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Outokumpu Oyj

Outokumpu

Outokumpu is a global stainless steel producer focused on sustainable manufacturing using 95% recycled materials.

Lobbying Activity

Meeting with Katri Kulmuni (Member of the European Parliament)

27 Jan 2026 · Hiilirajamekanismista, CBAM

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

4 Dec 2025 · Steeel industry measures

Meeting with Katri Kulmuni (Member of the European Parliament) and SSAB AB

4 Dec 2025 · Terästeollisuuden näkymät EU:ssa

Meeting with Pekka Toveri (Member of the European Parliament)

4 Dec 2025 · Current Topics in EU

Meeting with Karin Karlsbro (Member of the European Parliament, Rapporteur) and SSAB AB and Stegra (formerly H2GS AB)

1 Dec 2025 · Stålmarknaden

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

4 Nov 2025 · Steel industry

Meeting with Aleksandra Kordecka (Cabinet of Executive Vice-President Stéphane Séjourné) and Fortum Oyj and

4 Nov 2025 · The meeting covered three key topics: an exchange of views on driving competitive transformation and addressing investment barriers, a discussion on the Industrial Accelerator Act, including the low carbon Steel Label.

Meeting with Wopke Hoekstra (Commissioner) and

28 Oct 2025 · High Level Dialogue with Industry executives on the implementation of CBAM

Meeting with Stéphane Séjourné (Executive Vice-President) and

28 Oct 2025 · High Level Dialogue with Industry executives on the implementation of CBAM.

Meeting with Sofie Eriksson (Member of the European Parliament) and Jernkontoret

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

Meeting with Xavier Coget (Cabinet of Executive Vice-President Henna Virkkunen)

2 Oct 2025 · Steel market

Meeting with Isabella Lövin (Member of the European Parliament) and Fortum Oyj and

1 Oct 2025 · CBAM, competitiveness, net-zero products etc

Meeting with Aura Salla (Member of the European Parliament)

30 Sept 2025 · General discussion on EU affairs

Outokumpu urges stricter CBAM rules to prevent carbon leakage

25 Sept 2025
Topic — This initiative sets the methodology for calculating embedded emissions for the CBAM definitive period.
Message — Outokumpu requests including indirect emissions from 2026 to align with EU ETS rules. They argue for default values based on carbon-intensive methods to prevent resource shuffling. They also propose a melted and poured approach to origin to stop circumvention.123
Why — Stricter rules protect Outokumpu’s green investments by ensuring a level playing field against high-emission imports.45
Impact — Carbon-intensive foreign producers lose the ability to bypass levies through selective exporting of cleaner products.678
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Outokumpu demands strict standards for foreign carbon price recognition

25 Sept 2025
Topic — Consultation on rules for converting foreign carbon prices into CBAM certificate deductions.
Message — The company calls for a cautious and conservative approach to recognizing carbon prices paid in countries of origin. Only explicit and net carbon costs from robust climate legislation should be accepted. They insist that all rebates be deducted and that energy taxes not be recognized.123
Why — Stricter recognition rules prevent foreign competitors from using weak carbon schemes to avoid CBAM costs.4
Impact — Exporters from third countries with less transparent or recently introduced climate measures may face higher levies.56
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Outokumpu demands CBAM benchmarks reflect best environmental technologies

25 Sept 2025
Topic — The consultation defines rules for adjusting CBAM obligations as free carbon allowances phase out.
Message — The organization requests that CBAM benchmarks reflect the best environmental technologies and processes. They specifically propose that stainless steel benchmarks reflect the lowest content in virgin ferro alloys.12
Why — This would protect the company's competitiveness by ensuring importers face similar carbon costs.3
Impact — Importers using carbon-intensive production methods would face higher financial obligations at the border.45
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Meeting with Adam Romanowski (Cabinet of Commissioner Maroš Šefčovič)

3 Sept 2025 · Implementation of the Steel and Metals Action Plan (SMAP)

Meeting with Mika Aaltola (Member of the European Parliament)

30 Jun 2025 · EU Affairs

Meeting with Antti Timonen (Cabinet of Executive Vice-President Henna Virkkunen)

21 May 2025 · EU competitivenes, economic security, clean energy, steel and aluminium action plan

Meeting with Koen Doens (Director-General Directorate-General for International Partnerships) and

15 May 2025 · Greenland Resources to present its mining project in Greenland and the new ten year’s off-take agreement signed with Outokumpu by which Outokumpu, European Steel leader, would source molybdenum from Greenland.

