Re Alloys
Re Alloys jest zaufanym i cenionym w branży producentem żelazostopów.
ID: 262629996873-10
Lobbying Activity
Response to General revision of the General Block Exemption Regulation
6 Oct 2025
The European steel industry, as an energy-intensive sector deeply integrated into multiple value chains, plays a vital role in the EU economy while operating under conditions of intense global competition. In recent years, the sector has faced rising unilateral carbon costs and significantly higher energy prices compared to producers outside the EU. Over the past decade, the EU has shifted from being a net exporter of over 9 million tonnes of steel products annually to a net importer of steel on a similar scale. Recent data also point to record-low capacity utilization rates in steel plants across Member States. The increase in production costs within the EU, combined with the absence of comparable climate-related burdens in third countries, has led to unfair competition and carbon leakage. Steel production relocated outside the EU often occurs with lower energy efficiency and higher CO emissions, undermining the effectiveness of European climate policy. Particularly damaging is the impact of electricity prices, which can account for up to 40% of steel processing costs meaning even small differences in energy prices have a significant effect on the sectors international competitiveness. Another factor weakening the position of European steelmakers is the widespread use of industrial subsidies by third countries, especially China. According to OECD Steel Committee analyses, the level of support for Chinas steel sector is more than ten times higher than in OECD countries, causing severe distortions in global markets. Despite the introduction of the CBAM mechanism, European steel will remain exposed to carbon leakage in the coming years unless climate and energy costs in the EU are offset through exemptions or other forms of support. The GBER should enable Member States to provide more effective support to energy-intensive industries during the transition period. It is essential to allow measures such as reductions in energy charges and other forms of aid that must be implemented efficiently. Moreover, the use of such instruments should be facilitated, and complex administrative procedures should be minimized. In this context, the review of GBER rules must consider the real operating conditions of the steel industry. It is necessary to re-evaluate the long-standing exclusion of the steel sector from regional aid, so that European steel plants can benefit from investment incentives on equal footing with other industrial sectors. The revision of GBER should also make it easier to support decarbonisation projects in steelmaking, as the transition to low-CO steel production requires substantial public funding to prevent carbon leakage and maintain steel production within the EU. In order to attain this objective, a change in the approach to the incentive effect is also required. The provisions of the GBER should enable the implementation of comprehensive strategies for decarbonisation and zero-emission green production, allowing for the development of integrated and diversified investment projects ultimately leading to zero-emission production. However, the current GBER regulations concerning the incentive effect either prevent or significantly hinder the implementation of such projects. Attached to this contribution is a detailed statement outlining our position and proposed amendments to the State aid regulations and in particular to the GBER
Read full responseMeeting with Adam Romanowski (Cabinet of Commissioner Maroš Šefčovič) and ERAMET and
11 Sept 2025 · The situation of the ferroalloys industry in the EU
Response to Modernisation Fund - first evaluation of the operating rules
12 May 2025
The current structure and practices of the Modernisation Fund do not provide sufficient transparency and predictability regarding the availability of funds, which hampers long-term planning for transformation projects. Therefore, the industry advocates for changes to ensure that investments related to industrial decarbonization are clearly identified as priority investments within the Modernization Fund and included in the list of projects specified in Article 10d(2) of Directive 2003/87/EC on the ETS. This solution would facilitate national authorities managing the fund in planning support for European industry and dialogue with the European Investment Bank and the Investment Committee, providing greater predictability and stability in investment planning for businesses. The industrial sector, especially the steel industry, expresses readiness to take action towards decarbonization, which in some cases means changing technology and replacing current integrated process installations (BF/BOF) with direct iron reduction installations combined with an electric arc furnace (EAF). The sector needs access to clean, green electricity and is ready to invest in this area, as well as consider the use of CCS technology. The industry is prepared to implement innovative technologies and transform production processes in line with EU climate goals. However, without strong institutional and financial support, the pace of this transformation will be insufficient, and the risk of losing competitiveness and relocating production outside the EU will grow. The industry expects real partnership and tools that will enable a safe and effective transition to a new economic model. Experience from the steel industry shows that there is a wide portfolio of projects that could be financed through the Modernization Fund. The effectiveness of these actions requires an appropriate financing model given the current market and cost situation, these investments can only be realized through direct grants, as the steel sector cannot afford capex commitments. Support forms based solely on market-based or repayable instruments are not suited to the industry's needs. Therefore, programs within the Modernization Fund offering loans directed at the industry are not popular, and the sector continues to call for changes in financing rules, regarding considering within the support also grants, blended with repayable financial instruments. Furthermore, the current formula for providing support to private entities does not allow for the financing of comprehensive decarbonization strategies. The European Investment Bank (EIB) makes an exception only for large public enterprisesprimarily in the energy sectorby offering a framework loan facility. However, achieving net-zero production targets requires the implementation of integrated strategies composed of multiple, thematically diverse projects, such as renewable energy sources (RES), carbon capture, utilization and storage (CCUS), waste heat recovery, and other decarbonization elements, rather than the financing of individual projects through project finance mechanisms. Additionally, the eligibility criteria imposed on investment proposals significantly restrict access to support. These requirements tend to act as barriers, rather than focusing on the actual objectives of decarbonization investments. They exclude projects already initiated by other entities which could be continued by a subsequent purchaser. Under the current rules, the acquisition of companies established specifically for the implementation of projects, i.e. Special Purpose Vehicles (SPVs), as well as the continuation of projects that are at an early stage or have not yet commenced but hold all necessary administrative permits is not considered an eligible cost. This restriction applies even though such projects could significantly accelerate progress towards achieving zero-emission targets.
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