Use this report
Start with your decision, not the sector slogan
Producer / project owner
- Evidence now
- Route, asset age, product mix, emissions boundary and input contracts.
- Monitor
- Reline or retirement date; power, hydrogen, pellet and scrap delivery; FID and offtake.
- Stop condition
- Do not treat policy support or an aid decision as a viable operating case.
EU importer / declarant
- Evidence now
- Goods code, origin, installation, route, precursor and verified emissions records.
- Monitor
- Current scope and defaults; free-allocation adjustment; proposal milestones.
- Stop condition
- Do not replace goods evidence with country averages from this report.
Non-EU mill / exporter
- Evidence now
- Production boundary, route, precursor chain and verification-ready calculation records.
- Monitor
- EU methodology changes and buyer evidence requirements.
- Stop condition
- Do not infer market access or a certificate advantage from a route label.
Downstream manufacturer
- Evidence now
- Steel inputs, origins, quantities, suppliers and contract change clauses.
- Monitor
- Downstream-CBAM procedure and demand-side product rules.
- Stop condition
- Do not treat proposed downstream coverage as current law.
Procurement / finance
- Evidence now
- Project state, input assumptions, financing, commissioning and contracted offtake.
- Monitor
- Execution milestones rather than announcement counts.
- Stop condition
- Do not turn CAPEX headlines into delivered output or returns.
Adviser / policy researcher
- Evidence now
- Document identity, date, status, unit, denominator and scenario contract.
- Monitor
- Procedure milestones and new JRC, OECD, worldsteel and EUROFER vintages.
- Stop condition
- Do not blend law, proposals, advocacy and pathways into one prediction.
Executive answer
CBAM changes the commercial equation; it does not solve the physical transition
Europe's steel future will be decided where five clocks meet: ageing blast furnaces, declining operating output, the EU ETS and CBAM transition, the delivery of electricity and low-carbon hydrogen, and a global market carrying large excess capacity. CBAM can change the relative carbon treatment of covered imports. It cannot by itself build grids, produce suitable scrap, supply direct-reduction pellets, finance a mill conversion or create buyers willing to sign long-term offtake.
125.792 Mt
EU crude-steel output in EUROFER's 2025 country tableC-011
64.8%
EU operating-capacity utilisation in 2025C-015
54.2 / 45.8
2025 BOF-and-other / EAF output sharesC-016
165 TWh/yr
conditional fossil-free power pathway for all announced projectsC-038
11.511 Mt
EU net scrap exports in 2025C-027
640 → 745 Mt
OECD 2025 estimate → 2028 excess-capacity projectionC-040
50 years
average age of the EU blast-furnace fleet in the JRC synthesisC-018
Proposal
downstream CBAM remained proposal—not law at the cut-offC-005
The strongest conclusion is therefore conditional: European steel can decarbonise through more than one route, but each route has a different binding input and delivery test. The useful question is not “Will CBAM save steel?” It is “Which evidence would prove that one asset, product and supply chain has a viable transition case?”
Canonical boundary
What this flagship owns—and what it deliberately links out
This report owns the steel-sector transition map: production structure, routes, asset timing, country differences, input constraints, trade pressure, project delivery states and the monitoring decisions those facts create. It does not duplicate the site's existing canonical answers.
| Question | Canonical owner | Treatment here |
|---|---|---|
| Which steel CN codes are covered? | Iron and steel sector | Compact boundary and link; no copied code list. |
| What did transitional Registry data show? | CBAM by the Numbers | No repeated origin/emissions dashboard. |
| What is CBAM's dated overall state? | State of CBAM 2026 | Only steel-specific status needed for the route decision. |
| What do macro models say about Europe? | Economic impact report | No repeated GDP, welfare or aggregate model table. |
| Who ultimately pays? | Who Pays for CBAM? | No copied incidence or pass-through framework. |
| How does the CBAM factor phase in? | Free-allocation phase-in guide | Strategic interaction only; no factor schedule. |
| What should a fastener buyer do? | Steel-fastener buyer guide | One downstream example; no duplicate buyer article. |
For a product decision, use the CBAM goods checker. This article is a sector map, not a customs-classification ruling.C-001C-002
Part 1
Europe enters the transition with lower output and low utilisation
EUROFER's operating-capacity series falls from 236 Mt in 2008 to 194 Mt in 2025. Its utilisation series moves from 78.4% to 64.8% across the same endpoints, with large cyclical breaks in between. These are industry-reported operating measures, not a universal test of mill viability. But together they show why a capital-heavy route conversion cannot be analysed as a technology exercise alone: the investment case starts inside an already under-used production system.C-014C-015
Figure 1 · 2008–2025
Europe is using less of a smaller operating base
How have EU steelmaking capacity and utilisation changed since 2008?