Meeting with Anne Fort (Cabinet of Commissioner Andrius Kubilius), Ramunas Stanionis (Cabinet of Commissioner Andrius Kubilius) and Greenland Resources

14 May 2025 · Critical Raw Material strategy

Meeting with Pekka Toveri (Member of the European Parliament)

29 Apr 2025 · Current Topics in EU politics

Meeting with Eero Heinäluoma (Member of the European Parliament)

29 Apr 2025 · Teräs- ja metalliala

Meeting with Olivia Gippner (Cabinet of Commissioner Wopke Hoekstra), Patrice Pillet (Cabinet of Commissioner Wopke Hoekstra)

28 Apr 2025 · Exchange of views on the Carbon Border Adjustment Mechanism (CBAM)

Meeting with Gabriela Tschirkova (Cabinet of Commissioner Valdis Dombrovskis)

23 Apr 2025 · Simplification

Meeting with Katri Kulmuni (Member of the European Parliament)

23 Apr 2025 · Vastuullisen terästuotannon kilpailukyky Suomessa ja Euroopassa

Meeting with Elsi Katainen (Member of the European Parliament)

23 Apr 2025 · Vähähiilinen teräs

Meeting with Miguel Jose Garcia Jones (Cabinet of Commissioner Wopke Hoekstra)

23 Apr 2025 · Discussion on Europe’s Steel sector competitiveness.

Meeting with Sanna Laaksonen (Cabinet of Executive Vice-President Henna Virkkunen)

23 Apr 2025 · Commission work programme

Meeting with Elsi Katainen (Member of the European Parliament)

23 Apr 2025 · EU´s Steel and Metals Action Plan and Clean Industrial Deal

Meeting with Anna-Maja Henriksson (Member of the European Parliament)

23 Apr 2025 · Steel

Meeting with Alexandr Vondra (Member of the European Parliament)

23 Apr 2025 · European steel and metals action plan

Meeting with Kerstin Jorna (Director-General Internal Market, Industry, Entrepreneurship and SMEs)

22 Apr 2025 · Exchange of views on the Steel & Metals Action Plan and Clean Industrial Deal

Meeting with Luis Planas Herrera (Cabinet of Commissioner Jessika Roswall), Paulina Dejmek Hack (Cabinet of Commissioner Jessika Roswall)

22 Apr 2025 · Clean Industrial Deal and Omnibus packages

Meeting with Kurt Vandenberghe (Director-General Climate Action)

22 Apr 2025 · Clean Industrial Deal and the Omnibus packages

Meeting with Ann-Sofie Ronnlund (Cabinet of Commissioner Ekaterina Zaharieva)

9 Apr 2025 · Steel and metals action plan.

Meeting with Mauri Pekkarinen (Member of the European Parliament, Rapporteur for opinion)

18 Aug 2022 · Visit at Outokumpu, discussion on ETS and energy efficiency in the EU

Meeting with Taneli Lahti (Cabinet of Commissioner Jutta Urpilainen)

