy targets to be non-binding.12
Why — This allows industry to maintain flexibility and avoid rigid, costly energy mandates.3
Impact — Delaying the revision slows improvements in air quality and harms public health.4
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Response to Review: Restriction of the use of hazardous substances in electronics

14 Mar 2022

Jernkontoret, the Swedish steel Producer´s Association, supports the conclusion that the RoHS Directive has contributed to protecting environment/human health and to the functioning of the internal market. It is therefore important to keep momentum and uphold the function of the directive. Jernkontoret also agree to the problem description given in the call for evidence that there are issues related to practical operation of the Directive that could/should be addressed to further improve the effectiveness (e.g. high administrative burden and slow/complex processes for exemptions). Further measures for clarifications, simplifications, and common interpretations (in all MS) and policy coherence would be welcomed. Jernkontoret have not had the opportunity to analyse the proposed political alternatives in detail. Also, there are several parallel initiatives ongoing under the umbrella Green Deal (e.g. review of Reach and Sustainable Products Initiative) that could influence the review of RoHS Directive. This makes it difficult for us to at this point give an opinion on which policy alternative is most appropriate. However, given the complexity of the task, and the importance of a level playing field, we see a potential need for more than "soft" measures. A thorough impact assessment of the different options is very important to retain the Directive’s well-functioning elements after the review. We look forward to providing further input in the next stages of the Directive’s review, sharing views, experience and concrete examples, and jointly explore opportunities for simplifications and improvements to the exemption process to everyone´s benefit. (Our comments are also found in the attached pdf.)
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Response to Carbon Border Adjustment Mechanism

18 Nov 2021

Jernkontoret, the Swedish steel producers´ association, gives our contribution in the attached file.
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Response to Revision of the Energy Tax Directive

18 Nov 2021

Jernkontoret, the Swedish steel producers´ association, gives our contribution in the attached file.
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Swedish steel industry seeks fair ETS reform for decarbonization transition

8 Nov 2021
Topic — EU proposal to revise emissions trading system to meet 55% reduction target by 2030.
Message — Jernkontoret requests maintaining the 1.6% benchmark reduction rate instead of the proposed 2.5%, deletion of energy efficiency conditions on free allocation, and evaluation of carbon border adjustment mechanism before phasing out free allocation. They argue the benchmark cuts would severely impact advanced product manufacturers during critical transition investments.1234
Why — This would reduce compliance costs and maintain free allowances during expensive technology transitions to hydrogen-based production.56
Impact — Overall climate ambition suffers if cost-efficiency is undermined by additional measures beyond linear reduction factors.7
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Response to Revision of EU legislation on hazard classification, labelling and packaging of chemicals

1 Jun 2021

Jernkontoret, the Swedish Steel Producer's Association, welcomes the European Commissions's IIA on CLP revision as a part of the Chemical Strategy for Sustainability and the opportunity to improve this legislation. Jernkontoret wants to comment the IIA revision on CLP as part of the ongoing open consultation. Introduce a prioritisation mechanism for harmonising the classification of certain chemicals and Clarify the obligations to classify mixtures and some complex substances Jernkontoret can support this new initiative, for instance for the endocrine disruptors, to be introduced in the existing EU legislation. This prioritised harmonisation, which could be used as a "fast track", can help to ensure that the same substance is only assessed once for its specific properties. However, a proper assessment in a robust and transparent way must be done before deciding for the prioritisation, carefully considering the specific properties of metals and inorganic metal compounds and their role in organisms. Metals and inorganic compound have very specific properties incomparable with organic chemical. For many metals and compounds, data is already available from the scientific literature. If these data will be combined with a robust assessment of the chemical properties, in a weight-of-evidence approach, the need for additional animal testing could be limited to a minimum. The management of metals and inorganic compounds should be specific and risk-based, taking into account the exposure considerations and the specificities of metals. On top of that classification should be based on science. Classification should therefore be limited to the route of exposure on which the positive CMR effect has been observed and concluded. The automatic classification for alternative routes of exposure is unnecessary precautionary and should be avoided. In this context it is particularly important to consider the alloying effect which occurs in many alloys. Although an alloy might contain some hazardous substances the matrix of the alloy prevents those substances to be released. They do not become bioavailable. The same applies to many substances in slag from iron and steel production, which are often firmly integrated into the mineral phases due to production and are therefore not bioavailable. In the present CLP's article 12 it is listed specific cases where further evaluation is required. e.g. in 12 b) where it is stated that if conclusive scientific experimental data show that the substance or mixture is not biologically available and those data have been ascer¬tained to be adequate and reliable. Article 12 has led to many uncertainties. In particular with regards to the interpretation of the concept of ‘not biologically available’. Furthermore, test methods to prove conclusive scientific experimental data are subject to conditions mentioned in Article 8(3) stating that the test methods shall be conducted in accordance with one of the following methods: (a) the test methods referred to in Article 13(3) of Regulation (EC) No 1907/2006; or (b) sound scientific principles that are internationally recognized or methods validated according to international procedures. It is for the metals industry very important that bio-elution is acknowledged as a proven methodology to demonstrate bio-availability. Introduce the possibility to submit proposals for and set harmonized environmental and safety values for some substances We are concerned about this proposal. We do not agree it is a good proposal to introduce occupational health limit values into CLP only based on hazard classification, without taking into account socio-economics impacts or feasibility assessments. This is normally considered when deciding on which risk management measures to implement in the workplace in order to minimize risks for exposure of chemicals in the industry.
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Response to Revision of EU legislation on registration, evaluation, authorisation and restriction of chemicals