78.4%
55.5%
69.1%
72.1%
69.4%
68.6%
70.1%
69.6%
69.5%
73.5%
73.1%
69.6%
62.1%
71.7%
64.0%
60.1%
65.4%
64.8%
Accessible table: all 18 annual values
| Year | Operating capacity, Mt | Utilisation |
|---|---|---|
| 2008 | 236 | 78.4% |
| 2009 | 233 | 55.5% |
| 2010 | 236 | 69.1% |
| 2011 | 233 | 72.1% |
| 2012 | 229 | 69.4% |
| 2013 | 225 | 68.6% |
| 2014 | 224 | 70.1% |
| 2015 | 223 | 69.6% |
| 2016 | 222 | 69.5% |
| 2017 | 219 | 73.5% |
| 2018 | 219 | 73.1% |
| 2019 | 216 | 69.6% |
| 2020 | 213 | 62.1% |
| 2021 | 213 | 71.7% |
| 2022 | 213 | 64.0% |
| 2023 | 210 | 60.1% |
| 2024 | 198 | 65.4% |
| 2025 | 194 | 64.8% |
Population: EU operating crude-steel capacity reported by EUROFER
Unit: million metric tonnes and percent; capacity integer Mt; utilisation one decimal.
Limitation: Industry-reported operating capacity is not the same as nominal, installed or technically available capacity.
Do not infer: Do not infer plant profitability, closure probability or future output from utilisation alone.
The decline is not one smooth structural line. Utilisation fell to 55.5% in 2009, recovered above 70% in several years, fell to 62.1% in 2020 and reached 60.1% in 2023. A single endpoint cannot tell whether demand, outages, imports, energy prices or plant decisions caused the movement. It can tell a strategy team which evidence must be added before approving a route narrative.
Part 2
The EU production atlas is concentrated—and incompletely disclosed
Germany's 34.090 Mt represented 27.1% of the 2025 EU country-table total. Italy contributed 20.733 Mt, Spain 11.778 Mt and France 9.916 Mt. The table then extends through every printed country row, not a hand-picked top five. That matters because the asset, electricity, scrap and product mix behind one tonne in Germany is not the same as one tonne in Italy, Sweden or Luxembourg.C-012
Figure 2 · 2021–2025
The complete disclosed EU production population
Which disclosed EU country rows produced the 2025 crude-steel total?
EUROFER prints 19 named country rows plus Others. Croatia and Hungary show dashes for 2025. Seven EU members are therefore not individually disclosed; this figure does not replace those missing values with zero.
Accessible table: 2021–2025 values and 2025 shares
| Country row | 2021, kt | 2022, kt | 2023, kt | 2024, kt | 2025, kt | 2025 share |
|---|---|---|---|---|---|---|
| Austria | 7,884 | 7,512 | 7,133 | 7,130 | 7,553 | 6.0% |
| Belgium | 6,909 | 7,030 | 5,864 | 7,135 | 7,048 | 5.6% |
| Bulgaria | 548 | 482 | 489 | 450 | 466 | 0.4% |
| Croatia | 185 | 169 | 212 | 153 | — | 0.0% |
| Czech Republic | 4,788 | 4,262 | 3,369 | 2,548 | 2,503 | 2.0% |
| Finland | 4,340 | 3,538 | 3,811 | 3,664 | 3,742 | 3.0% |
| France | 13,947 | 12,234 | 10,011 | 10,753 | 9,916 | 7.9% |
| Germany | 40,241 | 36,860 | 35,395 | 37,234 | 34,090 | 27.1% |
| Greece | 1,498 | 1,543 | 1,181 | 1,336 | 1,342 | 1.1% |
| Hungary | 1,100 | 857 | 477 | 232 | — | 0.0% |
| Italy | 24,412 | 21,599 | 21,055 | 20,007 | 20,733 | 16.5% |
| Luxembourg | 2,073 | 1,875 | 1,900 | 1,825 | 1,822 | 1.4% |
| Netherlands | 6,620 | 6,143 | 4,677 | 6,395 | 6,483 | 5.2% |
| Others | 1,953 | 1,855 | 2,040 | 1,948 | 2,090 | 1.7% |
| Poland | 8,454 | 7,407 | 6,428 | 7,113 | 7,186 | 5.7% |
| Romania | 3,375 | 2,625 | 1,622 | 1,364 | 850 | 0.7% |
| Slovakia | 4,863 | 3,872 | 4,377 | 3,866 | 3,612 | 2.9% |
| Slovenia | 701 | 623 | 559 | 598 | 602 | 0.5% |
| Spain | 14,234 | 11,464 | 11,352 | 11,832 | 11,778 | 9.4% |
| Sweden | 4,657 | 4,382 | 4,235 | 4,002 | 3,976 | 3.2% |
| EU27 printed total | 152,782 | 136,332 | 126,186 | 129,586 | 125,792 | 100% |
The complete printed rows sum 1 kt above the printed EU27 total in 2023 and 1 kt below it in 2024. The source's rounded rows and printed totals are retained separately.
