Statement on the Draft Implementing Regulation for Minimum Requirements on Environmental Sustainability in Public Procurement (NZIA-Implementing Act)
14 October 2025 | The European steel industry fully supports the Net-Zero Industry Act (NZIA) as a key driver for accelerating clean technology deployment. Steel is an essential material for the EU economy as well as a strategic industrial and net-zero enabling material, indispensable for EU climate neutrality and serving as a core input for solar, wind, hydrogen and grid infrastructure. Steel is also of strategic importance for increasing the Union’s defense and military capabilities. Public procurement must therefore go beyond recyclability and expressly recognize European-produced low-emission steel manufactured under stringent climate standards as an essential enabler to strengthen industrial resilience and strategic autonomy.
For simplicity and easier implementation, in the wind energy sector, for example, sustainability criteria should apply to both blades and at least steel-intensive towers, with emissions performance certified through harmonized frameworks such as the Low Emission Steel Standard (LESS) and digital product passports, as steel accounts for up to 83 per cent of total product emissions.
Lead markets are a crucial tool to drive demand for low-emission steel while safeguarding European industrial capacity, jobs, and strategic autonomy. By combining environmental and European content criteria, public procurement can stimulate investment in decarbonization technologies, de-risk large-scale projects, and create long-term demand signals for EU-made clean steel. The wind sector illustrates the potential: using low-emission steel in a 15 MW offshore turbine increases CAPEX by less than 2 per cent and electricity costs by ~1 per cent, demonstrating that industrial decarbonization is economically feasible.
By linking lead markets such as wind energy with targeted political instruments – including public procurement criteria, classification standards like LESS, and digital product traceability through DPPs – the NZIA can ensure that low-emission steel produced in Europe is not only available, but also actively demanded and deployed.
In doing so, steel becomes more than a material input – it becomes a cornerstone of Europe’s industrial competitiveness and climate leadership.
To translate this strategic vision into concrete action, several key enablers must be addressed. The following sections outline the main levels for achieving these objectives by:
- Supporting lead markets,
- using the Net-Zero Industry Act to increase demand,
- and establishing credible labelling mechanisms.
All these objectives can position low emission steel as a competitive advantage for Europe’s industry and a cornerstone of its climate transition.
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