Last-minute IAA change limits scope of ‘sliding scale’
The European Commission’s proposal for an Industrial Accelerator Act (IAA) has undergone last-minute amendments to text concerning the EU’s first green steel standard, as revealed upon official publication on 4 March, further supporting a non-harmonized implementation of the EU’s ‘voluntary low-carbon steel label’.
McCloskey has closely followed the drafting process for the IAA, as it represents one of the core pillars of the European Commission’s attempts to remedy European steelmaking competitiveness under its Steel and Metals Action Plan (SMAP), via demand-side measures to stimulate low-carbon lead markets.
In last year’s SMAP, the Commission committed to introducing the EU’s first ‘low-carbon voluntary label,’ initially covering steel products, as a means to standardise the definition of ‘green steel’ and give low-carbon consumers greater certainty on the quality of relevant emissions reductions. This label would then be referenced in public procurement and financial support schemes purchasing steels, under mandates to prioritise low-carbon, or domestic origin steels and stimulate green demand.
Negotiations to finalise provisions of the IAA have been fraught with disagreements as to the form and scope of the Commission’s proposed competitiveness remedies, primarily relating to the embedding of domestic “Made in EU”, and low-carbon content requirements into EU public procurement and financial support schemes. The specific formulation of the low-carbon label has also seen significant disagreement.
“Made in EU” content requirements are particularly contentious, supported by some member states, such as France and Italy (as described in a joint declaration of French and Italian industrial ministries on 3 March), but opposed by others like Germany and Scandinavia, who prefer a “Made with EU” approach that would extend requisite European origin status to the EU’s like-minded trading partners.
As of official publication of the IAA, on 4 March, the steel sector is referenced only in terms of mandates to include a minimum share of 25% for “low-carbon” steel products in public procurement and support schemes, without its own Union-origin requirements. The European Commission state that domestic content criteria is not necessary for the steel sector due to the long-term revision of the EU’s steel safeguard quotas, expected for July. The ‘low-carbon label’ is gone entirely.
Voluntary low carbon label and ‘sliding scale’
Independent of authorities, the European steelmaking lobby has itself been arguing about the form and scope of the EU’s first low-carbon steel label, as of yet unable to reach a compromise as to the means of defining green steel; namely whether or not to include a ‘sliding scale’ mechanism as a decarbonisation incentive for integrated blast-furnace producers.
Sliding scale mechanisms generally operate on a classification model (e.g A-E, with A as the least-polluting) facilitating a ‘greener’ classification the lower a steel product’s constituent share of steel scrap. This is intended not only to recognise that global supplies of quality steel scrap are insufficient to support the the entire transition of the world’s steelmaking to scrap-based electrified production, requiring alternative inputs like green direct-reduced iron (DRI); but also to allow primary producers to participate in low-carbon markets to finance the high investment costs of decarbonising their processes.
In principle, sliding scales make a lot of sense and can even be argued as necessary for a realistic low-carbon transition in the steelmaking sector, however, the proposed implementation of such a mechanism could present too high a burden for the EU’s existing secondary steelmakers.
DRI-EAF steelmaking is widely considered the most realistic path to green steelmaking worldwide, but if anything, the EU is behind the curve on DRI-EAF development, particularly in the MENA region, as illustrated in McCloskey’s Global Green Steel Profile.
A clear definition for low-carbon steel is thus viewed by many as necessary to lay secure foundations for the EU’s low-carbon transition, and some fear current efforts could fall short, as argued by Andrew Forth, Head of Policy and Advocacy at Climate Group:
“The EU’s Industrial Accelerator Act sets out a framework for classifying steel by emissions intensity, and we welcome the recognition that a labelling scheme is needed. But the detail matters enormously. A voluntary classification system will not provide the certainty that producers and buyers need to make the investment decisions that actually cut emissions at scale. We need a mandatory, harmonised EU definition of low-carbon steel – established without delay – so that public procurement and private investment reward cleaner production. Without it, Europe risks confusion, stalled investment and losing ground to competitors.”
‘Sliding scale’ – Secondary Steelmaker Resistance
Initial formulations of the low-carbon label under the IAA would have extended the sliding scale universally across all steel products, which combined with the possibility of international producers receiving certification and thus access to EU public procurement, was too big a threat for EAF steelmakers to accept. International DRI-EAF steels would benefit both from their competitive emissions profile, and lower scrap content, potentially obtaining a cleaner classification than fully recycled domestic products via the sliding scale. The EU’s secondary steelmakers predominantly service the construction sector, which is also already subject to sustainability requirements via the Construction Products Regulation (CPR).
These steelmakers were thus unwilling to accept the sliding scale in any capacity, though particularly in the absence of strict “Made in EU” content requirements, which could compound in threats to their existing construction sector market share both from domestic integrated producers, and international DRI-EAF exporters.
Germany, a supporter of the sliding scale due to its relative share of integrated primary steelmaking, is heavily resistant to the stricter definition of “Made in EU” – whereas countries like France and Italy have argued for the inclusion of domestic content requirements.
In their aforementioned joint declaration, France and Italy express support for lead market generating procurement mandates to support the steel sector, but explicitly oppose any implementation of the sliding scale (referred to in terms of the EU’s leading sliding scale certification, the Low Emissions Steel Standard (LESS), a project initially started of the German Steel Association, WV Stahl).