Population: 19 named country rows plus the source-defined Others aggregate
Unit: thousand metric tonnes; nearest thousand tonnes; source dashes retained.
Limitation: EUROFER does not individually disclose every EU member; Others must not be decomposed or mapped to zeroes.
Do not infer: Do not rank undisclosed countries or equate a dash with verified zero production.
Country coverage also needs an honest missing-data rule. EUROFER prints 19 named rows and an Others aggregate. Croatia and Hungary display dashes in 2025. This report therefore covers the full published population while refusing to invent seven individual country figures. The atlas is a reference table, not a transition ranking.C-013
Figure 4 · 2025 with 2024 comparator
Every published 2025 producer row
How much crude steel did every published producer row make in 2025?
Accessible table: all 50 countries plus Others
| Published row | 2025, Mt | 2024, Mt | Status |
|---|---|---|---|
| China | 960.8 | 1,005.1 | Reported |
| India | 164.9 | 149.4 | Reported |
| United States | 81.9 | 79.5 | Reported |
| Japan | 80.7 | 84.0 | Reported |
| Russia | 67.9 | 71.0 | Reported |
| South Korea | 62.2 | 63.6 | Reported |
| Türkiye | 38.1 | 36.9 | Reported |
| Germany | 34.1 | 37.3 | Reported |
| Brazil | 33.4 | 33.9 | Reported |
| Iran | 32.0 | 31.4 | Reported |
| Viet Nam | 24.7 | 22.0 | Reported |
| Italy | 20.7 | 20.0 | Reported |
| Indonesia | 19.0 | 18.6 | Estimate |
| Taiwan, China | 17.2 | 19.2 | Reported |
| Mexico | 13.5 | 14.3 | Reported |
| Spain | 11.8 | 11.9 | Reported |
| Canada | 11.5 | 12.3 | Reported |
| Saudi Arabia | 10.8 | 9.6 | Reported |
| Egypt | 10.6 | 10.7 | Reported |
| France | 9.9 | 10.8 | Reported |
| Malaysia | 7.7 | 9.0 | Reported |
| Austria | 7.6 | 7.1 | Reported |
| Ukraine | 7.4 | 7.6 | Reported |
| Belgium | 7.2 | 7.1 | Reported |
| Poland | 7.2 | 7.1 | Reported |
| Netherlands | 6.5 | 6.4 | Reported |
| Algeria | 5.5 | 4.5 | Reported |
| Australia | 5.2 | 4.7 | Reported |
| Thailand | 5.1 | 4.9 | Reported |
| Bangladesh | 4.5 | 4.5 | Estimate |
| South Africa | 4.5 | 4.7 | Reported |
| Kazakhstan | 4.3 | 4.2 | Reported |
| Argentina | 4.0 | 3.9 | Reported |
| Sweden | 4.0 | 4.0 | Reported |
| United Arab Emirates | 3.8 | 3.7 | Reported |
| Finland | 3.7 | 3.7 | Reported |
| Slovakia | 3.6 | 3.9 | Reported |
| Pakistan | 3.6 | 4.1 | Reported |
| Iraq | 3.0 | 3.0 | Reported |
| Oman | 3.0 | 3.0 | Reported |
| United Kingdom | 2.6 | 4.0 | Reported |
| Czechia | 2.5 | 2.5 | Reported |
| Portugal | 2.1 | 1.9 | Reported |
| Luxembourg | 1.8 | 1.8 | Reported |
| Belarus | 1.8 | 2.3 | Estimate |
| Kenya | 1.8 | 1.8 | Estimate |
| Philippines | 1.8 | 1.8 | Estimate |
| Qatar | 1.7 | 1.2 | Reported |
| Peru | 1.6 | 1.5 | Reported |
| Morocco | 1.5 | 1.4 | Reported |
| Others | 22.5 | 23.8 | Reported |
| Published world total | 1,848.9 | 1,886.8 | Source total |
The 51 one-decimal rows sum to 1,848.8 Mt; worldsteel prints an unrounded world total of 1,848.9 Mt. Both are retained.
Population: worldsteel top 50 producing countries plus Others
Unit: million tonnes crude steel; one decimal; source estimates flagged.
Limitation: This is production, not capacity, exports, CBAM-covered goods or verified embedded emissions.
Do not infer: Do not convert national crude output into EU import exposure or a competitiveness score.
