Opinion of the European Economic and Social Committee – Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions – A European Steel and Metals Action Plan (COM(2025) 125 final)
Date: 2025-09-18
Institutions: European Economic and Social Committee
Subjects: European industrial area, action programme, competitiveness, greenhouse gas, iron and steel industry, metal waste, metals, price of energy, reduction of gas emissions, waste recycling








C_202600036EN.000101.fmx.xml












Official Journal of the European Union


EN
C series













C/2026/36


16.1.2026






Opinion of the European Economic and Social Committee
Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions
A European Steel and Metals Action Plan


(COM(2025) 125 final)


(C/2026/36)


Rapporteur: 
Anastasis YIAPANIS (CY-III)

Co-rapporteur: 
Michal PINTÉR (SK-Cat. 1)






Advisor


Mihai Ivașcu (to the Group III rapporteur)
Bartosz Nienałtowski (to the Category 1 co-rapporteur)




Bureau decision


21.1.2025




Referral


European Commission, 13.5.2025




Legal basis


Article 304 of the Treaty on the Functioning of the European Union




Section responsible


Consultative Commission on Industrial Change




Adopted in section


10.7.2025




Adopted at plenary session


18.9.2025




Plenary session No


599




Outcome of vote
(for/against/abstentions)


95/0/0




1.   Conclusions and recommendations









1.1.


The European Economic and Social Committee (EESC) expresses its deep concern over the crisis facing the EU steel industry and calls for urgent measures to restore competitiveness, maintain quality jobs and boost investment in the transition of the steel and metals sectors. These measures should address short-term criticalities and be closely monitored to allow adjustments where necessary.












1.2.


In particular, the EESC calls for:






(a)


the urgent tabling of a new and comprehensive trade measure to replace the current steel safeguard before its expiry on 1 July 2026, covering all countries and all steel products affected by global overcapacity, and using the tariff-rate quota system linked to import market share and domestic capacity utilisation, in order to avoid harming downstream users while maintaining sector viability;










(b)


the immediate introduction of a ‘melted and poured’ rule to effectively combat circumvention and enhance the traceability of steel origin, as well as selective suspension of the ‘lesser duty’ rule;










(c)


the release of the legislative proposal on the Carbon Border Adjustment Mechanism (CBAM), with provisions to retain free allowances for exports to non-EU countries lacking comparable climate commitments. The proposal should establish robust default emissions values to discourage resource shuffling and uphold the environmental goals of the CBAM, as well as expand the CBAM’s scope to cover downstream, steel-intensive sectors;










(d)


the swift adoption of the Omnibus I proposal (1) to protect SMEs from unnecessary administrative and cost burdens under the CBAM whilst ensuring that environmental and social objectives are not undermined;










(e)


the Commission to recognise the strategic role of metal scrap as a secondary raw material and to propose a robust monitoring system for scrap exports. This should include measures such as export duties or tariff quotas to secure domestic supply, strengthened enforcement against illegal scrap exports and the integration of ferrous scrap recycling into end-of-life product legislation;










(f)


the adoption of secondary legislation – within the implementation of the Waste Shipment Regulation – to ensure that only waste exports to countries meeting EU-equivalent environmental and social standards are allowed;










(g)


structural reform of the electricity market and a comprehensive impact assessment of alternative market designs in order to transfer the costs benefits of clean electricity to both households and industrial consumers;










(h)


the introduction, under the Clean Industrial State Aid Framework (CISAF), of specific guidance for Member States on implementing temporary energy price relief schemes for energy-intensive industries exposed to international trade;










(i)


it to be possible for a predefined share of subsidised electricity from power purchase agreements (PPAs) to be provided at cost-plus pricing to selected energy-intensive industries, through new guidelines on PPAs and contracts for difference (CfDs);










(j)


the Commission to prioritise hydrogen access for industrial users by allocating dedicated sectoral budgets within future Hydrogen Bank auctions, to revise the Delegated Act on Renewable Hydrogen to enable cost-effective domestic production, and to swiftly adopt a delegated act on low-carbon hydrogen. Additionally, green electricity criteria should be made more flexible to facilitate faster hydrogen roll-out;










(k)


a proposal on ambitious resilience and sustainability criteria to strengthen the production of EU-made clean products, involving quality jobs, as part of the Industrial Decarbonisation Accelerator Act;










(l)


the Commission to assess the investment and funding needs of the steel and metals industries, and to consider increased and dedicated financial support, accompanied by social conditionalities where relevant, including via the earmarking and channelling of financial resources under the CBAM to covered sectors as well as by directing EU ETS revenues towards supporting industrial scale projects in the steel and metals industries, including via the upcoming Industrial Decarbonisation Bank;










(m)


the introduction of a dedicated Just Transition Fund for energy-intensive industries, with a focus on up-skilling and reskilling programmes and mobility support to help workers transition between regions and sectors; and










(n)


effective involvement of the social partners in all green transition policies, backed by clear commitments to promote social dialogue, collective bargaining, and applicable health and safety standards in the workplace.