“We support incentives for European green steel through sectoral quotas, while opposing a use of the LESS label that is harmful to European industry, and we call for “Made in EU” requirements for steel products used in construction through public procurement and public support schemes.”
Low-carbon label – current status
It seems this direct resistance to the sliding scale, and wider frictions surrounding “Made in EU” requirements, may have had an impact on the IAA’s final iteration.
McCloskey has tracked the ‘low carbon steel label’ as it has gradually transformed though leaked IAA drafts, from a universal classification across steel product groups informed by the sliding scale, to legislative non-existence. The label previously existed under Chapter VII of earlier versions of the IAA, but was completely cut late last week, with standardisation efforts now to be pursued under the steel-related delegated acts of the ESPR later this year.
Leaked IAA drafts seen by McCloskey on Monday 2 March, just days before official presentation, still contained references to a universal application of the sliding scale across steel products for future ESPR implementation, but have since been amended a final time in the wake of Member State and downstream sector resistance.
The explanatory recitals of the latest draft stated: “[product labelling requirements] should be based on classes of performance that acknowledge the different decarbonisation effort of the technologies routes, also rewarding circularity, adjusting emission intensity thresholds based on percentage of scrap metal used in production, as necessary.”
Whereas the officially published text now appears to constrain the scope of future efforts (emphasis added): “[…] adjusting emission intensity thresholds based on percentage of scrap metal used in production for those product categories that typically require primary steel production, as necessary.”
This would suggest that Commission intentions are now non supportive of a sliding scale-based label implemented universally across the steel sector, instead to be constrained to products produced via primary steelmaking.
Indeed, sources close to both the IAA drafting process, and consultations on the low-carbon label suggest that a compromise was potentially visible before the label was cut from the IAA, which would limit the scope of the sliding scale only to those steel product segments that require a decarbonisation incentive – such as flat steel products – leaving EAF-produced long steel products, destined for the construction sector, under the existing remit of the CPR.
New leaked IIA draft softens ‘Made in EU’ rules, opens door to import steel in public procurement
The latest leaked draft of the EU’s Industrial Accelerator Act (IIA) introduces a significant shift in its “Made in EU” procurement rules, allowing selected third countries to be treated as equivalent to EU producers in public purchasing for strategic industrial goods – including steel, Fastmarkets learned on Thursday February 12.
The change will mark a notable softening of earlier proposals outlined in the first IIA leaked draft and was widely seen as reflecting concerns among some EU member states about excessively rigid Union-origin requirements that could disrupt supply chains and create trade tensions.
The revised text retains the definition of “Union origin” as covering EU and European Economic Aewa (EEA) production but adds a mechanism allowing the European Commission to designate specific third countries as equivalent through delegated acts.
To qualify, countries must demonstrate reciprocal international commitments with the EU and contribute to the Union’s competitiveness, resilience and economic security objectives, according to the draft document seen by Fastmarkets.
The Commission would also be able to revoke this status in the event of serious breaches.
The provision applies to energy-intensive industrial products and net-zero manufacturing technologies listed in Annex II, which has yet to be published but was expected to include steel.
The addition of third-country equivalence underscores the major change, which is that the IIA is no longer framed purely as a “Made in EU” decarbonization tool, Fastmarkets understands.
The IIA draft was still subject to change ahead of being formally adopted, with a final version expected to be published on February 25.
Implications for steel market
The earlier draft leaned toward mandatory combinations of Union-origin and low-carbon production requirements in public procurement and state aid plans, effectively favoring domestically produced low-emissions steel.
The new draft was less prescriptive, allowing member states to apply either Union-origin criteria, or low-carbon criteria, or both.
For steel, this reduces the risk of a rigid “double requirement” system that industry sources had warned could disrupt supply.
“South Korean or Japanese plate is used for wind industry projects in the EUt,” a buyer source in the EU said. “Both countries can supply steel produced with reduced carbon emissions content, so this ‘third country’ addition is an important amendment.”
According to sources familiar with the matter, Germany had pushed back against strict origin rules, citing the integration of EU steelmaking with global raw materials and automotive supply chains. The trusted partner mechanism appeared to reflect that pressure.
At the same time, the draft maintained plans for a carbon intensity label for steel, intended to differentiate low-carbon production – a key objective for EU mills investing in electric-arc furnaces (EAFs) and hydrogen-based direct-reduced iron (DRI) modules.
The practical effect will depend on the still-unpublished annexes defining which steel products will be covered, the origin thresholds and the carbon emissions intensity methodology, Fastmarkets understands.
Steel industry stakeholders agreed that IIA had the potential to “unlock” green steel demand through public procurement.
The shortage of public infrastructure projects in Europe that are capable of mandating green steel procurement has been deemed a significant obstacle to stimulating demand for low-carbon steel, Fastmarkets heard.
“If authorities do not push for green steel use through public procurement, then [green steel] will remain a niche market,” a mill source said.
“The effect of energy prices and also the cost of steel within the green transformation [are among] the key issues,” the distributor source said. “The distribution of green steel will be working… if we make green steel, put a label on it and make it part of public procurement.”
Reflecting the muted trading environment, Fastmarkets’ weekly assessment of the green steel, domestic, flat-rolled, differential to HRC index, exw Northern Europe, remained at €100-150 *$119-178) per tonne on February 12.