The global comparison is deliberately separate. Worldsteel's table contains 50 countries plus Others, led by China at 960.8 Mt and India at 164.9 Mt. Those values describe national crude-steel production—not capacity, exports to Europe, covered CBAM goods or verified embedded emissions. They show the asymmetry of the production field; they do not assign a CBAM risk score.C-020C-021
Part 3
Six route families; six different decision contracts
The route question is often reduced to coal versus hydrogen. That is too crude for an investment, sourcing or evidence decision. Europe's portfolio includes BF-BOF assets, scrap-EAF production, natural-gas DRI-EAF bridges, hydrogen DRI-EAF, capture configurations and early electrolysis pathways. Their inputs, maturity, residual emissions and infrastructure dependencies differ.
Figure 3 · 2016–2025
The route mix is moving, not flipping
How has EU crude-steel output split between BOF/other and EAF routes?
| Year | BOF/other, kt | EAF, kt | Printed total, kt |
|---|---|---|---|
| 2016 | 91,489 | 62,809 | 154,298 |
| 2017 | 93,928 | 66,941 | 160,869 |
| 2018 | 91,937 | 68,129 | 160,066 |
| 2019 | 86,655 | 63,589 | 150,244 |
| 2020 | 74,189 | 58,018 | 132,217 |
| 2021 | 86,261 | 66,521 | 152,782 |
| 2022 | 77,389 | 58,943 | 136,332 |
| 2023 | 69,729 | 56,457 | 126,186 |
| 2024 | 71,775 | 57,812 | 129,586 |
| 2025 | 68,239 | 57,552 | 125,791 |
EUROFER's printed 2020 components sum to 132,207 kt while its printed total is 132,217 kt; in 2024, the components sum to 129,587 kt versus a printed total of 129,586 kt. The source rows and totals are retained separately rather than silently reconciled.
Population: EU crude-steel output reported by production route
Unit: thousand metric tonnes; nearest thousand tonnes; printed totals preserved despite source reconciliation effects.
Limitation: BOF and other is an aggregate; EAF output does not disclose scrap versus DRI metallic inputs. The 2020 printed components sum 10 kt below the printed total and the 2024 components sum 1 kt above it.
Do not infer: Do not label all EAF output recycled or near-zero-emission steel or silently replace printed totals with component arithmetic.
BF-BOF
- Binding inputs
- Iron ore, coke/coking coal, sinter or pellets, oxygen
- Evidence state
- Dominant EU primary route; mature assets with high direct process emissions
- Decision trigger
- Reline or retirement date, ETS/CBAM interaction, ore and coal supply, capture retrofit feasibility
- Boundary
- BF-BOF is not one homogeneous intensity; installation and product evidence still matters.
Scrap-EAF
- Binding inputs
- Sorted scrap, electricity, alloys and carbon inputs
- Evidence state
- Mature route; EU output table does not reveal scrap grade or electricity emissions
- Decision trigger
- Scrap quality and price, power price and carbon intensity, product-grade requirement
- Boundary
- EAF does not automatically mean 100% scrap, renewable power or near-zero emissions.
Natural-gas DRI-EAF
- Binding inputs
- DR-grade ore/pellets, natural gas, electricity and EAF metallics
- Evidence state
- Commercial bridge configuration; DRI furnace can later use hydrogen subject to design and supply
- Decision trigger
- Gas/hydrogen pathway, pellet supply, EAF and grid connection, lock-in risk
- Boundary
- Hydrogen-ready is not evidence of current low-emission hydrogen use.
Hydrogen DRI-EAF
- Binding inputs
- DR-grade ore/pellets, low-carbon hydrogen and fossil-free electricity
- Evidence state
- JRC reports TRL 6–8 and cost uncertainty driven by hydrogen and power
- Decision trigger
- Hydrogen delivered cost and carbon content, power availability, offtake and financing
- Boundary
- A project announcement or electrolyser plan is not operating commercial capacity.
BF/DRI with carbon capture
- Binding inputs
- Existing or redesigned process, transport and permanent CO2 storage
- Evidence state
- Capture rates, residual emissions, transport and storage chains are configuration-specific
- Decision trigger
- Capture performance, storage access, infrastructure timing and full-chain cost
- Boundary
- A capture unit target is not a verified full-chain abatement result.
Electrolysis routes
- Binding inputs
- Iron ore and large quantities of low-carbon electricity
- Evidence state
- MOE and alkaline iron electrolysis remain development/demonstration pathways in the JRC synthesis
- Decision trigger
- Scale-up, cell life, ore preparation, capital and commercial-readiness evidence
- Boundary
- High theoretical reduction potential is not current industrial performance.
