Ocelářská unie
We represent Czech and Slovak steelmakers on national and EU level.
ID: 284400047930-54
Lobbying Activity
Meeting with Ondřej Krutílek (Member of the European Parliament)
30 Jul 2024 · EU policies on steel industry, energy and climate (2024-2029)
Response to Amendment of the free allocation rules in response to the ETS revision/Fit For 55
2 Jan 2024
Please find comments of the Steel Union in the attached document. (members of the Steel Union include Czech and Slovak steelmakers as well as educational and research institutions)
Read full responseResponse to Climate neutrality plan for ETS installations in response to the ETS revision / Fit for 55
1 Sept 2023
Please find bellow our crucial comments on the draft IA. Comment 1 It needs to be noted that in case of several economic sectors like steel sector, big uncertainties persist as regards available technologies for reaching climate neutrality in 2050. At the same time, generally, successful implementation of projects is highly dependent on many external factors which are not in hands of companies (physical and economic availability of sufficient amount of clean electricity, hydrogen, overall energy and economic situation, infrastructure needed, national policies, geographical circumstances, availability of financial support, development of technologies etc.). Thus, many EU companies are neither able to set concrete plan or describe specific investments, neither they can guarantee 100 % compliance with such transformation pathways by 2050 but also for 2030 etc., as required by the draft. To add, no one can, in case of each installation/company, expect continuous (5-year) CO2 mitigation or new targets/milestones every five years. This is always dependent on completed projects, their character and investment cycles. Moreover, e.g. targets or CO2 mitigation for 2025 will hardly to be set if the company plans or already stared e.g. a big investment to be finished in 2030. This needs to be taken into account when setting the rules. Thus, the CNPs should not be binding and provide sufficient flexibility to deviate from their content if the right conditions for its and needs realisation (mention under point 6(c) of the Annex) are not met. For the reasons mentioned above, companies/installations should not be forced to concretely describe all of their future measures and investments, intermediate milestones or targets, as required in the draft. The rules should allow companies/installations to set such pathways gradually in time, based on the current situation at any given time. No such flexibilities are proposed within the COM draft - this may have serious consequences on companies but also for successful reaching of climate neutrality in EU. Comment 2 The interpretation of the provisions on climate neutrality plans as being applied at installation level entails a disproportionate and inconsistent treatment. Operators of installations covering several product benchmarks and fall-back sub-installations would be subject to the obligation and penalty for their entire installations as soon as one sub-installation belonged to the worst 20% percentile of a given product benchmark in the years 2016-2017, regardless of the performance in all other sub-installations. The wording and spirit of article 10a paragraph 1 as well as the previous jurisprudence indicate that the obligation and penalty concerning climate neutrality plans for the least 20% efficient installations should be interpreted and applied at sub-installation level. This would lead to a more consistent and proportionate treatment, where the obligation and penalty are applied only for the relevant product benchmark sub-installations belonging to the worst 20% percentile. However, it should be allowed to develop the CNPs which would cover the entire group of sub-installations under one installation/entity.
Read full responseResponse to Revision of EU Ambient Air Quality legislation
14 Mar 2023
We welcome the opportunity to express our views and comments on the draft revision of AAQD. Below please find some of our main points, while in the attachement further comments on individual Articles can be found. Alignment of the future EU AQ standards with technical and economic feasibility must be a key principle of the Directive. The compatibility of the updated standards with future energy scenarios is also key not to disrupt the ongoing energy transition. More frequent updates of the EU air quality standards based on demonstrated technical progress in air pollution reduction, as required in Article 3, should be aligned, as far as possible, on investment cycles. The regular review described in Article 3 of the revised Directive should consider technical progress in air pollution reduction and involve relevant stakeholders, including industry. The appropriate measures, if applied in the end, called for in Article 19 on air quality plans should be distributed fairly among the stakeholders whose activities contribute to the exceedance situations, to the extent of their technical-economic capabilities. Not only stakeholders which can easily be monitored and targeted should be subject to these measures. This principle of fair distribution should be enshrined in the Directive, e.g. by introducing a provision requiring to prove the specific contribution of a given source of air pollution. The requirement to ensure consistency of air quality plans with other plans/legislations goes in the right direction. As recommended by the WHO, appropriate mitigation measures should be based on a careful analysis of their potential for complying with standards, as well as their costs and benefits. Flexibilities based on a cost-benefit analysis exist in sector-specific legislation, in particular the Industrial Emissions Directive and shall be duly considered. Especially, the deep industrial transformation implies that conventional production will coexist with new technologies for a period of time extending well beyond 2030. The revised AAQD should include provisions ensuring that no further investments are required in processes and measures that already comply with BAT and will be phased out. The Directive should indeed provide legal/planning certainty to allow all sectors concerned to carry on with their transition plans. Otherwise, hindering these plans may slow down or block the transformation of EUs industry, which is a precondition for substituting existing installations. This would result in the positive effects for the environment associated with this transformation to not materialise. Within this transformation, a possible temporary increase of air pollutant contribution should be taken into account/acknowledged. The requirement to involve stakeholders, including the relevant industrial federations, in the consultations for the preparation of air quality plans is welcomed. Stakeholders should not suffer from extra measures taken as a result of pollution originating from EU or third countries. Such principle must be enshrined in the Directive. Generally, public funds should be channelled towards mitigation measures rather than towards penalties or compensation mechanisms. Also, the reversal of burden of proof established in the new compensation provisions will pave the way for frivolous and abusive litigation, whilst it has now become easier for plaintiffs to demonstrate a link between the damage to health and the infringement.
Read full responseMeeting with Kadri Simson (Commissioner) and
26 Oct 2022 · Joint purchasing options.