20 May 2021 · Steel industry

Response to Climate change mitigation and adaptation taxonomy

18 Dec 2020

We thank for the opportunity to give input to Taxonomy proposal and provide the following comments: Section 3.8. a) in Annex I and II: To evaluate the environmental and societal impact of activities of the steel industry, the entire life cycle needs to be assessed. This in line with Article 19 (g) of the regulation. As part of a life cycle approach, it is key to assess the performance along the entire steel value chain, including all inter-connected steelmaking processes, to have consistent data and avoid misleading results which would compromise the existence of sustainable steel value chains in Europe. The methodology of ETS benchmarks is not able to evaluate the environmental impact of the activities of the steel industry as it does not consider the interconnected processes that make up the steel production value chain. Those benchmarks are defined to be used in the EU ETS. In practise, different product benchmarks would need to be integrated to obtain a reliable methodology for the calculation. Another agreed methodology is also needed to consider the value chain. Internationally or regionally recognised 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. 3.8. b) in Annex I and II: The threshold of 90% scrap use is achievable only for EAF installations that manufacture low alloyed steel. For high alloyed steels, like stainless steel, a significant part of the raw materials are alloying elements that are not available in high enough quantities to meet the threshold. In stainless steel making, the best performers reach >75% scrap use, while the global average of scrap use is only 44%. We suggest adding the following share of scrap input: (c) steel in electric arc furnaces (EAFs) and at least 70 % of the iron content in the final stainless steel and high alloy products is sourced from scrap steel.
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Response to Review of Directive 2012/27/EU on energy efficiency

21 Sept 2020

Introduction Energy efficiency is one of the most cost-effective ways to decarbonise the energy system in both short and long term. A successful energy efficiency policy should aim at supporting multiple targets such as strengthening the competitiveness of industrial value chains and helping to reach climate goals, among others. Such goals will however depend on several sectors (industry, transport, buildings) and the use current as well as the development of future technologies. The right combination of regulation, policies, programmes and incentives at EU and national levels to encourage energy efficiency is also crucial. Any proposal to revise the current Energy Efficiency Directive (EED) should be based on solid evidence and relevant measures. For example, the results of the upcoming impact assessment for the 2030 Target plan should be taken into account. Outokumpu supports an exhaustive assessment of the current framework to overcome non-regulatory barriers, market failures and weaknesses that may arise from COVID-19 crisis. General remarks Outokumpu supports Option 2 – Non regulatory measures with particular attention to financial measures and regimes that could support energy efficiency projects and pilots. Outokumpu recalls the European Commission to refrain from proposing any particular binding measures for sectors included in the ETS Phase IV, in particular those highly exposed to a significant risk of carbon leakage. Outokumpu also supports the proposal for public procurement criteria and recovery of heat waste that may provide incentives to invest in innovative energy efficiency projects. In terms of EU Energy Efficiency targets, the need for more stringent targets should be assessed based on the results of the submission of National Energy and Climate Plans. This assessment is crucial to avoid excessive and unrealistic targets that may create divergent outcomes in different countries. Member States should continue to have the possibility to set their own indicative national energy efficiency targets and efficiency obligation schemes to deliver their commitments based on their regional and local specificities. Voluntary energy efficiency agreements have been effective and should be continued Current EED offers Member States several options how to improve energy efficiency on a national level. Some Member States have opted for article 7b on alternative policy measures. Energy efficiency agreements are means jointly chosen by the central government and the participating sectors for meeting the international energy efficiency targets and obligations. The use of energy efficiency agreements has proven to be successful. The use of voluntary sectoral measures and schemes for further energy efficiency improvements should be continued. Energy consumption cap must be removed Capping energy consumption as it is now in the current EED is problematic in several ways. European energy sector is going through a revolution from fossil fuels towards use of carbon free and renewable energy sources. Energy storages with sufficient capacity and response time is needed for balancing variations in energy production and consumption. One option is converting renewable energy to hydrogen and further to various fossil free carbon hydrate fuels (P2X). Due to losses in conversions production of green hydrogen and P2X requires significant amounts of clean electricity. Also, electrification itself offers major GHG emission reduction potential in many other industrial processes and operations as well as in transportation and logistics. Combatting climate change is the top priority not only in Europe but globally. Therefore, reducing GHG emissions is more important than cutting total energy consumption particularly when electricity is produced by using fossil free energy sources. Low carbon electricity will be crucial to the carbon neutral future. Therefore, the energy consumption cap should be removed from the EED.
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Meeting with Thierry Breton (Commissioner) and

