Statement on EU Taxonomy: Review of Climate and Environmental Delegated Acts
05 December 2025 | The German Steel Association (Wirtschaftsvereinigung Stahl) welcomes the EU Commission’s initiative to revise the Delegated Acts of the EU Taxonomy. As a sector undergoing a profound transition towards climate-neutral production while facing global overcapacity, high investment needs and increasing regulatory pressure, a clear, workable and proportionate Taxonomy framework is essential. The current DNSH (Do not significant Harm) requirements and several technical screening criteria create significant administrative burdens without improving environmental integrity, especially regarding the already drastically increasing permit requirements with the revised Industrial Emission Directive (IED). Better alignment with existing EU legislation and clearer evidence pathways are crucial to ensure that the Taxonomy supports – rather than slowing it down – industrial transformation. A streamlined, coherent and predictable EU Taxonomy will enable major green investments, strengthen the competitiveness of European steel producers and support EU climate objectives. The industry stands ready to contribute constructively to the further refinement of the Delegated Acts.
Our demands at a glance:
- Streamlined DNSH compliance through recognition of established regulatory frameworks: For the steel sector, comprehensive EU legislation (e.g., REACH, IED, sector-specific product regulations) should be accepted as sufficient evidence of DNSH conformity. This avoids regulatory duplication, reduces unnecessary administrative burden, and provides legal certainty for both EU-based production and imported materials.
- Regulatory stability and adequate transition periods: Decarbonisation investments in the steel sector are long-term and capital-intensive. Frequent changes to the Taxonomy criteria undermine investment certainly. Sufficient transition periods are essential.
- Technology neutrality and recognition of all viable decarbonisation routes: The steel industry pursues several scientifically and technically robust pathways towards climate neutrality (hydrogen-based direct reduction, electric arc furnaces, hybrid routes). Therefore, taxonomy must remain technological-neutral and reflect these diverse transition paths.
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