Ecodesign rules for steel: how the EU will define ‘low-carbon steel’

The Ecodesign for Sustainable Products Regulation (ESPR), Regulation (EU) 2024/1781, lets the Commission set sustainability requirements for almost any physical product. One of its first product rules, and the first for an intermediate product, concerns iron and steel. The Commission has indicated that it will adopt the delegated act in the fourth quarter of 2026. Beyond ecodesign, the act matters because other EU files depend on it: the Industrial Accelerator Act would use it to decide which steel counts as ‘low-carbon’ in public procurement, and the planned car CO₂ rules would use the same methodology for steel credits. Steel producers, stockists and every manufacturer that buys steel have a stake in how the thresholds are drawn.

ESPR in brief

The ESPR entered into force on 18 July 2024 and replaces the Ecodesign Directive. It is a framework: the regulation itself sets few obligations, and the Commission adds product-specific requirements through delegated acts. These can be performance requirements, such as minimum recycled content or maximum carbon footprint, or information requirements, which can include classes of performance shown on a label or in a digital product passport. Each act requires an impact assessment and consultation of the Ecodesign Forum, which includes experts designated by the Member States.

The working plan of 16 April 2025 sets the priorities:

Some parts of the regulation already apply. Since 19 July 2026, large companies may no longer destroy unsold apparel, clothing accessories and footwear, subject to derogations the Commission adopted on 9 February 2026; medium-sized companies follow in 2030, and micro and small companies are exempt. On 16 July 2026, the Commission adopted Implementing Regulation (EU) 2026/1778 on the registry for digital product passports, in force since 6 August 2026.

What the steel act is expected to contain

The Commission’s call for evidence and public consultation ran until 12 August 2026 and drew 84 and 142 responses respectively. The call for evidence describes a market where steel’s carbon footprint is poorly accounted for, demand for low-carbon steel is limited and competing definitions fragment the market. The options include:

• mandatory information on carbon footprint, recycled content and substances that hinder recycling;
• performance classes and minimum thresholds based on carbon footprint data;
• digital product passport requirements for all actors in the supply chain.

Preparatory work by the Commission’s Joint Research Centre (JRC) covers five representative intermediate products: hot rolled coil, wire rod, galvanised cold rolled coil, electrical steel and stainless steel. According to an analysis by Adherent, the draft JRC reports focus on recycled content, substances of concern and carbon footprint. The passport would contain the heat number, the country of origin and where the steel was melted and poured, the chemical composition from mill test certificates, recycled content split into pre-consumer and post-consumer scrap, and a carbon footprint aligned with ETS and CBAM reporting and compatible with environmental product declarations for construction (EN 15804).

Why the definition matters beyond ecodesign

• Public procurement. The Industrial Accelerator Act (COM(2026) 100) would require at least 25% low-carbon steel in public procurement from 1 January 2029. Steel in construction would follow the Construction Products Regulation; other steel would count as low-carbon if it meets the conditions ‘to be set out in the delegated acts under the ESPR’. The proposal provides for performance classes for steel that are adjusted for scrap content, using EU ETS benchmarks and CBAM-verified data where available.
• Car CO₂ standards. The Commission’s proposal to revise the car CO₂ rules would let carmakers cover up to 7 percentage points of their 2035 target with low-carbon steel made in the EU. According to Transport & Environment, the definition will be set in secondary legislation drawing on the ESPR methodology for iron and steel. The compromise adopted by Parliament’s industry and transport committees on 22 October raises the steel credit to 7.5 points.
• Public support. The Industrial Accelerator Act would also attach low-carbon conditions to state support for energy-intensive industry.

Whoever falls into the better classes will have easier access to these lead markets. That is why the methodology has become a political file.

Fixed thresholds or a sliding scale

The JRC approach is technology-neutral and cradle-to-gate, with fixed thresholds for all production routes. In a joint statement of 15 June 2026, recyclers backed that approach, which in their view recognises the decarbonisation potential of scrap, but called the proposed classes ‘too conservative’: they want only the 10% best-performing products in the top two classes and a cut-off at 400 kg CO₂e per tonne of crude steel.

A coalition initiated by LESS, a low-emission steel label, argued on 12 May 2026 that the proposed thresholds do not reward investment in cleaner routes, for instance a switch from gas-based to hydrogen-based direct reduction. It wants a sliding scale based on CO₂ intensity and recycled content. The Industrial Accelerator Act takes a middle road: its sliding scale is limited to product categories that typically require primary steel, mainly flat products.

Downstream manufacturers raise a different concern. Orgalim, representing Europe’s technology industries, asked on 3 July 2026 to limit the act strictly to intermediate steel products. It notes that machinery can contain up to 90% steel, and that downstream manufacturers ‘cannot be held responsible for data that they do not control’. Belgian wire producer Bekaert, quoted in the paper, supports a simple passport for intermediate products only.

