Brussels, 7 April 2026 – With discussions ongoing in Brussels on how to define green steel, Recycling Europe emphasises the urgent need for an impartial and scientifically credible approach that rewards circularity and promotes the use of recycled metals in steel production. Such an approach cannot be based on methodologies that penalise the use of ‘scrap’, such as the so-called “sliding scale” currently being discussed amongst steel stakeholders.

In this context, Recycling Europe expresses serious concerns regarding Responsible Steel’s communication of 18 March (Global Recycling Day), which claimed that the “sliding scale” methodology supports recycling. This assertion is misleading and contradicts the actual benefits of circularity.

To comprehend the paradox of such an argument, it is essential to understand how the sliding scale works. The methodology applies a scrap-adjusted approach, whereby installations using less recycled steel scrap are allowed to emit more CO₂, and yet, still qualify as “green steel.” Rather than incentivising  better environmental performance, the sliding scale effectively rewards more carbon‑intensive production, practically ‘penalising’ higher use of recycled materials.

It is crucial to clarify that the sliding scale is neither scientifically robust nor environmentally credible. It distorts the clear link between actual emissions and sustainability claims, undermining the core principles of circularity and resource efficiency. If embedded in legislation, it risks misleading policymakers, investors, and end‑users, into believing that higher emission production routs are ‘greener’ than the circular ones, thereby weakening trust in green steel classifications. By allowing higher emissions thresholds to be offset through adjustment factors, this methodology dilutes the environmental value of recycling instead of strengthening it.

Even more concerning, the sliding scale favours steel production routes reliant on iron ore, a feedstock almost entirely imported from outside the EU, further worsening EU’s dependence on third-country supplies. In contrast, recycled steel is abundant within the EU and already exceeds current demand. Its use represents the most circular and carbon-neutral way to decarbonise steelmaking, while also strengthening supply security, strategic autonomy and re-industrialisation.

The European recycling industry remains fully committed to supporting the decarbonisation of the steel sector, including the transformation of primary steel production, which remains vital for Europe. To achieve this, the EU needs a credible green steel framework that is grounded in measurable, verifiable carbon intensity and not one that relies on distortive adjustments such as the sliding scale.

The ‘green steel’ label should recognise the distinct characteristics of primary and secondary steelmaking routes in order to create a fair, predictable, and investment-grade framework. It must value circularity, including recycled steel scrap, independently, and not allow it to be used to justify higher absolute emissions. Such a label would ensure transparency, scientific integrity, and genuine comparability of emissions data. This is why a one‑size‑fits‑all methodology, such as the sliding scale, which ignores these fundamental differences, risks undermining both decarbonisation goals and the development of a truly circular steel economy.

Recycling Europe therefore urges ResponsibleSteel to reconsider its public claims regarding the sliding scale and to align its position with a scientifically sound and environmentally credible approach. We also remain open to constructive dialogue with ResponsibleSteel, stakeholders and policymakers, and stand ready to contribute to the development of a robust, policy‑aligned framework for green steel that genuinely supports the decarbonisation and competitiveness of primary steelmakers within the EU.