2.   General comments









2.1.


On 26 February 2025, the Commission launched the Clean Industrial Deal (CID) and the Action Plan on Affordable Energy. The CID included measures to strengthen the competitiveness of energy-intensive industries and the clean tech sector and recognised the urgent need to support the decarbonisation of energy-intensive industries, switch to clean energy and tackle high energy costs, unfair global competition and complex regulations.












2.2.


The EESC acknowledges the challenges facing the steel and metal sectors; these include global overcapacity and unfair practices undermining the level playing field, high energy costs, carbon leakage, the need to invest in decarbonisation and the importance of keeping metal scrap in the EU. It also acknowledges that the European metals industries, which represent a significant share of EU greenhouse gas emissions, have undertaken to meet the EU’s climate and environmental goals. Furthermore, the EESC highlights the need to protect and promote quality industrial jobs, as the sector provides direct and indirect employment for nearly three million workers.












2.3.


The EU’s share of global steel and metals production has dramatically decreased over the past decade. China, but also India, other ASEAN countries and the Middle East, have massively expanded their production capacity, often supported by distorting subsidies. OECD data estimate that global steel overcapacity will rise from 602 million tonnes in 2024 to 721 million tonnes by 2027 (2), more than five times the EU’s steel annual production.












2.4.


The EESC acknowledges the European Commission’s view that steel and metals are essential for the EU’s 
economy, strategic autonomy, green and digital transition and its
 defence. For example, a battle tank contains 50 to 60 tonnes of high-quality steel, a self-propelled artillery system up to 100 tonnes and a fighter aircraft 3 tonnes of aluminium (3). In today’s geopolitical context, securing a stable and resilient supply chain for these materials is essential.












2.5.


Global overcapacity, low profit margins, high energy costs, a market unwilling to pay a premium for green products and insufficient funding hinder investment in decarbonisation. The EESC points out that urgent measures are needed to avoid further plant closures, job cuts and industry decline across Europe and ensure that the steel and metals industries can continue to deliver for strategic sectors, including defence and clean tech.












2.6.


The aluminium sector has permanently lost a significant share of its European production capacity, with over 50 % of primary production at a standstill since 2021. Meanwhile, EU steel output has declined from 160 million tonnes in 2017 to 126 million tonnes in 2023. The current rate of steel capacity utilisation is approximately 65 %: this is unsustainable, as capital-intensive industries need to operate at above 85 % to remain competitive (4).












2.7.


Building on the Strategic Dialogue on Steel held with the European Commission President on 4 March 2025, the EESC supports the European Steel and Metals Action Plan (ESMAP) proposed by the Commission, but stresses that immediate action is required. For years, the Committee has been calling for dedicated support for the steel and metals sectors, and the EU cannot afford further delays. While the action plan is a step in the right direction, the Committee emphasises that time-specific legislative proposals are urgently needed (particularly on trade defence and energy prices), taking into account the current geopolitical situation. It urges the Commission to move beyond a medium and long-perspective and to take urgent action by immediately implementing measures to safeguard the sector’s future and address the economic and social crisis it faces.




3.   Ensuring access to clean and affordable energy for the metals industries









3.1.


The EESC acknowledges the Commission’s intention to lower energy costs for the hardest hit consumers, particularly energy-intensive industries, via measures set out in the Action Plan on Affordable Energy. It highlights that, while this action plan comprises positive measures to reduce costs related to network charges and levies, it mainly relies on national measures, market integration and storage and power purchase agreements, which are medium- and long-term measures.












3.2.


The EESC stresses that, without further measures, energy costs could hinder the competitiveness of the steel and metals industries in the short term, as such costs make up a large share of production costs. The EESC notes that, in 2025, energy prices remain higher than historical levels and are two to three times higher in the EU than in the USA (5), while natural gas prices are nearly five times those in the USA (6). Urgent short-term measures are therefore required to restore competitiveness and unlock investments in decarbonisation.












3.3.


The EESC urges the Commission to implement more robust measures for energy price relief as well as a clear framework for competitive industrial electricity. The EESC thus regrets that the Commission did not propose a section to address high energy costs in the recently published draft CISAF. Dependence on demand-side flexibility, subsidies or temporary tax relief is unsustainable in the long term. The Commission should therefore evaluate the current regulatory framework for electricity markets and conduct an in-depth impact assessment, including an evaluation of alternative market-design models, in order to better ensure affordable electricity prices for both households and industrial consumers, in line with the Clean Industrial Deal.












3.4.


The EESC also believes that it is essential for the CISAF to include a section with guidelines for the Member States on designing energy price relief measures for energy-intensive industries exposed to international trade. These should serve as temporary tools to enable affordable energy consumption in the short term.