Where the file stands (28 October 2026)

• Steel delegated act. The call for evidence and public consultation closed on 12 August. The Commission’s planning lists adoption of the delegated regulation in the fourth quarter of 2026. As of early October, no draft had been published for feedback; that step and the consultation of the Ecodesign Forum normally come before adoption. Parliament and Council can then object before the act enters into force.
• Application. As a rule, requirements apply no earlier than 18 months after a delegated act enters into force. The Industrial Accelerator Act’s procurement rules would apply from 1 January 2029.
• Linked files. Parliament’s committees aim to vote on the Industrial Accelerator Act on 1 December; the Council aims for its mandate in November. On car CO₂ standards, Parliament’s environment committee votes in early November, with a plenary vote expected in December.
• Next ESPR acts. Aluminium, textiles and tyres are planned for 2027. For batteries, the first product passport in EU law applies from 18 February 2027 under the Batteries Regulation.

What it means in Belgium

• Producers and processors. Belgian steel producers already report emissions under the EU ETS, through VEKA in Flanders and AWAC in Wallonia. The proposed carbon footprint would build on ETS and CBAM data, but at product level and per tonne of steel sold.
• Public buyers. Under the Industrial Accelerator Act, federal, regional and local contracting authorities would have to apply the 25% low-carbon steel requirement. The ESPR classes would tell them what qualifies.
• Regional support. Support schemes for industrial decarbonisation are largely regional. If they carry low-carbon conditions, Flanders, Wallonia and Brussels would rely on the same definition.
• Downstream industry. Machinery, metalworking, electrical and automotive suppliers would receive steel data through the passport and, depending on the final scope, might have to pass it on.
• Unsold textiles. Since 19 July 2026, the destruction ban also applies to large apparel and footwear sellers in Belgium; national authorities oversee compliance.

What to do now

1. Map your steel exposure. Identify whether you produce, stock, process or buy steel, and for which markets: public works, vehicles, machinery or construction products. Each position is affected differently.
2. Put your carbon data in order. Product-level footprints, recycled content split into pre-consumer and post-consumer scrap, and heat-number traceability will be the basis of the classes. Align them with your ETS, CBAM and EPD data now.
3. Test both threshold designs. Model where your products would land under fixed thresholds and under a scrap-adjusted sliding scale. The answer tells you which design to support.
4. Prepare for the passport. Check which data your mill test certificates already carry, which systems would feed a passport and who in your chain controls the data.
5. Engage before the draft is final. The feedback period, the Ecodesign Forum and the scrutiny by Parliament and Council are the remaining windows. Keep the Industrial Accelerator Act and the car CO₂ file in view, since the same definition will decide access to both. In Belgium, that means both the federal level and the regions.

Sources

1. EUR-Lex, Regulation (EU) 2024/1781 establishing a framework for the setting of ecodesign requirements for sustainable products, 13 June 2024 (Articles 1 and 2; recitals 22, 28–29, 56–58).
2. Stibbe, The Ecodesign Regulation: new sustainability obligations for manufacturers, 27 September 2024.
3. European Commission, 2025–2030 working plan (Green Forum), and Sidley, European Commission releases list of priority products, 29 April 2025.
4. European Commission, New EU rules to stop destruction of unsold clothes and shoes, 9 February 2026.
5. EUR-Lex, Commission Implementing Regulation (EU) 2026/1778 on implementation arrangements for the digital product passport registry, 16 July 2026.
6. European Commission, Proposal COM(2026) 100 for an Industrial Accelerator Act, 4 March 2026 (explanatory memorandum; recitals 21–22).
7. European Commission, Have your say: Ecodesign requirements for iron and steel products, initiative 17672, consulted 28 October 2026; CDX, ESPR delegated act on iron and steel: Commission opens stakeholder consultation, May 2026 (on call for evidence Ares(2026)5076198).
8. Adherent, Early signals from the EU’s preparatory work for future ESPR delegated acts on electronics, textiles and iron & steel, 29 June 2026.
9. Recycling Europe and co-signatories, Joint statement: an ambitious green steel definition under ESPR, 15 June 2026.
10. LESS and supporting organisations, Public statement: a credible and operable framework for low-carbon steel, 12 May 2026.
11. Orgalim, Iron and steel products under the Ecodesign for Sustainable Products Regulation, position paper, 3 July 2026.
12. EUROMETAL, EU Industrial Accelerator Act drops EU-origin steel rule, narrows emissions sliding scale to primary steel, 5 March 2026 (reporting Fastmarkets).
13. Transport & Environment, Low-carbon steel credits in the EU cars CO₂ standards, position paper, 2026.
14. electrive, EU Auto Package: committee votes to relax CO₂ rules, 23 October 2026.
15. DPP Atlas, EU Digital Product Passport rules: October 2026 update, October 2026.

This analysis reflects the state of the file on 28 October 2026. We update it when the file moves.