JRC reports H₂-DRI-EAF at technology-readiness level 6–8 and cites an average abatement-cost range of EUR 122–171 per tonne CO₂. It also cites scrap-EAF production costs 35–68% above BF-BOF in the underlying comparison. Both ranges are sensitive to electricity, hydrogen, scrap quality and other assumptions. They are not current quotes for a mill or a forecast of a steel premium.C-032C-033
Natural-gas DRI can be a bridge toward hydrogen, and modern DRI plants can be designed as hydrogen-ready. Neither phrase proves that low-carbon hydrogen is being used today. EAF is likewise a furnace route, not a guarantee of 100% scrap, renewable electricity or near-zero product emissions.C-034C-035
Part 4
The asset clock may force decisions before every input is ready
JRC describes an EU blast-furnace fleet averaging about 50 years, with 25% operating for more than 60 years. Almost half of EU blast furnaces are set to retire before 2035 in the cited synthesis. That creates a decision window: reline, convert, replace, pause or close. It does not prove which choice any installation will make.C-018C-019
Asset decision
What is the technically and financially relevant reline/retirement date?
Input decision
Are electricity, hydrogen, pellets, scrap and CO₂ infrastructure deliverable by that date?
Market decision
Is there contracted demand or policy-backed lead-market evidence for the product?
A strategy passes this gate only if the three clocks align. A technically mature process without grid access is not an operating pathway. A subsidised project without financing, construction and offtake is not delivered capacity. A low-emission product without a compatible emissions boundary and buyer acceptance is not automatically a premium market.
Part 5
The electricity requirement is explicit; delivery is not
JRC reports current EU steel electricity use of 75 TWh per year, including 55 TWh purchased from the grid; the remainder is generated mainly from primary-steelmaking residual gases. Its announced-project pathway then requires 75 TWh per year of direct electricity plus about 2.12 Mt of hydrogen. Producing that hydrogen by water electrolysis corresponds to another 90 TWh, for about 165 TWh per year of fossil-free electricity.C-036C-037C-038
Figure 8 · current baseline and announced-project pathway to 2030
The announced-project energy stack is conditional
What electricity and hydrogen inputs does JRC associate with running all announced EU projects?
| Quantity | Value | Evidence status |
|---|---|---|
| Current total electricity use | 75 TWh/year | Observed/synthesised baseline |
| Current grid purchases | 55 TWh/year | Subset of current total |
| Direct power for announced plants | 75 TWh/year | Conditional pathway |
| Electrolysis power for 2.12 Mt H₂ | 90 TWh/year | Conditional pathway |
| Total fossil-free power pathway | 165 TWh/year | 75 + 90; not plus current 75 |
| Hydrogen associated with pathway | 2.12 Mt/year | If announced plants run; 90 TWh assumes water electrolysis |
Population: JRC's stated EU announced-project scenario
Unit: TWh per year and Mt hydrogen per year; 75 TWh direct; 2.12 Mt H2; 90 TWh electrolysis; about 165 TWh total.
Limitation: Conditional pathway arithmetic assumes hydrogen from water electrolysis and all announced plants running.
Do not infer: Do not report these quantities as observed demand, secured supply or a forecast that all projects operate.
The correct comparison is not 75 + 165. The 165 TWh pathway is the stated 75 TWh direct requirement plus 90 TWh for electrolysis. It is conditional on all announced plants running and on the specified hydrogen-production route. It does not prove that generation, network capacity, electrolysers, storage or contracts exist.
For a project file, replace “hydrogen available” with four fields: delivery point, annual quantity, carbon-accounting method and delivered price period. Replace “renewable electricity secured” with generation profile, grid connection, contractual instrument and treatment under the emissions methodology. Those fields turn a slogan into evidence.
Part 6
More EAF raises a quality and allocation question, not just a tonnage question
EUROFER reports EU scrap consumption of 74.424 Mt in 2025, imports of 4.797 Mt and exports of 16.309 Mt. Its published net-export value is 11.511 Mt; subtracting the rounded gross values produces a one-thousand-tonne difference. That rounding gap is preserved rather than “corrected”.C-025C-026C-027
Figure 6 · 2016–2025
Scrap is a volume, trade and quality problem
How do EU scrap consumption, imports, exports and net exports move together?
| Year | Consumption | Imports | Exports | Printed net exports |
|---|---|---|---|---|
| 2016 | 85,818 | 4,467 | 11,714 | 7,246 |
| 2017 | 90,882 | 4,918 | 13,410 | 8,492 |
| 2018 | 88,459 | 4,550 | 15,122 | 10,572 |
| 2019 | 83,787 | 4,268 | 15,579 | 11,311 |
| 2020 | 75,255 | 4,122 | 17,446 | 13,324 |
| 2021 | 87,852 | 5,522 | 19,430 | 13,907 |
| 2022 | 79,340 | 3,951 | 17,612 | 13,661 |
| 2023 | 75,183 | 3,897 | 18,738 | 14,842 |
| 2024 | 76,648 | 4,741 | 15,618 | 10,876 |
| 2025 | 74,424 | 4,797 | 16,309 | 11,511 |
Population: EUROFER EU scrap balance series
Unit: thousand metric tonnes; nearest thousand tonnes; one-thousand-tonne rounding tolerance.