1 Jun 2021

Jernkontoret, the Swedish Steel Producer's Association, welcomes the revision of EU legislation on REACH as a part of the Chemical Strategy for Sustainability. Jernkontoret agrees on the main goal for REACH and want to comment the IIA revision on REACH as part of the ongoing open consultation. • Chemicals and metals are essential to society and are used in almost all our products to deliver specific functions of features. Chemicals are also important during the manufacturing of materials, e.g. steel. The steel industry produces high-tech materials on which a modern, climate-neutral and resource-efficient society will be built. A safe handling of chemicals to ensure a high level of protection to the environment and to human health is a prerequisite for the steel industry. • REACH is the most comprehensive regulatory framework securing safe use of chemicals and metals. Making what we have simpler and more efficient in combination with a strong and coordinated enforcement across Member States will truly protect consumers, environment and ensure a level playing field and competitiveness. • The current REACH revision is an opportunity to further improve the framework by making it more efficient, consistent and coherent with other pieces of EU product safety and environmental law by o Bringing added value to new data requirements o Using digitalised supply chain communication o Simplify the authorisation and restriction procedures o Improve and maintain policy coherence between REACH and product policies (RoHS, Ecodesign, etc) o Improved and coordinated enforcement to ensure safety of imports entering EU • All regulatory proposals from the coming revision of REACH must be preceded by a thorough socio-economic impact assessment, including the supply chain, production losses, prices for customers and added value for the European society. It is also important to acknowledge the value of a Europe based manufacturing industry including a thriving and ongoing innovation climate within European Union.
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Response to Modernising the EU’s batteries legislation

1 Mar 2021

When introducing new requirements as in the battery legislation, it is important that there is a clear environmental benefit with the measures and that the impact assessment that the Commission is planning for is thorough. Jernkontoret supports carbon footprint reporting on listed battery types, but the reporting requirement should not be for each batch of batteries, as this would result in an unreasonable administrative burden for upstream suppliers of raw materials with no real added value. Instead, it should be sufficient to report per battery type and as an annual average. It is positive that the Commission is proposing the gradual introduction of environmental performance reporting requirements, ie introducing reporting requirements in a first step before setting the requirement levels. The proposal states that calculation methods for the carbon footprint reporting requirements should be developed by the Commission. The fact that this has not been established before the regulation takes place creates a great deal of uncertainty about what this will mean for companies. It is positive that the Commission is planning to set up a database where companies can find secondary data for carbon footprint calculations of batteries, this is especially important for many SMEs. On the other hand, there is a balance between the use of secondary data and specific data. A large use of secondary data in relation to specific, and especially if the secondary gives a large impact in the LCA, will make it difficult to differentiate between different products (batteries). Jernkontoret is concerned with the current proposal of targets for recycling efficiencies and fixed recovery rates as they are set before the methodology has been developed. Jernkontoret believes the approach should be the reversed. The targets for both recycling and the proportion of recycled material must be realistic based on the availability of batteries that are recycled, technical recycling solutions and the available amount of recycled and recyclable material. In parallel with increased recycling, another ambition should be to ensure that products including batteries have a longer lifespan and stay longer on the market before they are recycled. Also with regard to the proportion of recycled material, the term batch is used, which creates the same problems regarding reporting in this application as under carbon footprints. The definition of recycled content should be broadened to include metal units from any type of waste and not be limited to metal units originating only from spent batteries. The regulation should encourage “open loop” recycling, allowing recycling of metal units from any type of secondary raw materials and not limited to spent batteries only. The output product from the recycling process should be allowed to be in any refined metal form, and not necessarily in such product form that it can re-enter the battery value chain again as this would limit the competition and could result in unwanted negative effects for other industries. If any targets are set, these should be voluntary and not mandatory. The Commission suggest introduction of a product passport for batteries over 2 kWh. Jernkontoret supports that the Commission has made a selection of the batteries that are to be covered by the requirements for product passports and that the requirements are not automatically introduced for all types of batteries. In order for the system not to become too administratively burdensome, the information in the product passport should be limited to what is relevant and necessary for the purpose and current product, ie what is requested in the value chain and how the information can be made available for use.
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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

