Statement on the Consultation on the Review of the EU Taxonomy Delegated Acts
14 April 2026 | The proposed amendments to the EU Taxonomy Delegated Acts to Regulation (EU) 2021/2139 (Climate Delegated Act) and Delegated Regulation (EU) 2023/2486 (Environmental Delegated Act) represent a pragmatic and necessary step to improve the usability, clarity and practical applicability of the framework and are supported by the steel industry in Germany.
The proposal appropriately responds to stakeholder feedback regarding complexity, legal uncertainty and implementation challenges, especially in relation to DNSH criteria, chemicals requirements and the demonstration of compliance.
It is particularly important that the amendments remain targeted in nature, focusing on clarification and alignment with existing EU legislation, without altering the underlying policy framework.
The explicit maintenance of existing technical screening thresholds for steel production under Delegated Regulation (EU) 2021/2139 is therefore strongly welcomed. Preserving these thresholds is essential to ensure regulatory stability and investment certainty, particularly in a context where the transition to low-emission steel requires high upfront capital expenditure, long investment cycles and significant technological and market risks.
Against this background, the following elements are particularly relevant to ensure the effective and practical implementation of the Taxonomy:
- Preserve existing thresholds to ensure investment certainty (EU) 2021/2139:
The maintenance of current thresholds for steel production is critical to safeguard ongoing investments in low-emission steel and to ensure a stable framework for industrial transformation. - Strong support for targeted improvements in (EU) 2023/2486, Annex C:
The proposal represents a clear and pragmatic improvement, notably by enhancing clarity, reducing interpretative grey areas and strengthening alignment with existing EU legislation, especially in the areas of chemicals and biodiversity. - Alignment with existing EU legislation must be maintained:
The systematic reference to existing EU regulatory frameworks (e.g. REACH, RoHS, IED) is a major strength of the proposal and should be consistently pursued to avoid duplication and unnecessary administrative burden. - Ensure legal certainty and a level playing field by addressing remaining ambiguities:
Targeted refinements are necessary, regarding Annex C (points 7 and 8), to ensure consistent implementation across Member States and avoid unintended distortions. - Reflect the full sustainability contribution of steel:
The Taxonomy should more explicitly reflect the core sustainability advantages of steel, in particular durability, high recyclability and reparability, and acknowledge the critical role of low-emission steel as an enabler of climate-neutral value chains.
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