In the coming years, being recognised as a “green product” will be crucial to secure market access and competitiveness. As the EU works towards defining “green steel”, as outlined in the Steel and Metals Action Plan, and setting up a voluntary certification scheme, EuRIC stresses the need to use  a fair and scientifically sound methodology to this end. Using a biased and flawed approach to define ‘green steel’ would distort competition, undermine decarbonisation efforts, and fail to account for the full range of climate and environmental impacts of steelmaking.

The recent JRC report on “Defining low-carbon emissions steel” compares various international initiatives and standards aimed at providing a method to identify what constitutes  “green steel.” Of the six initiatives assessed, four rely on the flawed sliding scale approach, which unfairly penalises the use of recycled materials under the pretext of limited availability. This overlooks that other resources, like iron ore, are also finite. More importantly, the sliding scale cancels out the environmental benefits of circularity, blurring the differences between steel products with vastly different carbon footprints. As a result, it risks undermining the integrity of “green steel” labels and creating inconsistent, misleading market definitions.

EuRIC strongly supports green markets and labels that incentivise the use of circular and low-carbon materials in manufacturing processes. It is scientifically proven that substituting raw materials from mining, petrochemical, or forest industries, with recycled materials is the most mature and effective way to reduce CO₂ emissions and enhance circularity. However, to ensure this substitution occurs and truly sustainable products become the norm, the methodology used to define low-carbon products, whether at the micro or macro level, must be scientifically robust. In this regard and to ensure the environmental benefits of circularity are properly recognised, EuRIC emphasises the importance of robust life cycle assessment (LCA) methodologies that properly account for the emissions savings resulting from using recycled materials instead of virgin ones, as this is key to incentivising manufacturers to reintegrate circular materials into new production cycles.

Different methodologies for assessing a product’s climate and environmental impact can yield varying results, depending on the boundaries and assumptions set in context of LCA. To avoid greenwashing, it is essential to use impartial methodologies based on quantifiable and measurable criteria and reliable data sets, while avoiding at all costs the introduction of faulty assumptions into what should be a science-based approach. Ensuring that products are ‘green’ or high performing from a sustainability perspective will be crucial to support the decarbonisation of the steel industry and to ensure that the budgets of the European Union and its Member States are used to fund projects aligned with the Union’s climate ambitions. As such, the use of robust LCA methodologies is recommended to support Green Public Procurement (GPP) and the delegated acts envisaged under the Ecodesign for Sustainable Products Regulation (ESPR).

To make sustainable products the norm, we must prioritise scientifically sound methodologies and transparency in emissions accounting. EuRIC suggests focusing on two key factors:

• Introducing mandatory local recycled content targets to increase the uptake of circular materials. Mandatory local recycled content targets are necessary to connect recycling with manufacturing, and thus ensure circular materials are reintegrated into new production cycles.
• Using scientifically reliable, robust and impartial methodologies to measure the carbon intensity and environmental footprint of products. The total CO₂ emissions per tonne of material or product produced, should be based on standardised LCA methodologies that properly account for that the emissions savings resulting from the use of recycled materials.