Jernkontoret, Swedish steel producers' association, comments on the draft delegated regulation Jernkontoret also supports the position of Eurofer General view Jernkontoret supports the purpose of the taxonomy, i.e. to make capital available for large investments that are needed to reach the EU climate targets and a sustainable growth. European steel industry is part of this transition and is already investing heavily in new process technology and large development projects. Swedish steel industry has developed a climate roadmap with concrete measures to decrease and eliminate climate related emissions. This includes innovative and ambitious research projects already started to develop new technology that will tackle the largest emission sources. The steel industry also continues to develop new products that contribute to decreased emissions when used in various end-products in society. In addition, most products of today´s society are made of steel or are produced using steel. And regarding transformation towards a fossil-free future, a precondition for wind power mills, vehicles, white goods etc. to become more efficient and able to contribute to the climate targets is to use specialized steel. This means that steel industry has an essential role to play in terms of climate change mitigation and climate change adaptation As an enabler for the transition the taxonomy should also focus on the future in order to direct capital flows towards activities that are driving the development. The criteria should therefore mirror the important function that steel industry fulfills as an enabler both for climate mitigation and climate adaption. Technical screening criteria on climate mitigation for manufacture of iron and steel The criteria presented in the delegated act is focused on classifying companies from a state- of-the-art situation and considering a limited part of their operation. Note that the TEG report did propose a criterion referring to investment plans that would result in actions towards decreased emissions. Such a criterion, which to some extent addresses the transition, should therefore be included in the delegated act. The delegated act proposes criteria according to the principle of ETS benchmarks. This includes emission intensities for intermediate products including some processes along the value chain. These intensity levels take no account of the variety of steel products and neither of the fact that the value chain includes many more steps. The principle of ETS benchmarks is aimed at handling free allocation of emission allowances and not to evaluate company sustainability. We propose to include a life cycle perspective to handle both the value chain in production and steel as an enabler in other value chains. Using, for example, the standard EN 19694-2 would make it possible to calculate emissions for iron and steel production in a comparable manner. The delegated act proposes eligibility for EAF (electric arc furnace) steel production using at least 90% scrap. This criterion does not take into account the different steel qualities such as high alloy or stainless steel, which are mainly scrap based but unable to reach such high percentage. With these proposed criteria, the main part of steel industry would not be taxonomy eligible. This would hamper steel companies' possibilities to make efficient efforts in technology development and investments towards the climate targets. This would certainly not be in line with the purpose of the taxonomy. Other sector criteria Electrification is the main solution to reduce and eliminate climate emissions from steel industry. Increasing supply of fossil free electricity is therefore crucial to enable this transition and the taxonomy criteria should not limit or counteract the development and increased use of any fossil free energy sources, such as hydro or nuclear power.
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Response to New EU Soil Strategy - healthy soil for a healthy life

10 Dec 2020

New Soil Strategy – healthy soil for a healthy life Feedback from Jernkontoret - The Swedish Steel Producers´ Association Contact: Sophie Carler, Ph. D., Senior Advisor, Water, ecosystems, and sustainability. Mobile: +46 70 398 56 89. sophie.carler@jernkontoret.se We welcome the initiative for a comprehensive policy framework on land and soil that includes updated scientific knowledge, an update of the Soil Thematic Strategy within the framework of the Green Deal, and bringing coherence with the Zero Pollution Action Plan and the EU Biodiversity Strategy 2030. The Swedish Steel industry has worked since the 70s with minimizing pollution to soil and has extensive experience of monitoring and measuring soil quality on site. This is also part of Swedish environmental legislation ever since. Today steel producing companies have strategies and resources allocated for that purpose while at the same time complying with extensive European (IED status reports for example) and Swedish legislation for soil protection (specific rules for contaminated soils, evaluating risks and impacts on soils from industrial activities according to Swedish Environmental Code). Given these conditions, it is important to recognize that soil management is a national, regional, and local issue. As an example, methodologies for identifying and defining contaminated areas have been developed in Sweden and applied at regional and local level. It is important therefore that the issue remains at national level. Coherence between this initiative and existing regulations on soils is essential to avoid any double regulation and unnecessary administrative burden that could affect companies. That would also result in a European soil policy that is based on real conditions and thus on what is achievable. An illustration of that is the necessary coherence between restoration of degraded ecosystems under the EU Biodiversity Strategy and the aim of achieving land degradation neutrality by 2030. Given the common framework of the Green Deal, the initiative to a new soil strategy should be organized and carried out using three overarching principles: - The final objective of the strategy should be a resilient soil system. In other words, focus should lie on restoring degraded ecosystems to become resilient enough to withstand current climate change impact and generate essential ecosystem services. - Consider the Planetary Boundaries as the outer limit that defines "a safe operating space", that is the starting point for any of the strategies, actions, or targets that aim for healthy soils. - Consider the whole of Agenda 2030 in order to balance the different actions that spring from the Soil Strategy, the actions necessary to achieve the Green Deal, and the socio-economic needs associated with the global agenda. Importance of a science- based approach means - Using targeted and proportionate risk-based approaches to enable full use of restored degraded soil. Natural recovery should be included within the scope of restoration of contaminated soils. - Using risk-based approach to evaluate the environmental and health effects when it comes to metals and alloys. - Using a systemic approach, considering that a site being classified as contaminated is not based on the total concentration of contaminant(s) when it comes to metals, but instead include biological factors such as bioavailability, synergistic effects, variations in the toxicity of metals as a function of time and space, among others. Development of good practices and guidance is needed for that. In addition: o Natural background levels of metals as well as local environmental conditions should be considered. o High concentrations of a substances is not synonymous with high risk, as well as low concentrations of a substances is not synonymous of low risk. The science-based approach should be clearly integrated in coming proposals for soil strategies. A safe management of contaminated areas goes through a thoro
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Response to Protecting biodiversity: nature restoration targets

2 Dec 2020

Jernkontoret – The Swedish Steel Producers´ Association - please see attached file
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Jernkontoret demands free carbon allowances to protect steel competitiveness

26 Nov 2020
Topic — The European Commission is reviewing the Emissions Trading System to meet higher 2030 climate targets.
Message — The association insists that free allocation for globally competitive sectors must remain unchanged to provide predictability. They also argue that non-ETS sectors should take a larger share of emissions reductions to support industrial growth.12
Why — These measures would protect the industry's profitability and investment capacity during its transition to electrification.34
Impact — Sectors outside the emissions trading system would face heavier burdens to meet overall climate targets.5
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Response to Revision of lists of pollutants affecting surface and groundwaters

20 Nov 2020

Please see attached file, Best regards, Sophie Carler
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Response to Sustainable Products Initiative