10 Sept 2020 · EU industrial strategy

Response to Climate Law

1 May 2020

Global CO2 emissions need to be reduced significantly during the next decade. Even if the emissions in the EU have reduced, global emissions continue to grow. Climate change mitigation needs strong global actions. Third countries will provide final NDC’s submissions to the Paris Agreement in 2020. As a key requirement for EU’s climate diplomacy and leadership, it is necessary to evaluate these commitments before the EU decides on any changes in its 2030 reduction targets. It is also necessary to assess the full impact of the ongoing COVID-19 outbreak. There is an urgent need to strengthen the carbon leakage measures. Carbon Border Adjustment (CBA) should be a complementary tool to reduce carbon leakage, not an alternative. CBA should take into account the whole carbon footprint. This broader approach is also needed to avoid further outsourcing of emissions to supply chain. The second key objective of the strategy towards climate neutrality is to make Europe more attractive for investments. The transformation of the steel sector will require significant investment in the breakthrough technologies while the sector needs to remain competitive throughout the entire transition and beyond. This can be better achieved if the Climate Law proceeds simultaneously, rather than preceding the overall enabling framework’s initiatives in the field of industrial, RDI, finance, trade and competition policies that are necessary to preserve industrial competitiveness. Industry needs stability and predictability in the regulatory framework to plan and implement the necessary long term investments. A third key element is to ensure the capability of the operating environment to support the transition. Affordable low carbon electricity as well as the availability of steel scrap in the EU are essential for a successful transition towards a low carbon future. Art. 2 Climate-neutrality objective The climate neutrality target in article 2(1) is referring to “emissions regulated in Union law”, i.e. EU production emissions. The EU represents only around 10% of global emissions, and this share is further decreasing. It is essential to monitor not only emissions from EU producers but also emissions embedded in consumption in order to preserve environmental integrity and avoid carbon leakage. A linear trajectory covering emissions from production in the EU has limited impact on worldwide emissions if it is compensated by increased emissions from imported products. For example, more than 30% of the stainless steel consumed today, is produced outside the EU. The footprint of stainless steel produced in China or Indonesia is in average almost five times bigger compared to products produced by Outokumpu. Thus, the Asian imports generate every year a carbon leakage of 9 Mt CO2. For carbon neutrality of the EU, imported emissions need to be taken into account. Art.3 Trajectory for achieving climate neutrality An incremental change through energy efficiency is not sufficient for climate change mitigation. There is need to accelerate the development and uptake of breakthrough solutions in all sectors of the economy. Innovation does not follow a linear trajectory in emission reduction. Especially disruptive breakthrough technologies that are needed for the long-term climate neutrality objective require sufficient time for being developed, upscaled and commercialized. There is also a need to ensure the availability of affordable low carbon energy and steel scrap. Art.4 Adaptation to climate change The international dimension of impact assessments should be complemented by a regular analysis of adaptation costs, based on international climate commitments. Third countries represent 90% of global emissions. As the climate ambition of the third countries has a major impact on EU adaptation costs, this element should be addressed transparently in the implementation of the Climate Law.
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Response to Climate change mitigation and adaptation taxonomy

27 Apr 2020

As the largest stainless steel producer in Europe, Outokumpu would like to address the following: Steel is the most important building material of the European infrastructure, logistics and transport. Without steel there is no renewable energy. The use of steel decreases much more greenhouse gas emissions in society than its production creates. Already today European stainless steel producers are the most sustainable companies in the global industry. Globally Outokumpu has the lowest carbon footprint including scope 3 emissions in our stainless steel. Comment to the report on taxonomy: 1. Technical criteria should cover all dimensions of sustainability must be also included. EU-ETS benchmark represents only steel melting shop, not company performance.. - Using genuinely an integrated lifecycle approach to take into account steel as an enabler for CO2 mitigation in multiple value chains. An approach based merely on ETS benchmarks would fall short of taking the overall effects of steel products on the environment and the society into account. - Using the principles of standard EN 19694-2, developed with a mandate from the EU Commission, to assess relative performance in place of unsuitable ETS benchmarks where lifecycle approach is not available. 2. Outokumpu has the highest recycled content in products globally but the proposed recycled scrap criteria are impossible to reach for any stainless steel company in the world. Stainless steel and high alloyed steel are made in Europe through EAF route, mainly from recycled steel. There is not enough recycled stainless steel available in Europe or globally. Other alloys like ferrochromium and ferronickel are always needed for the product steel grade. Chromium content in stainless steel is ~18%. The proposed threshold does not consider all the EAF steel qualities. According to our experience for high alloy and stainless steel the recycled scrap criteria should be 50%. The proposed criteria have to be revised or stainless steel companies must have a separate criteria from carbon steel. During the next implementation of such a requirement, this principle should be absolutely taken into account. 3. Carbon valorisation/CCU technologies should be included in the above list of breakthrough technologies. 4. It is important that Blast Furnace Slag has been removed from the list of main potential source of significant harm to other environmental objectives from the iron and steel production acknowledging the substantial contribution of slag to climate change mitigation, however, this not recognised in the benchmarks. This applies also to other slags from metal industry. The use of slag decreases greenhouse gas emissions in society compared to virgin materials. E.g. use of Outokumpu’s ferrochrome slag products in road layers decreases by 50-75% the carbon footprint of road construction and it replaces virgin materials. Steel and our by-products help mitigate product lifecycle emissions. During the next phase of the implementation of taxonomy these should be assessed and taken into account as a part of sustainability of the metal industry.
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Response to 2030 Climate Target Plan

