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Metallinjalostajat ry - Finnish Steel and Metal Producers

MJ, FSMP

Finnish Steel and Metal Producers is the voice of the Finnish Steel and Metal producers and major metal recyclers in Europe.

Lobbying Activity

Meeting with Aura Salla (Member of the European Parliament)

22 Apr 2025 · Steel and Metal Action Plan

Meeting with Maria Guzenina (Member of the European Parliament)

9 Oct 2024 · Industrial policy

Meeting with Eero Heinäluoma (Member of the European Parliament) and SSAB AB

9 Oct 2024 · Reception

Meeting with Katri Kulmuni (Member of the European Parliament)

8 Oct 2024 · Energiaintensiivisen teollisuuden uudistuminen

Meeting with Nils Torvalds (Member of the European Parliament)

21 Jun 2022 · Metal industry

Response to Carbon Border Adjustment Mechanism

18 Nov 2021

The EU needs effective means to prevent carbon leakage and level the playing field. Finnish Steel and Metal Producers (Metallinjalostajat ry) believes that carbon leakage should be tackled first and foremost through the present emissions trading mechanism. CBAM-mechanism should be explored in the EU and considered as a complementary measure if the climate ambition between the EU and the rest of the world prevails. CBAM is a challenging proposal from the trade policy point-of-view. The measure would a major novelty not only within the EU, but also globally. Its risks relate to retaliation by third countries, higher prices for imported raw materials and products, and the abolition of the current free allowances for the EU producers (increased EU costs). Therefore, the preparation and implementation must be done carefully in consultation with the main trading partners and industry stakeholders. In our view, the creation of the CBA-mechanism is such a significant and pioneering measure internationally that its preparation must strive for high quality and predictability. For this reason, we suggest that the delegated acts of the Commission proposals cannot regulate matters with such significant effects, but should, as a general rule, be resolved via normally EU regulatory routes. In particular, with regard to the scope of the CBA-mechanism, it is essential to seek to establish a regulatory mechanism that is both technically and commercially acceptable and does not lead to undesirable retaliation. The Finnish Steel and Metal Producers emphasizes that the proposed CBAM-sectors must be guaranteed - in addition to possible carbon duties - an adequate allocation of free allowances and compensation for the indirect electricity costs as long as the climate policies have leveled off as third countries have increased their climate obligations and related supportive carbon emission pricing methods. We want to also point out that already in the commission earlier impact assessment the option with CBAM and free allowances coexisting until 2035 (option 4), proved to be the best from the carbon leakage prevention and exports maintenance point-of-view. Consequently, we request that a new impact assessment, with an analysis of CBAM and full free allowances coexisting, will be performed. To our understanding the international trade community has already accepted the idea of CBAM (as long as it imposes the free allocation equivalent to the imports as it does for the EU-production). The only true danger to the WTO compatibility is the idea of using the CBAM as a revenue generator. We strongly believe that as long as the sole motive of the CBAM is climate change mitigation it can be implemented without drawbacks. More information: Kimmo Järvinen, kimmo.jarvinen@teknologiateollisuus.fi, 043 825 7642
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Response to Updating the EU Emissions Trading System