16 Nov 2020

The Swedish Steel Producer's Association, Jernkontoret, welcomes the initiative taken by the EU Commission on sustainable products. This initiative can be an enabler for achieving EU goals on resource efficiency and climate, as part of Circular Economy Action Plan. It is important that the three pillars of the sustainability are taken into account. Jernkontoret is in favor of opening the Eco-Design Directive to make it wider in order to cover a larger number of products. Jernkontoret believes it is important to assess the environmental performance of products with common and robust LCA-based methodology/ies covering cradle-to-cradle which is/are consistent across all product groups. If both PEF and EPD according to EN 15804 will be recommended to use it is important that the two methods are as compatible which each other as possible. Steel is an intermediate product which is used in different segments as in construction products, automotive products and metal gods and the same or very similar method must be able to use for steel used in different type of products. Sustainability principles for products should include product circularity requirements of which some can be horizontal but some also must be product group specific. It is very important that sustainability principles are defined in cooperation with the sectors concerned. Design for circularity is critical. Jernkontoret believes that a product passport can be used for information through the value chain to provide greater transparency and provide information about products to the consumer. Jernkontoret suggest that chemicals, and the presence of those in products, should continue to be regulated via existing chemical legislation to avoid double or conflicting regulation.
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Response to Review of Directive 2012/27/EU on energy efficiency

21 Sept 2020

Representing the steel industry in Sweden, Jernkontoret is deeply engaged in the area of energy efficiency. Making the best use of energy is central for the industry as it is a natural way to increase cost efficiency, competitiveness and sustainability. As the EED is now evaluated for a possible revision, Jernkontoret would take this opportunity to make some statements and suggest a few changes in order to make it more effective, should it be opened. Our first choice, however, would be to focus on the non-regulative measures. Focusing on non-regulatory measures, such as education and building up the skill of the workforce would be a way to increase engagement and interest to handle these questions from bottom and up. Knowledge and empowerment is a successful strategy. Furthermore, industry would be able to contribute even more to the society and the energy system, if for example waste heat could come to better use. Looking into the directive, our interest is mainly focused on article 8: - To reach any further, and stepping up the ambitions of the industry, it should be clearly stated in the directive that the responsibility and full power of deciding which measures to take as a result of the energy audit must lie with the enterprise in question. Demands stretching beyond that, will influence the costs, competitiveness and possibilities to invest in new technology and solutions necessary to transforming its processes and reach net-zero-pollution as well as higher efficiency in the long run. - The use of a certified energy management system (as already stated in the directive) should be the first choice to comply with the demands for conducting an energy audit. No further reporting should be necessary, as this today only leads to extra work and administration without any additional benefit. Member states today act differently in this matter, and the directive therefore should state this more clearly.
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Response to Environmental claims based on environmental footprint methods

31 Aug 2020

Jernkontoret supports the establishment of a common and consistent assessment framework for how companies making green claims should assess their product's or organisation's impacts on the environment. Jernkontoret also find it important that this initiative is consistent with other policy initiatives, such as the sustainable product policy initiative, and takes into account the full product lifecycle. Limiting the number of methodologies, eco labels criterias etc. for green claims would, in principle, reduce cost to industry. Jernkontoret supports harmonized methodologies for assessing the environmental footprint of products within EU which uses the same approach to assess recycling performance, including recycled content, recyclability, and the quality of recycling. Example of methodologies that need to be further harmonized are the PEF methodology with the circular footprint formula and CEN 15804 including how to calculate end of life i modul D. Jernkontoret prefer the option 2: Establish a voluntary EU legal framework enabling companies to make green claims in accordance with the Environmental Footprint methods, as a complement to existing methods (developed by private or public entities, at national or international level). Jernkontoret does not think the market is ready for a mandatory requirement for any green claim to use the Environmental Footprint method (option 3).
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Response to Chemicals strategy for sustainability

18 Jun 2020

Jernkontoret welcomes the Chemicals Strategy for Sustainability as part of the zero-pollution ambition for a toxic-free environment, announced in the European Green Deal in December 2019. It is positive that the EU-commission emphasizes the importance of chemicals to our society. Chemicals including metals play an important role to deliver climate ambitions, are essential to society and are used in almost all our products to deliver specific functions and features. The chemical industry and the materials industries produces the building blocks and materials on which a modern, climate-neutral and resource-efficient society will be built. A safe handling of chemicals to ensure a high level of protection to the environment and to human health is a prerequisite. Although Jernkontoret agrees with the main objective of the strategy we would like to give following input that we believe are essential to link the strategy to other policy areas in the Green Deal. Ten aspects described in attached document are important in the continued development of the strategy. We find it worrying that no impact assessment is foreseen for the Strategy as a whole. We hope that the upcoming Chemicals Strategy for Sustainability represents a key opportunity to achieve the objectives of a zero-pollution ambition in the framework of the Green Deal, and that the strategy facilitates the circular transition in the society.
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Response to A EU hydrogen strategy

8 Jun 2020

See attached file.
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Response to Strategy for smart sector integration

8 Jun 2020

See attached file.
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Response to Climate Law