3.5.


The upcoming Commission guidelines on PPAs and CfDs should make it possible for a predefined share of the subsidised electricity from PPAs to be supplied, at production costs plus mark-up, to specific energy-intensive industries exposed to international competition.












3.6.


Although the ESMAP proposes improved access to hydrogen for industrial users, the references to existing initiatives are insufficient to ensure an affordable and rapid scale-up of hydrogen for the steel and metals sectors. The EESC therefore calls for measures to support the off-take of hydrogen in energy-intensive sectors, in line with the prioritisation principle pursuant to Article 3(6) of the revised Hydrogen and Gas Decarbonisation Package, e.g. via sectoral budgets for energy-intensive industries in future Hydrogen Bank auctions. It also recommends revising the Delegated Act on Renewable Hydrogen to foster cost-effective, domestic production of renewable hydrogen, as well as swiftly adopting a delegated act on low-carbon hydrogen.




4.   Preventing carbon leakage









4.1.


The EESC agrees that loopholes identified by the Commission in the CID and the ESMAP could undermine the effectiveness of the CBAM in preventing carbon leakage and delivering on its environmental objectives. The Committee calls for a swift legislative proposal, under the CBAM review, to include specific measures to prevent carbon leakage on exports in the form of maintaining free allowances for exports for sectors covered by the CBAM to non-EU countries without comparable climate targets for their domestic steel industries, thus maximising the CBAM’s effectiveness. The proposal should also set appropriate default emissions values to ensure the environmental integrity of the CBAM, discourage resource shuffling practices and extend the scope of the CBAM, as set out in Annex I of the CBAM Regulation, to cover relevant downstream steel-intensive sectors, while safeguarding SMEs’ competitiveness by swiftly adopting the Omnibus I proposal.












4.2.


Given the recent policy developments and uncertainties regarding key strategic investments to produce low-carbon steel in Europe, the EU’s policy framework for tackling carbon leakage will have to be reassessed to provide certainty for companies considering investing in decarbonisation. If the mechanism proves even partially ineffective, the EESC advises the Commission to reconsider the phase-out trajectory for free allowances under the EU Emissions Trading System (ETS).




5.   Promoting and protecting European industrial capacities









5.1.


The spillover of global overcapacity threatens the viability of steel and metals production in the EU. The EESC stresses that the 25 % tariffs on imports from the US of steel and aluminium introduced on 12 March 2025 further exacerbate the ongoing crisis by restricting access to the EU market and increasing pressure from exports of global steel and metals diverted from the US to the EU. The EESC warns of serious consequences for the broader EU economy, including key downstream industries.












5.2.


The EU recently concluded a review of the existing steel safeguard. Although it recognises the work carried out by the Commission, the EESC regrets that the adjustments made do not effectively address either the challenges facing the EU steel sector, particularly the intense pressure on imports in segments such as stainless steel, or the failure to align quotas with the new market situation. The EESC also notes that the safeguard is set to expire on 1 July 2026.












5.3.


The EESC welcomes the Commission’s announcement on the implementation of a new trade measure to replace the current safeguard regime, providing a highly effective level of protection against the negative trade effects of global overcapacities. The effectiveness of the measure will depend on its design: it must be comprehensive, covering all steel products and all exporting countries where global excess capacity exists. Like the existing safeguard, the new measure should take the form of a tariff-rate quota to prevent added costs for steel users and prevent supply shortages, and should be calibrated by linking import market shares to sustainable levels of domestic capacity utilisation. The EESC urges the Commission to present the proposal without delay to prevent trade deflection following the USA’s blanket 25 % import tariff on steel and to ensure the new regime is fully operational well before the safeguard expires on 1 July 2026.












5.4.


The EESC welcomes the Commission’s announcement that it will consider launching a safeguard investigation on aluminium.












5.5.


The EESC agrees with the Commission that growing circumvention undermines trade defence measures, and stresses that introducing a ‘melted and poured’ rule, which would allow the Commission to identify the country of origin of a good as being where the metal was originally melted, regardless of the place of subsequent transformation, would effectively address circumvention and reduce the number of trade investigations. This measure can be implemented swiftly and is aligned with existing proof obligations under the Russia sanctions.












5.6.


The EESC stresses that lifting the ‘lesser duty’ rule would enhance the effectiveness of trade defence instruments in specific cases, particularly against Chinese exports. Suspending this rule would be a highly effective and WTO-compatible measure.




6.   Promoting circularity for metals









6.1.


The EESC acknowledges that circularity remains an important pathway for the decarbonisation of metals industries. Recycling scrap is instrumental in reducing dependency on imported primary raw materials, including strategic and critical raw materials. The EESC recommends directing investment towards enhancing and expanding EU recycling infrastructure, ensuring greater domestic processing of recycled metals to strengthen the circular economy within the EU.