15 Apr 2020

Outokumpu welcomes the opportunity to provide feedback to the Inception Impact Assessment of Climate Target Plan 2030. Global CO2 emissions need to be reduced significantly during the next decade to avoid irreversible damage from climate change. The emissions in the EU have EU have reduced continuously. At the same time, global CO2 emissions continue to grow. Climate change mitigation needs strong global actions. Countries will provide their final NDCs submissions according to the Paris Agreement to the UNFCC by the end of 2020. It is necessary to evaluate and take into account the level of commitments of the third countries. It is also necessary to assess the full impact of the ongoing COVID-19 outbreak. Preliminary assessments indicate that with the existing burden sharing between ETS/non-ETS sectors, an increased ambition to 50...55% would have a significant impact on the EU ETS market, with a respective reduction in available allowances by 1.2…1.8 billion. In the absence of further adjustments, that could mean a reduction of free allowances respectively by 500M…750M. This would more than nullify the 3% auctioning/free allocation shares’ flexibility agreed in the recent ETS revision. According to, carbon prices would rise to levels around 50…75€/tCO2 by 2030 for ambition at 50...55%. A comprehensive analysis of carbon leakage measures is needed. Carbon leakage measures need to remain commensurate to and effective for the high level of pursued climate ambition. The increased climate ambition would require that carbon leakage provisions are strengthened. The proposed Carbon Border Adjustment mechanism is needed as a complementary measure to reduce carbon leakage, and not as an alternative to existing ones, i.e. free allocation and indirects compensation. Also, Carbon Border Adjustment mechanism should take into account the whole carbon footprint, not only direct emissions. This would further strengthen EU’s role as a global climate leader. A broader approach is also needed to avoid further outsourcing of emissions to supply chain. The carbon leakage assessment needs to have a forward-looking approach instead of historical evidence as mentioned in the Inception Impact Assessment. The assessment of the techno-economic potential needs to take into account the external factors - the enabling regulatory framework and the relevant energy and raw materials - that would allow to overcome the barriers and materialise such potential. Hence, the plan needs to include concrete proposals on the enabling regulatory framework and the abatement potential should not be used as an argument for reducing carbon leakage protection, since it would make EU companies more vulnerable in the decisive time when compliance costs are complemented by the abatement costs of the implementation of the breakthrough technologies. The initiative aims to assess what would be required to have a more balanced reduction pathway from 2020 to 2050. However, innovation does not follow a linear path and especially disruptive breakthrough technologies that are needed for the long-term climate neutrality objective will require sufficient time for being developed, upscaled and commercialized. Thus, an accelerated pathway post 2030 could well be achievable when such technologies reach a sufficient level of maturity. The most cost-efficient and internationally sound burden sharing between ETS and non-ETS should be applied when the target is set. We welcome the statement that all sectors of the economy and society will need to contribute to the transition. There is a large potential for example in the buildings, agricultural and transport sector.
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Response to Carbon Border Adjustment Mechanism