30 Apr 2020

Jernkontoret, the Swedish steel producers´ association, comments on the proposal for an EU Climate Law. Jernkontoret also support the contribution from Eurofer. Setting a long-term target, such as the proposed climate neutrality 2050, gives the opportunity to development and deployment of new technologies in a resource efficient and economically feasible way. Such a target must work in parallel with economic growth both to have a chance to succeed and for EU to be an example for other countries. The development of ambitions by all signatories of the Paris agreement need to be taken into account in EUs climate law and related legislation to retain a sustainable development with a global perspective. Policies and measures to reach the target needs specifically to take account for effects on international competitiveness and long-term profitability of European industry. Swedish steel industry has developed a climate roadmap describing technical possibilities and needed supportive conditions to reach net zero GHG emission 2045, being the Swedish climate target. The major solution to decrease GHG emissions in steel industry, and other sectors, is electrification. Access to fossil free electricity to competitive cost is thus an important enabler. The second main enabler is long term support for research and development. Emission elimination need development and deployment of new technologies. Ambitious activities have already started in steel industry such as research on using hydrogen as reducing agent for iron making, hydrogen as heating fuel in steel processing and development of biobased raw materials and energy. Climate policies should focus on supporting and enabling measures to continue this positive development. For industries that 1) need to develop new breakthrough technologies (R&D&I) and 2) need to adjust implementation of new technology to investment cycles (resource efficiency) the emission reductions will be a stepwise development. Thus, the assessment of Union progress and national measures as well as the setting of a trajectory for the progress towards the target need also to consider sector specificities and roadmaps to take account for non-linear development. Jernkontoret would like to stress that using simple linear models for emission reduction as a base for policy measures may counteract ambitious efforts by industrial companies and thus slow down the transition. Concerning the review of the 2030 target and the proposed setting of a trajectory with review every five years it is important that this is decisions taken by the member states to ensure the collective responsibility among all member states.
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Response to Climate change mitigation and adaptation taxonomy

27 Apr 2020

Jernkontoret, the Swedish steel producers´ association, welcomes the ambition to facilitate sustainable investments to support the transformation towards the sustainability goals. Swedish steel industry is committed to continue to shape a better future being in the technological frontline and to deliver societal value on all sustainability aspects. To develop new industrial processes requires research including testing and upscaling. The pathway for emission reduction will not be linear since implementation and investments need to be timing investments cycles to be resource efficient. Thus, the availability to capital is needed all along the pathway to 2050 and any legislation to promote this should be directed towards the future and integrate a life cycle approach. Concerning the detailed proposals on technical screening criteria, Jernkontoret support the comments by Eurofer as attached.
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Response to EU rules on industrial emissions - revision

20 Apr 2020

•There is a significant EU added value elaborating sector BREF in the Seville process. An improved Seville process will be able to both contribute to circular economy and to interact with decarbonization of industry and major changes in IED may not be necessary. •Legal certainty should be ensured throughout the revision process, and no new BREF review cycle in Seville should be initiated until a revised IED enters into force, & the ongoing BREF-revisions must remain as IED 2010 permits. •Due to the corona crises, many employees work less hours and focus time on essential issues. This, in combination with a unexpected timetable for this process, limit the possibility reply. To make a new legislative proposal linked to the IIA before the evaluation report and the Staff Working Document is published in combination with Corona crises, is not satisfactory. Please, for next steps, provide transparent timetable and generous reply times. BAU and Sectoral issues Many BREFs are not yet reviewed or implemented, so IED's full performance is yet unknown. If including installations below thresholds (or new activities) it's important to assess benefits (environmental) with the increased workload for all stakeholders (economics) but also possible delaying updates of other BREFs (environmental). BREF process It is important with collection of robust, reliable and representative data for environmental performances, and for the identified key environmental issues for a sector. The BREF guidance should be updated and include the criteria for Key Environmental Issus (KEI), a transparent derivation methodology for the setting of BAT-AE(P)Ls and guidance on circular economy. Access to information When improving access to information, participation in decision-making and access to justice it is needed to also comply with CBI and competition rules. Contribution to the CE IED may accomplish to CE but is not the main tool, as IED is for processes in an installation. BAT should always be assessed for the specific sector concerned, keeping the integrated approach in mind. In CAEP – IED is one of 35 actions – with industrial symbiosis as a separate action point. For steel sector, having many different BREFs, they all contribute to CE via e.g. waste management, material efficiency as BATAEPLs, use of by-products, recovery and recycling. With a new BATC, waste amount (sludge/dust) often even increase with better techniques. Parallel with the production of steel, by-products and waste are produced (e.g. slags, dust). For utilization of these the main legislation is Waste Framework Directive (WFD), but for obvious reasons, it is not possible to have targets for industrial waste minimization in WFD. Interaction with decarbonization of industry With regards to decarbonization efforts, IED Article 9.1 has ensured – and should continue to ensure and retain the coherence of IED with ETS legislation. In order to support the deployment of novel techniques, IED Article 15(5) could be used more frequently and for longer periods. IIA assumed that decarbonization can be achieved with an improvement in all other environmental aspects. We already know from Swedish steel industry's Climate Roadmap (https://www.jernkontoret.se/en/vision-2050/climate-roadmap-for-a-fossile-free-steel-industry/) that the demand electricity will increase, but changes for other emissions by the transformation are not fully known. Coherence with other legislation The IED has a strong coherence with other environmental policy areas. The subject matter in IED is to address emissions into air, water and land and waste generation from processes, in order to achieve a high level of protection of the environment taken as a whole. This should continue to be pursued. Emissions to water are mentioned in IIA and Water framework directive is a main legislation and overlaps should be avoided. When assessing priority substances for a certain sector, the four criteria for KEI must be used.
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Response to 2030 Climate Target Plan