Limitation: Gross tonnage does not encode grade, contaminants, recovery yield, ownership or suitability for specific steel products.
Do not infer: Do not treat all exported scrap as immediately usable domestic EAF feedstock.
Net exports are not an immediately recoverable domestic feedstock pool. Scrap differs by grade, copper and other residuals, collection and sorting cost, recovery yield and product suitability. A flat or automotive grade can impose different input constraints from construction steel. JRC's pathway estimates EU scrap use at about 77 Mt in 2024 and 92 Mt in 2035 under its route-mix and stable-production assumptions; that is a conditional pathway, not proof of a quantified shortage.C-031
Primary routes face their own dependency. JRC estimates 77% EU import reliance for iron ore and reports around 75% of iron-ore and coking-coal supply coming from extra-EU sources. Those values describe supply structure, not interruption probability. A DRI pathway adds a further question: whether the ore or pellet supply has the quality needed by the selected process.C-028C-029
Part 7
Europe is transitioning inside a market with record capacity pressure
OECD estimates global excess steel capacity at 640 Mt in 2025 and projects up to 745 Mt in 2028. The projected number depends on announced projects underway and planned plus the OECD demand path. It is not an observed 2028 fact. OECD separately reports global steelmaking capacity at a record 2,445 Mt in 2025 while demand contracted for a fourth year.C-040C-041C-042
Figure 7 · 2019–2025 observed/estimated; 2026–2028 projected
640 Mt estimated; 745 Mt projected
What separates OECD's 2025 excess-capacity estimate from its 2028 projection?
2025 · Estimate
640 Mt
Global crude-steel capacity minus demand under the OECD definition and stated inputs.
2028 · Projection
745 Mt
Global crude-steel capacity minus demand under the OECD definition and stated inputs.
| Year | Evidence status | Excess capacity | Contract |
|---|---|---|---|
| 2025 | OECD estimate | 640 Mt | Record 2,445 Mt capacity; demand measure stated by OECD |
| 2028 | OECD projection | 745 Mt | Announced projects underway and planned; projected demand |
Population: global capacity and demand in OECD Steel Outlook 2026
Unit: million tonnes crude-steel equivalent; nearest million tonnes in headline values.
Limitation: Forecast capacity is based on announced projects underway and planned; demand and capacity are modelled by different stated inputs.
Do not infer: Do not present 745 Mt as observed, guaranteed or attributable to a single country or policy.
Figure 5 · 2016 and 2025
The origin mix changed materially between 2016 and 2025
How did the EUROFER origin rows change between 2016 and 2025?
| Origin row | 2016, kt | 2025, kt | Change, kt |
|---|---|---|---|
| Türkiye | 2,044 | 4,815 | 2,771 |
| South Korea | 2,523 | 3,345 | 822 |
| Indonesia | 88 | 2,636 | 2,548 |
| China, P. Republic | 5,249 | 2,576 | -2,673 |
| India | 1,822 | 2,411 | 589 |
| Ukraine | 2,942 | 2,211 | -731 |
| Taiwan | 705 | 1,949 | 1,244 |
| Vietnam | 45 | 1,869 | 1,824 |
| Africa | 222 | 1,780 | 1,558 |
| United Kingdom | 2,039 | 1,316 | -723 |
| Others | 9,019 | 4,819 | -4,200 |
| Printed total | 26,698 | 29,727 | 3,029 |
Population: ten ranked origin rows plus Others in EUROFER's all-qualities table
Unit: thousand metric tonnes; nearest thousand tonnes.
Limitation: Africa and Others are source aggregates; the table is not a CBAM customs-scope or emissions dataset.
Do not infer: Do not infer supplier emissions, certificate liabilities or trade diversion causally from origin tonnage.