6.2.


Producers in non-EU countries pay higher prices for scrap due to their lower environmental standards and lack of regulatory costs, leading to a decline in the availability of steel and metal scrap in the EU, while other countries such as China implement deliberate strategies to source aluminium scrap from the EU. The EESC regrets that ferrous scrap exports have more than doubled in recent years, while aluminium scrap exports are expected to exceed 1,3 million tonnes (7).












6.3.


The EESC therefore welcomes the recognition of metal scrap as a strategic secondary raw material in the ESMAP, due to its importance for the transition to a low-carbon, circular economy as well as for energy savings. In Q3 2025, the Commission should introduce a monitoring and surveillance system on scrap exports, implement exports restrictions in the form of an export duty or a tariff-quota system, tackle illegal exports and promote ferrous scrap recycling in relevant end-of-life products legislation (e.g. discarded vehicles, ships and vessels, and electric and electronic equipment).












6.4.


The EESC also calls for effective implementation of the Waste Shipment Regulation – through secondary legislation – to effectively assess and enforce standards and regulations that are environmentally and socially equivalent those of the EU in the countries of destination of the exported EU waste.












6.5.


The EESC was expecting more clarity on the Circular Economy Act scheduled for 2026, including detailed plans and timelines to ensure effective implementation and impact.




7.   Defending quality industrial jobs









7.1.


The EESC acknowledges ESMAP’s commitment to quality industrial jobs, characterised by decent pay, stable working conditions, and high health and safety standards. It supports the protection of workers’ rights, particularly regarding information, consultation, and participation – elements that are essential as the steel and base metals sectors undergo a profound green and digital transition.












7.2.


The EESC considers that no worker or region should be left behind in the green transition. It acknowledges the importance of retaining quality jobs, including for skilled technical workers. It recommends introducing a dedicated Just Transition Fund for energy-intensive industries, with a focus on up-skilling and reskilling programmes in order to equip workers with the skills needed for green industries and mobility support to help workers transition between regions and sectors.












7.3.


The EESC welcomes the proposal to amend the European Globalisation Fund to support job-to-job transitions in support of workers affected by industrial changes. The fund should serve as a proactive tool to retain workers through re- and up-skilling in anticipation of restructuring, rather than reacting only after layoffs have occurred.












7.4.


The EESC urges the Commission and the Member States to ensure that the social partners are involved in all future policy interventions and to make clear commitments to uphold robust social dialogue and maintain high standards of workplace health and safety throughout the green transition process. This will foster a just and equitable transition for all. The EESC also underlines the important role of social dialogue, 
including collective bargaining,
 in ensuring a just transition.




8.   De-risking decarbonisation projects through lead markets









8.1.


The use of fossil-free energy will result in higher operational costs and more expensive low-carbon products. The EESC stresses that it is essential to develop lead markets in order to provide a green premium and support investment in the steel and metals sectors. Swift and effective implementation of measures is now crucial.












8.2.


The EESC takes note of the Commission’s announcement that it is developing a voluntary label for low-carbon steel, as well as its intention to work on product-related legislation in order to establish lead markets. This includes initiatives such as the upcoming Industrial Decarbonisation Accelerator Act and the use of resilience and sustainability criteria to boost the production of EU-made clean products. The EESC also calls on CEN-CENELEC to develop a corresponding standard at a later stage.












8.3.


The Commission must expand the scope of the Critical Raw Materials Act to include strategic secondary raw materials such as steel scrap. While nickel and other alloying elements are recognised as critical, the action plan should also prioritise these secondary materials and introduce enhanced monitoring to ensure their sustainable availability and use in the green transition.












8.4.


The EESC stresses that funding will be necessary to de-risk large-scale industrial projects. It welcomes the Commission’s announcement in the CID that it will launch an Industrial Decarbonisation Bank, along with measures to improve the use of existing resources, particularly ETS revenues. The EESC highlights the need to earmark ETS revenues for industrial decarbonisation projects and calls for the immediate deployment of the EU Industrial Decarbonisation Bank, with targeted instruments for the steel and metals sectors.






Brussels, 18 September 2025.


The President


of the European Economic and Social Committee

Oliver RÖPKE
               





(1)  Omnibus I – COM(2025) 87.

(2)  
            OECD – 97th Session of the Steel Committee.

(3)  
            JRC Publications Repository – Raw materials in the European defence industry.

(4)  
            Eur-Lex Steel and Metals Action Plan.

(5)  
            Eur-Lex Steel and Metals Action Plan.


(6)  
            Affordable Energy Action Plan.

(7)  
            Steel and Metals Action Plan.



ELI: http://data.europa.eu/eli/C/2026/36/oj
ISSN 1977-091X (electronic edition)