15 Apr 2020

Jernkontoret, the Swedish steel producers´ association, welcomes the opportunity to provide our view on the 2030 climate target plan. Jernkontoret also support the contribution from Eurofer. Swedish steel industry has developed a climate roadmap describing technical possibilities and needed supportive conditions to reach net zero GHG emission 2045, being the Swedish climate target. The major solution to decrease GHG emissions in steel industry, and other sectors, is electrification. Access to fossil free electricity to competitive cost is thus an important enabler. The second main enabler is long term support for research and development. Emission elimination need development and deployment of new technologies. The long-term target, climate neutrality 2050, is most important and should be the focus for energy and climate policy development. Interim targets, like the 2030 target, should be thoroughly prepared and need to be reachable at the basis of cost efficiency. The further we get in decreasing and eliminating emissions the more targeted solutions is needed. The low hanging fruits are picked, and more complicated and expensive solutions need to be developed and implemented. Thus, different sectors need different support and incentives. For this reason, we do not support the extension of EU-ETS to other sectors such as transport. That would only increase the carbon price and the costs for industry exposed to international competition. Another aspect is that the decrease in emission for different sectors will have different paths. For industries that need new breakthrough technologies there will not be a linear trajectory. New technology requires sufficient time to be developed, tested and implemented. After that, an accelerated pathway could be achieved, most likely post 2030. It is problematic if targets directly affecting legislation directed towards companies, ie ETS, is changed during the ongoing trading period. This would create great uncertainty due to the risk of increased costs for emission allowances and disincentivize investments in European production sites. Increased costs may also slow down the development of new technologies. We would like to emphasize the importance the keep and strengthen the carbon leakage provisions in connection to ETS. The free allocation is crucial to maintain a competitive industry in Europe and the compensation for indirect costs due to higher electricity price should be compulsory to all member states. An increased 2030 target should therefore be directed towards the non-ETS sectors and maintaining the current level of ambition in the ETS. Focusing the increased efforts towards the member states through the Effort sharing regulation would enable MS to choose the appropriate measures depending on national conditions. We welcome the extensive analysis that the commission will carry out. For process industries it is essential that the impact assessment includes a forward-looking approach including the analysis of carbon leakage measures and the consequences of the current COVID-19 crisis. An economic downturn may well delay investments and implementation of techniques that could lead to decreased emissions. Long-term profitability and sustainable growth are prerequisites to enable climate ambitions.
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Response to Revision of the Energy Tax Directive

1 Apr 2020

Jernkontoret, the Swedish steel producers association, welcomes the Green Deal and the holistic perspective that characterize the strategy and we also support the EU ambition to become climate neutral by 2050. Both the Commission and the Member States (MS) need to commit to a long-term policy framework with realistic objectives, and simple and clear rules to provide this stable environment. The current ETD remains effective and operational, without hampering competitiveness for business and secure access to energy and feedstock at competitive prices while supporting wider EU policy objectives. Aligning different EU policies is a commendable ambition. Different policy areas influence each other and to reach an efficient development in line with the Green Deal the combination of regulatory measures need to be complementary. At the same time, it is important that different legislation do not overlap each other. Hence every piece of legislation shall have its well-defined purpose. The primary objective of ETD is to support the proper functioning of the internal market by avoiding double taxation and other distortions of trade and competition between energy sources and energy consumers and suppliers. As such, ETD provides MS with a tool to tax energy and indirectly support the objectives of other legislation in energy and climate policies. EU-ETS is the key tool for reducing CO2-emissions from power and process industry and hence these sectors shall not be subject to a CO2-tax. To fulfil other energy and climate policies, each MS has the possibility to use strategies and instruments most suited in each country. Energy and CO2-tax may be relevant and usable measures within these strategies, but other measures are also needed, such as R&D&I support, education and other incentives. The mix of strategies and instruments used to reach its climate and energy targets should still be the choice of each MS. Hence the ETD, as such, shall not have the ambition to promote e.g. emission reduction or energy efficiency. A common EU framework is necessary for the smooth functioning of the EU energy market in order to avoid distortions on the internal market. However, minimum energy tariffs do not exist in a large part of the rest of the world where European industry have their global competitors. In order to mitigate the negative impact of energy taxation to international competitiveness, minimum tariffs shall be kept at the current level. Companies need a stable policy environment to be able to make long-term investment decisions. This is particularly relevant in the transition to a low-carbon economy. In this context it is important that companies operating in highly competitive international markets remain out-of-scope as stated in article 2.4b of the ETD to ensure a level playing field at a global level. Similarly, the exemptions in article 17 and 15(l) concerning energy intensive industries is important to safeguard a level playing field at the EU internal market. These consistent definitions facilitate implementation and minimize costs and administrative burdens for MS and businesses and paves the way for a cost-efficient green transition. Sectoral differentiation of tax levels is an important possibility for MS to optimize their policy framework to efficiently reach their desired targets. Therefore, the current possibility to differentiate between tax levels for industry and other sectors is important to keep. Such national differentiation should not be regarded as subsidies since its purpose is to keep a level playing field between competing sectors within the EU. We also believe that the legal basis for ETD shall continue to be article 113 of the Treaty. To ensure greater legal certainty for companies, we would urge the Commission to ensure that any energy tax reductions or exemptions allowed by the ETD is automatically considered in line with state aid rules and fall under the General Block Exemption Regulation.
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Response to Carbon Border Adjustment Mechanism

1 Apr 2020

Jernkontoret, the Swedish steel producers association, support the feedback given by Eurofer which is attached.
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Response to Climate Law