EUROFER's all-qualities import-origin table totals 29.727 Mt in 2025. Türkiye is the largest named row at 4.815 Mt. Indonesia rises from 0.088 Mt in 2016 to 2.636 Mt in 2025. These endpoints do not prove CBAM causation, trade diversion or supplier emissions; product mix and other trade measures also changed.C-022C-023C-024
Trade protection and carbon adjustment are separate layers. The pre-existing steel safeguard expired after 30 June 2026. Regulation (EU) 2026/1384 opened the replacement tariff quotas; Implementing Regulation (EU) 2026/1457 distributed those quotas and applies from 1 July through 31 December 2026. CBAM uses a different legal mechanism. A commercially useful steel view keeps quota access, duty exposure, CBAM evidence and product demand in separate scenario rows rather than collapsing them into one “border cost”.C-008C-009C-056
Part 8
The policy stack contains law, programmes and proposals
| Layer | Status at 12 August 2026 | Steel decision | Boundary |
|---|---|---|---|
| CBAM Regulation | Adopted law | Covered goods, embedded-emissions evidence and certificate obligations. | Only Annex I goods; use the goods checker and official text. |
| EU ETS / free-allocation adjustment | Adopted law | Links import adjustment to equivalent EU free allocation. | Detailed factor schedule belongs to the canonical phase-in guide. |
| Steel and Metals Action Plan | Official operations / data | Energy, lead markets, circularity, trade, investment and CBAM work programme. | A programme contains measures at different delivery states; it is not one law. |
| 2026 replacement steel quota regime | Adopted law | Regulation 2026/1384 opens the regime; Implementing Regulation 2026/1457 distributes the tariff quotas. | The implementing distribution applies 1 July–31 December 2026; it is not a CBAM certificate or emissions rule. |
| Downstream CBAM extension | Proposal — not law | Could change exposure for selected steel-intensive downstream goods. | Procedure 2025/0419(COD); proposed application from 2028 can change. |
| July 2026 ETS revision | Proposal — not law | Potential future competitiveness and decarbonisation changes. | Do not mix COM(2026)616 into operative ETS law. |
Current CBAM scope is narrower than “all steel-containing goods.” Annex I lists covered iron and steel codes and exclusions, including ferrous waste and scrap under CN 7204. The downstream proposal describes around 180 additional CN codes and an estimated 7,500 additional importers, with proposed application from 1 January 2028. Those remain proposal parameters—not current obligations.C-001C-002C-006C-007
CBAM certificate surrender is adjusted to reflect EU ETS free allocation for equivalent EU production, while the ETS Directive applies a declining CBAM factor to free allocation for covered goods. This article does not reproduce the schedule or calculate a company result. Use the dedicated phase-in guide and the CBAM cost calculator with current official assumptions.C-003C-004
Part 9
A project pipeline is only as credible as its delivery state
The JRC synthesis says most announced EU near-zero projects combine hydrogen-compatible DRI-EAF and scrap-EAF routes. It also states the prerequisite directly: project realisation requires a business case. Therefore announced projects are not operating capacity. Neither aid approval, a company target nor a technology-readiness claim closes the delivery chain.
A May 2026 JRC INCITE report record describes a 2026–2030 pipeline of approximately 17 Mt per year of direct-reduced-iron capacity across eight plants and about 35 Mt per year of new electric-arc-furnace capacity across sixteen plants. The record's use of “confirmed” does not make those tonnes commissioned capacity, annual production or proof that all plants will operate.C-058
1. Announcement
Scope, location and target disclosed; no delivery inference.
2. Aid approved
Public support is authorised; financing and build may remain open.
3. FID / finance
Sponsors commit subject to the disclosed financing package.
4. Construction
Physical execution starts; schedule and cost risk remain.
5. Commissioning
Systems are tested; nameplate capacity is not annual output.
6. Operating
Production evidence exists; route, fuel and utilisation still matter.
7. Paused
Timing or scope is suspended; do not retain the old delivery date.
8. Cancelled
Remove from future-capacity totals; preserve historical provenance.
JRC cites EUR 31 billion of CAPEX and EUR 54 billion of OPEX—EUR 85 billion combined—for the announced near-zero project pathway to 2030. It separately reports a EUROFER projection of 81.5 MtCO₂ in annual emissions reductions by 2030 from a 145 MtCO₂ 2023 baseline if the projects are completed. These are conditional scenario figures, not audited committed budgets, achieved abatement or a project-by-project forecast.C-039C-057
A project should enter a capacity figure only when the dataset's state and measurement allow it. Announcement counts can support a pipeline map. Commissioned nameplate capacity can support a commissioning table. Observed annual production can support an output table. Those are three different artifacts.
Part 10
Low-emission steel needs a buyer and a definition
Supply-side technology is only half the market. A route conversion requires products buyers can specify, emissions boundaries they can compare and offtake terms that help support financing. JRC's comparison of international initiatives finds multiple low-carbon-steel definitions rather than one universal threshold. Accounting boundaries, scrap treatment and performance classes differ.C-044
Global industry data allocate 52% of 2025 steel use to building and infrastructure, 16% to automotive, 12% to mechanical equipment, 10% to metal products and smaller shares to other uses. That is a global demand structure—not an EU CBAM allocation. It explains why public procurement, construction standards, vehicle policy and industrial buyers can matter to route economics without every downstream product being currently covered by CBAM.C-046
A credible product claim
- Evidence now
- Named accounting method, production boundary, route, electricity treatment, scrap treatment and verified period.
- Monitor
- EU product-policy method, interoperable standards and buyer acceptance.
- Stop condition
- Do not use an undefined green-steel label or compare unlike boundaries.
A credible demand signal
- Evidence now
- Buyer, product, annual volume, term, price mechanism and delivery specification.
- Monitor
- Contract execution, product qualification and renewal—not press-release demand.
- Stop condition
- Do not turn an MoU or procurement aspiration into bankable offtake.