1 Apr 2020

- Carbon Border Adjustment (CBA) would be supplementing the European Climate Policy. It is needed to achieve the long-term ambitions of EU climate policy while avoiding carbon leakage. CBA can also be seen as a temporary tool whereas the long-term target is to have a global price for carbon. - CBA should be based on the whole carbon footprint which takes into account direct emissions, the emissions from electricity production as well as the emissions from the production of raw-materials. If this is not possible in the scoping of CBA, then EU should immediately start preparing standards to set limits for carbon footprint. The timing and products should be the same as for CBA. - In the transition towards global climate neutrality, CBA needs to complement the current for carbon leakage preventing measures in the Emission Trading System, i.e. free allocation and compensation for indirect costs. The EU aims to be a global leader for the EU leadership in the global climate change mitigation. At the same time global emissions continue to grow. As long as there is no international binding agreement with a global carbon price of carbon, there is a need to reduce the risk for carbon leakage. Carbon leakage is evident in the steel market where imports of stainless steel now account for more than 30% of the European steel consumption. At the same time, the steel produced in Asia creates up-to 5 times higher CO2 emissions compared to European producers’ emissions. Avoiding the risk of carbon leakage is a pre-condition for preserving the environmental integrity of EU climate policy and industrial competitiveness. EU ETS free allocation and indirect compensation are designed mainly to address the risk of production relocation, thus tackling the carbon leakage only partly. Carbon border measure can be an effective instrument to address structurally the emissions embedded in the imported products if it takes into account the total carbon footprint. The preparation of carbon border adjustment should start with the most vulnerable sectors, such as steel. Carbon Border Adjustment must include the whole carbon footprint to be effective For stainless steel, a significant part of the product CO2 footprint is typically attributed to scope 3. Thus, it is crucial that carbon border adjustment mechanism takes into account the whole carbon footprint. If this is not possible, then the EU needs to set limit values for product carbon footprint. The time-schedule and scoping should be the same as for carbon border adjustment Reporting and measurement of carbon emissions as part of CBA The data submitted by producers should be measured and reported according to a specified protocol and there should be a verification by a third party. The EU should define a standard for the calculation of the total carbon footprint. It would also be possible to use international standards, for example for life cycle assessment. The current carbon leakage measures are still needed Until the EU has a comprehensive CBA mechanism and enough experience of its functionality, the current tools to reduce the risk for carbon leakage, i.e. free allocation, and indirect compensation, are essential. In particular, rules on carbon leakage measures for the period until 2030 have been adopted very recently and should not be modified. Even with free allocation and compensation, EU producers bear carbon costs that are not applied to extra EU competitors. This divergence will further increase in the future.
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Response to Commission Regulation amending the CLP Regulation (EC) 1272/2008 and correcting Commission Regulation (EU) 2018/669

4 Feb 2019

Outokumpu is a major producer of stainless steel in the EU and we are deeply concerned about the proposed classification of cobalt and the implications it will have on stainless steel due to the small amounts of cobalt that are present in all stainless steel as impurity. We propose that the cobalt classification should not be included in this act as there are still open issues regarding for the proposed classification; for example the lack of scientific evidence for extending the carcinogenicity to all routes instead of by inhalation as proposed by industry. Also, the epidemiological studies that indicate that there is a threshold value have not been taken into account In addition, since the consequences of such a severe classification will be significant for stainless steel in downstream legislation (medical devices, ecolabelling, waste classification and recycling) we propose that the cobalt classification should be postponed until there is guidance in place for classification of special mixtures. Special mixtures (like some metal alloys) are mentioned in the REACH regulation but the CLP fails to give clear guidance on their classification. Stainless steel is such a special mixture and while it has been proven that the hazards of stainless steel are different from the individual components in the steel, the lack of clear guidance on special mixtures under CLP is an obstacle to having a correct classification.
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Meeting with Jyrki Katainen (Vice-President)

23 Nov 2018 · Exchange on ongoing safeguard investigation on steel

Meeting with Jyrki Katainen (Vice-President)

6 Mar 2018 · Exchange on possible US tariffs on steel and aluminium