7 Nov 2021

This paper provides the initial reaction of the Finnish Steel and Metal Producers (FSMP) to Commission’s proposal for the review of the EU Emissions Trading System (EU ETS). FSMP represents Finnish Steel and non-ferrous metals producers including various Steel products, Copper, Nickel and Zinc. Executive Summary By increasing its greenhouse gas (GHG) target to 55% by 2030, the EU is adopting much stronger climate ambition compared to the countries and regions outside the EU. For energy intensive globally competing sectors such as steel and non-ferrous metals, these higher ambitions lead to higher operational costs and additional competitiveness concerns. As price taker industries, these additional costs cannot be passed on to customers without losing significant market share. These costs also weaken our capacity to invest in low-carbon untested technologies and undermines our international competitiveness in this crucial transition period. The upcoming ETS revision should take this into account and seek to improve the carbon leakage protections of industry, directly compromising the EU’s climate efforts. In particular, it will be important the ETS ensures that the best performers do not face undue carbon costs and allow for economic growth to take place within the cap. Given this, in our paper we comment on the following three strategic areas: 1. Achieving the higher climate ambition in a cost-effective manner: The EU ETS should accomplish the new target without artificially increasing carbon costs. To do so, we recommend to: i. Apply the LRF as the sole guiding principle for the cap reduction as a gradual phase-out would provide more certainty than large, punctual withdrawal of free allocation. ii. Use the MSR to provide stability, not artificial price increase, to the market to avoid major price spikes. iii. Revisit the price containment mechanism to enable authorities to react timely to excessive carbon prices. 2. Strengthening carbon leakage protection: Until other regions show the same climate ambition as Europe and comparable industries pay the same climate costs, it needs to be ensured that high climate ambition is met with reciprocal measures to protect the most exposed companies against carbon leakage. In this regard we call on policy makers to: i. Maintain the recently adopted indirect costs compensation framework until at least 2030. ii. Ensure sufficient level of free allocation at the level of realistic benchmarks without the application of the cross sectoral correction factor (CSCF). On this subject we discuss the following elements: (a) the flexibility between auctioning and free allowances; (b) the interplay with CBAM; (c) benchmarks - update rates for fallback & redefinition of their boundaries; (d) the flawed methodology used for the assessment of tiering and (e) the alignment on conditionality across recent EU regulation. 3. Accelerating the implementation of breakthrough technologies in industrial sectors: The ETS cap alone could not guarantee industrial decarbonization and more support must be given for the scalability of those technologies in this precise decade. We also comment on other important elements of the proposal like rewarding carbon removals; the implications of covering new sectors, the use of EU ETS revenues or a fair distribution of the climate ambition. Elsewhere, while a tiered approach is not adopted in the text, we reject out of principle and the methodology used by the Commission to decide on the tiers in their impact assessment. The assessment is based on flawed data and does not adequately assess a sector’s market characteristics, in particular the ability of a sector to pass on carbon costs. See the attached file for a more detailed explanation Contact: Kimmo Järvinen, managing Director, Kimmo.jarvinen@techind.fi, phone +358 43 825 7642
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Meeting with Andrea Beltramello (Cabinet of Executive Vice-President Valdis Dombrovskis), Caroline Boeshertz (Cabinet of Executive Vice-President Valdis Dombrovskis) and

19 Mar 2021 · Due diligence

Response to Climate change mitigation and adaptation taxonomy

18 Dec 2020

Finnish Steel and Metal Producers supports the EU Commission’s comprehensive strategy on sustainable finance with the aim of redirecting capital flows to help generate sustainable and inclusive growth. Decarbonization and electrification of energy intensive industries processes like steel and non-ferrous metals production will require substantially more clean energy, and especially electricity, in the coming decades. This objective can only be achieved if the EU sustainable finance criteria takes into consideration the relevant aspects of investing to low CO2-emission electricity production. Unprecedented transformative projects are needed for the development, demonstration, scaling up and adoption of new low-CO2 process and energy technologies over a relatively short time period. The sustainable finance taxonomy should facilitate this transformation and maintain a flexible approach that prevents prescriptive and rigid categories which do not take the dynamic evolution of technology and value chains into account. The transition towards carbon neutrality will not be linear, but will rather require step changes, investments and adaptations spanning over several decades. As discussed profoundly in the various EU Commission Green Deal documentation, successful transformation of the EU energy and energy intensive industry sectors is undoubtedly the most important single task to successfully achieve the climate change mitigation targets and lead the global mitigation efforts. Our view is that the technical screening criteria set by the draft act should be further fine-tuned to accommodate different energy, low-carbon and circular technology solutions and related maintenance and service activities, which all contribute to the reduction of the usage face carbon footprint (positive handprint) while rewarding innovation and competitiveness. Consequently, to ensure European technology leadership and innovation, and the subsequent green recovery, we call upon the Commission to consult the members states and main industrial sectors about the widespread desire to postpone the enactment the first delegated act until the necessary fine-tuning has been accomplished. Finnish Steel and Metal Producers proposes to amend the proposed criteria as follows and as explained in detail in the attached full version of our contribution to the consultation: a) Allow flexibility for tailor-made emerging low carbon technologies b) Maintain technology neutrality in energy production, storage and transfer • include nuclear power into the sustainable finance • assess hydropower in a technology neutral manner • include feasibility assessment in low-carbon hydrogen criteria c) Iron and Steel as enabler 1) Use internationally or regionally recognized standards or protocols which define clear accounting rules reflecting interconnections should be used for calculating the emissions of the economic activity “manufacturing of iron and steel”; instead of ETS benchmarks for example the European standard EN 19694-2. 2) Use the share of scrap input as an indicator (as done in the June 2019 TEG report) and use the following thresholds for EAF produced steel qualities: i. Steel scrap input relative to product output for conventional EAF carbon steel: >= 90 % ii. All green new steel production, or combination of new and recycled steel production, is eligible if the emissions fall below the thresholds above iii. Steel scrap input relative to product output for EAF stainless and high alloy steel (speciality steels): >=70% d) Possibility to support the transition to a low carbon economy • classify multifuel bioenergy technology and production as substantial contributor to the climate change mitigation
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