Development of a technology-neutral framework

The Global Steel Climate Council (GSCC) welcomes the preparatory work carried out by the Joint Research Centre (JRC) in the context of the future delegated act’s preparation under the Ecodesign for Sustainable Product Regulation (ESPR).

GSCC supports all efforts to develop a label grounded in scientific evidence and a robust methodology and remains ready to continue cooperating with the Commission to help establish a framework that is fair, transparent and capable of correctly identifying steel products that should be classified as low emission.

Based on the indications shared to date, it is encouraging that the JRC appears mindful of how the methodology and classification approach developed in the context of its preparatory reflections could be relevant for future work, including in relation to labelling of upstream steel products. GSCC welcomes that the JRC’s preparatory work supports an approach grounded in actual greenhouse gas emissions, robust measurement, and supporting circularity objectives. While classification remains an open issue, the overall direction appears encouraging and points towards a framework that is compatible with a technology-neutral and science-based approach.

GSCC hence supports the adoption of a technology-neutral framework that is capable of considering relevant factors beyond scrap-related considerations, while keeping actual greenhouse gas emissions as the central point of reference.

What needs to be improved?

Nonetheless, GSCC identifies different areas where further improvements could be made.

1. A more ambitious classification system
   Given the nature of the organisation, GSCC supports a more ambitious classification system that rewards real emissions reductions and provides a clear investment signal for further decarbonisation efforts.

   The JRC’s current thresholds do not provide sufficient incentives for high emitting steelmakers to commit to reducing their emissions, nor do they ensure that these companies continue investing in cleaner production routes without backtracking from previous commitments.

2. Transparency and completeness of information
   The future label should be supported by a well-functioning measurement, reporting and verification (MRV) framework that allows customers to compare low-emission steel offerings on the market based on their carbon footprint and other relevant sustainability information.

   Transparency will therefore be an essential element. GSCC’s members believe that, in order to establish a technology-neutral and transparent label, greenhouse gas emissions should be the main metric of the classification system and should be included as mandatory information to be displayed.

   Other components, such as scrap content, substances of concern, water consumption and energy consumption, should be considered complementary, while still mandatory, information. This would help customers understand the broader environmental profile of the product they are purchasing without displacing actual greenhouse gas emissions as the core basis for classification.

3. A forward-looking and dynamic standard
   Even though the JRC’s study and proposed classification system are firmly grounded in verified data and scientific evidence, GSCC members believe this is not sufficiently forward-looking.

   The system should not merely provide a fair and accurate assessment of where different companies currently stand in their decarbonisation journey. It should also create the right incentives to encourage further efforts for both primary and secondary steel producers. This framework should encourage those steelmakers that have already committed to reducing their emissions to keep pursuing their decarbonisation strategy and pathway in the future as well.

   GSCC is open to a labelling scheme in which the best-performing, lowest emission classes are defined by reference to the best-performing products currently available in terms of greenhouse gas emissions.

   Additionally, to maintain incentives for steelmakers to deliver on their decarbonisation commitments, the thresholds of the low-emission steel label could also be progressively tightened through periodic revisions, similar in spirit to the evolution of emissions benchmarks under the EU ETS. This approach would help ensure that the highest classes remain genuinely ambitious over time and that Class A is clearly distinguished from the rest of the market.

Principles and previous examples to keep in mind for future delegated acts

The Commission’s work under the Ecodesign for Sustainable Products Regulation (ESPR) is expected to provide one of the first opportunities to develop a coherent approach to low-emission steel products at the EU level. The ESPR aims to support the creation of a climate-neutral and circular economy by improving the sustainability, circularity and efficiency of products placed on the single market. GSCC firmly believes that these objectives should be preserved in the Commission’s development of future requirements for low-emission steel products.

In the context of the Construction Products Regulation, and any future delegated acts or implementing work relating to low-emission steel construction products, GSCC would also encourage the Commission to consider practical examples already emerging in the market.

For instance, in 2024, the Construction Leadership Council(CLC), together with the UK Ministry for Industry and Economic Security, launched the “Five Client Carbon Commitments” initiative to support the decarbonisation of the construction sector in the United Kingdom. Under Commitment 4, “eliminate the most carbon intensive steel products”, the initiative uses the GSCC Steel Climate Standard to define the scope of carbon calculation for procured (green) steel in combination with a classification system.

This example shows how a clear, emissions-based and technology-neutral standard can help create demand-side signals, support procurement decisions and encourage the phase-out of the most carbon-intensive steel products. GSCC believes that similar principles should guide the development of EU low-emission steel definitions and labels.

We stand ready to provide the necessary support to the European Commission and the JRC in the development of a fair and science-based low-emission steel label.

Who are we?

As the world faces the urgent need to lower greenhouse gas (GHG) emissions, the Global Steel Climate Council (GSCC®) is leading efforts to decarbonise steel production by promoting investments in lower-emission technologies and aligning with the 2015 Paris Climate Agreement’s net-zero goals.

Although steel producers are at different stages of decarbonisation, GSCC® members are united in their commitment to sustainable production. Technological solutions already exist that can reduce global steelmaking emissions by over 70%, with promising innovations like hydrogen-based ironmaking and carbon capture on the horizon.

To enable this transformation, a single, transparent, science-based global standard is essential—one that measures actual emissions regardless of production method. The GSCC® Steel Climate Standard meets this need by offering a technology-neutral, verifiable framework that holds all producers equally accountable, incentivizes innovation, and drives real emissions reductions toward the 1.5°C climate target.