Position Paper: Chemical Policy Guidelines for a Sustainable Steel Sector
20 November 2025 | With its „Chemicals Industry Action Plan“, the European Commission is pursuing the goal of strengthening the competitiveness, sustainability and innovative strength of the industry. Central to this are the planned amendment to the REACH Regulation, which are also crucial for the steel industry. This requires practical, risk-based and differentiated regulation, but not necessarily a complete revision.
In particular, a sense of proportion is required when dealing with tramp elements from secondary raw materials so that recycling streams are not jeopardized. The steel industry warns against generic classifications of metallic substances as „endangering production safety, recycling and investment“. Science-based regulation must distinguish between hazardous substances, such as the heavy metal nickel, on the one hand, and the safe use of e.g. firmly bound metals in a steel matrix, such as nickel in stainless steel, on the other. The concept of „essential use“ must also not lead to general bans on substances. Instead, the risk-based approach must be continued.
In addition, the amendment to the REACH Regulation must achieve a level playing field between EU production and imports, more transparency and participation of industry in decision-making processes. REACH authorization and restriction procedures need to be reformed and reduced in bureaucracy to ensure certainty for industry in its planning.
We advocate a chemicals policy agenda that reliably protects, is proportionate and secures the location – as the basis for a sustainable industrial and environmental policy in a resilient Europe.
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