6 Feb 2020

The Swedish Steel Producers Association (Jernkontoret) supports the EU-goal of reaching climate-neutrality by 2050, and would like to submit the following feedback on the consultation regarding roadmap for the proposal for a climate law. For the EU to stay at the forefront of global climate action the EU must ensure not only that emissions decrease and reach net-zero by 2050 but also that businesses and societies continues to grow. Only by proving that it is possible to combine decreased emissions with economic growth will the EU truly be a role model which inspires the rest of the world to follow in our tracks. By creating conditions for business to develop and invest in low carbon solutions in the EU, the EU can both reduce its own emissions as well as export solutions that reduces emissions globally. EU climate policy must further ensure a competitive business sector and prevent carbon leakage. It is unacceptable to lower the EUs emissions by moving industries, jobs and companies to other parts of the world. Not only would this be an ineffective global climate policy, but it would also serve as a deterring example of how not to cope with climate change. At the core of a successful combat against climate change lies ensuring a competitive business sector that can provide climate solutions globally. The EU steel industry will require approximately 400TWh of CO2-free electricity every year by 2050 (including for the production and use of hydrogen). From that perspective, the reliable availability and abundant supply of low- or CO2-neutral energy (mainly electricity and hydrogen) at economically viable, affordable cost levels is a necessary pre-condition for the successful transformation of the steel sector in the coming decade and beyond. This kind of necessities for making the transformation possible must be high-lighted in the up-coming work. In the roadmap the Commission notes that “the initiative could set the principle of having intermediate targets” and that the Commission might propose to amend the climate law at a later stage. With regards to this it is important to emphasize that predictability is essential for businesses and companies. Rules must be clear and those who follow them should be rewarded, if the rules, incentives or targets are changed or unpredictable investments could be put at risk. It should also be taken into consideration that emission reduction on EU level is not likely to be linear all the way to 2050. Furthermore, that the road towards climate neutrality includes both incremental measures (e.g. energy efficiency) as well as technology break-throughs and leaps (e.g. new industrial processes) Investments in research and innovation is necessary to reach the technology breakthroughs that are needed. These aspects need to be taken into consideration when developing climate policy and therefore an intermediate goal should not be implemented in the law as full focus from all actors should be on reaching the 2050-target.
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Response to A new Circular Economy Action Plan

20 Jan 2020

Jernkontoret, the Swedish Steel producer's association, welcomes the Roadmap for New Action Plan on Circular Economy. Steel plays an important role in the transition to both a more circular economy and a CO2-neutral society. Steel is the most recycled material in the world and has a long a mature market for recycled steel. • All the terms used; for instance; sustainable/green/harmful/circular products and services need to be defined. The CE roadmap also needs to be consistent and inclusive with all other initiative related to Green deal, e.g. climate policy, zero pollution, chemical strategy and IED, in order to avoid different regulations in opposite directions. Instead the CE action plan should be built on a holistic and horizontal view in the same way as the Commissions Green deal communication. • For steel there are three different material flows; 1. steel/scrap flow (steel used in consumer product, construction, infrastructure, transportation, industry etc. After end of life of the steel products they become scrap which is a valuable raw material when producing new steel), 2. Process related waste from the steel production and 3. Process-related byproducts which are by volume linked to the steel production where the largest volume is manufactured aggregates (metallurgical slag). The roadmap needs to focus on creating markets for secondary raw materials (e.g. scrap), End-of-waste, and byproducts and not only on secondary raw material. • Steel is a permanent multiple recyclable material, with already well functioning markets for scrap (secondary raw material), more than 80 percent is already recycled. For steel it is more important to focus on the material's recyclability than recycled content. • To create a circular economy the legal definition of the material should not hamper the use of the material. If it fulfills the requirements (legal/functional/quality demands/standards) it should be promoted for useful use and not be landfilled. • With a fully tox-free chemical agenda, a lot of material will not be used and therefor need to be landfilled which will not contribute to a more Circular Economy. The focus must be on phasing out SVHC and limiting the risk of exposure of hazardous substances to human health and the environment, not the specific content of different substances in different materials and applications. A metal alloy is not the same as a blend of chemicals and this is needed to be recognized. • Sustainable products must be seen in all three dimensions of sustainability and not only the green one. The tools like Green Public Procurement should therefor shift to Sustainable Public Procurement tools. • To empower well informed purchasing decisions, for private consumers, in business to business and in public procurement, reliable, verifiable and comparable information (robust methods) is needed. Jernkontoret welcomes the alignment of PEF, EN 15804 and environmental and sustainability labels. It is important that methods and criteria used consider the different markets for different types of secondary raw materials e.g. the circular footprint formula developed in PEF. • The design of final products is important to improve the possibility to reuse, repair, dismantle and finally recycle dismantled materials. The Eco-design Directive can be used for this. • The monitoring framework for Circular Economy should be improved monitoring the real recycling of materials, not only the collected amount of specific waste materials, and the real use of byproducts. • The legal Chemicals, Products and Waste interface must be reviewed or clarified in order to improve the material efficiency without risk for increased exposure of harmful substances for human health and the environment. • The same requirements must be valid for products produced outside EU as within EU as the market for many products and for waste as scrap are global. See also sector specific appendix attached.
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Response to EU 2030 Biodiversity Strategy

18 Jan 2020

Safeguarding nature - EU 2030 Biodiversity Strategy Feedback from Jernkontoret - The Swedish Steel Producers´ Association Contact: Sophie Carler, Ph. D., Senior Advisor, Water, ecosystems, and sustainability. Mobile: +46 70 398 56 89. sophie.carler@jernkontoret.se Please see our feedback as attached file.
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Response to Commission Regulation amending the CLP Regulation (EC) 1272/2008 and correcting Commission Regulation (EU) 2018/669

8 Feb 2019

Jernkontoret questions the inclusion of cobalt in this ATP as more clarification is required regarding all routes of exposure, mutagenicity, the carcinogenic potency methodology and consideration of bioavailbility for the classification of matrix materials like alloys. Jernkontoret is the Swedish Steel Producers Association. The classification of cobalt has an impact on steel as cobalt often is available in steel either as a natural component or added as an alloying element. There are a number of remarks which have been raised during the process of introducing a harmonised classification of cobalt. Even if the Commission would suggest a GCL of 0.1% for cobalt metal, there are still five concerns that Jernkontoret would like to highlight: 1. Including “all routes of exposure for carcinogenicity” is not in line with GHS (globally harmonised system) 3.6.2.1. We understand that the present proposal, including an ‘all routes of exposure’ classification for carcinogenicity is mainly the result of the lack of in vivo study results for dermal and/or oral exposure demonstrating that these routes are not concern. Considering the mechanisms of action of cobalt, the target organ but also the results from the extensive epidemiological studies, these exposure routes are very unlikely to lead to an increased cancer risk. 2. The suggested classification of mutagenicity is not in line with the interpretation done by OECD*, Canada** and Australia***. 3. There is still some work needed on the bioelution protocol and the way to sue the results in CLP. 4. The expert group for review of the carcinogenic potency methodology's utility for inorganic substances will start soon and the result from this review can be useful in the case of classification of cobalt. 5. The results from the big epidemiological studies, which have been sent in to the commission earlier, have not been sufficiently evaluated as the results became available only a short time before the RAC meeting (Sept 2017) finalizing the opinion on the cobalt classification. The studies cover over 33 000 workers in 5 countries and found no evidence that exposure at levels experienced by the workers examined, increases lung cancer mortality risks. Also, there was no evidence on increased risk from any other causes of death was found. The results indicate existence of a threshold value for carcinogenicity. * https://hpvchemicals.oecd.org/ui/handler.axd?id=b789fd1c-bab3-433c-9f47-3cbd49042976 ** https://www.canada.ca/en/health-canada/services/chemical-substances/substance-groupings-initiative/cobalt.html *** https://www.nicnas.gov.au/chemical-information/imap-assessments/imap-assessment-details?assessment_id=1311 Bo-Erik Pers CEO, Karin Östman Senior Policy Advisor Environment
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Response to Monitoring Framework for the Circular Economy

3 May 2017

The Swedish steel industry is very supportive of the initiative for transforming the European economy into a circular one and would like to comment on the roadmap on “Monitoring Framework for the Circular Economy”. Then, the steel sector wants to contribute to this exercise being a sector for which resource efficiency and circularity are key concepts. Moreover, steel is a material that can be endlessly recycled without losing its inherent properties and permanently available for the society purposes. It is very important to not focus on the share of secondary raw material in steel products. There are several reasons for that. 1. The global (and European) demand for steel is bigger than the amount of scrap available for recycling. The existing scrap market is a well functioning system and the production have to be balanced by primary production. The main message that should be taken into account is the possibility for steel to be recycled without loss of properties. Compare with the “circular footprint formula” developed in the PEF-work. 2. If the BF-BOF steel production in Sweden or Europe were to be replaced by a global average steel mill, emissions would increase due to the electricity mix available and types of ore or distance to mines with “good” iron ore. There is not scrap enough available to replace the primary production and that is why we in the foreseeable future will meet this scenario. Steel products’ high potential to be both reused and recycled (with the same quality or even to be up-graded) should be used and considered during product design. The value of recyclability during end of life should be evaluated if possible. End-Of-Life recycling rate should be preferred to the recycled content Raw Material Scoreboard Jernkontoret participates in a Swedish Working Group discussing possible Resource Efficiency Indicators. We have found that the indicator for Domestic Material Consumption that is possible to monitor and follow up within EU should not be used for comparing countries. The indicator includes domestic extraction and trade (import and export). The domestic extraction is measured in tonnes of gross ore (or gross harvest) whereas imports and exports are measured as the mass weight of products as they cross country borders. This means that the weight of traded products do not represent the domestic extraction of materials that was necessary to produce the traded product. This means for example that a country as Sweden gets a comparable high number for Domestic Material Consumption due to great asset and export of materials as e.g. iron ore. The Circular Economy Concept fits very well with the Swedish Steel Industry´s Vision for 2050 "Steel shapes a better future" This vision implies three undertakings: •We lead technical development Our research and innovation revolutionise technology for tomorrow's society. Our steel constantly challenges the frontiers of engineering. •We nurture creative individuals Our working environment fosters new solutions for communities through global collaboration. Our creativity constantly challenges the limits of contemporary thinking. •We create environmental benefits Our production uses resources so efficiently that only products of value to the community leave our plants. Our ambition constantly challenges the limits of the possible. Related to the last bullet a research Project together with Stockholm Environment Institute is ongoing with the purpose to develop a compass to evaluate whether the steel industry approaches the vision of producing only products that provide social benefits. This is a follow up Project to an earlier Project, see link to web information: http://www.jernkontoret.se/en/vision-2050/societal-value-creation/
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