The fastener case has its own canonical workflow. Buyers of CN 7318 goods should use the steel-fastener buyer guide. The proposed broader downstream extension is covered by the current-versus-proposed downstream guide.
Practical workflow
What each actor should collect before changing strategy
EU steel producer
Collect
- • asset age and reinvestment date
- • route-level verified emissions
- • power/hydrogen/scrap supply evidence
Monitor
- • ETS/CBAM factor law
- • project and infrastructure delivery states
Do not infer: Do not infer that border protection supplies the energy, demand or finance required for route conversion.
EU importer / declarant
Collect
- • CN code and origin
- • installation and production-route evidence
- • verified embedded-emissions record
Monitor
- • current scope and defaults
- • downstream proposal procedure
Do not infer: Do not substitute country averages or this article's route ranges for the legally required goods evidence.
Non-EU mill / exporter
Collect
- • installation boundary
- • precursor evidence
- • verification-ready calculation records
Monitor
- • EU methodology changes
- • buyer evidence requests
Do not infer: Do not infer EU market access, a certificate advantage or product eligibility from a national route label.
Downstream manufacturer
Collect
- • steel input codes and quantities
- • supplier route and origin fields
- • contract price and change clauses
Monitor
- • downstream proposal status
- • lead-market and product-policy rules
Do not infer: Do not treat the proposed downstream extension as current law or assume universal pass-through.
Procurement / finance
Collect
- • project stage and financing evidence
- • energy and metallic-input assumptions
- • offtake volume and term
Monitor
- • FID/construction/commissioning changes
- • power, hydrogen and scrap contract evidence
Do not infer: Do not treat announced capex, targets or policy support as delivered output, margin or return.
Adviser / policy researcher
Collect
- • document identity and date
- • legal or evidence status
- • unit, denominator and scenario contract
Monitor
- • procedure milestones
- • new JRC/OECD/worldsteel vintages
Do not infer: Do not blend adopted law, Commission proposals, industry positions and institutional pathways into one prediction.
Monitoring design
A steel-transition dashboard should track proof, not headlines
| Signal | Minimum fields | Update trigger | False shortcut |
|---|---|---|---|
| Asset decision | Installation, route, product, reline/retirement date | Owner-confirmed schedule change | Average fleet age predicts this plant |
| Project state | Announcement, aid, FID, construction, commissioning, operation | New dated primary evidence | All pipeline tonnes are future output |
| Electricity | Quantity, profile, connection, source treatment, price period | Contract or grid milestone | National renewable share proves project supply |
| Hydrogen | Delivery point, quantity, production route, carbon method, price | Contract, FID or operation | Hydrogen-ready means hydrogen-fuelled |
| Scrap | Grade, contaminants, yield, price, volume, location | Contract or quality change | Net exports equal available feedstock |
| DR ore/pellets | Specification, origin, capacity, contract and logistics | Supply agreement or project change | Iron-ore import volume proves DR quality |
| Demand | Buyer, product, volume, term, price and qualification | Executed contract or delivery | MoU equals bankable offtake |
| Policy | Document, status, operative date, product scope | Official Journal or procedure milestone | Commission proposal equals law |
Safe synthesis
Brief the uncertainty without making the article useless
Use
- “EUROFER reports 125.792 Mt of EU crude-steel output in its 2025 country table.”
- “JRC estimates a 165 TWh/year fossil-free electricity pathway if all announced projects run and electrolysis supplies the stated hydrogen.”
- “The downstream extension remained a proposal at the 12 August 2026 cut-off.”
- “OECD projects up to 745 Mt of excess capacity in 2028 under its stated capacity and demand inputs.”
Do not use
- “CBAM guarantees the future of European steel.”
- “Europe will need exactly 165 TWh more electricity.”
- “All downstream steel goods enter CBAM in 2028.”
- “745 Mt of excess capacity will exist in 2028.”
- “EAF steel is green steel.”
Method
How the evidence was admitted and transformed
The research cut-off is 12 August 2026. The source search covered current EUR-Lex law and legislative procedure, Commission steel and CBAM documents, JRC route, supply-chain, intensity and definition studies, OECD capacity analysis, worldsteel and EUROFER statistical publications, IEA technology analysis and official operational pages. Primary law owns legal claims. Institutional studies own pathway claims. Industry publications are labelled rather than presented as neutral official statistics.
- Freeze: material PDFs and page text were retained locally with checksums where retrieval allowed.
- Classify: adopted law, official operations, proposal, institutional pathway, industry data and held conclusion remain separate.
- Atomise: every material claim records a source, locator, limitation, prohibited inference and canonical owner.
- Reconcile: complete printed populations are reproduced; dashes, aggregates and rounding differences remain visible.
- Fail closed: unsupported shortages, project delivery, company outcomes and universal technology conclusions stay in the held ledger.
No chart mixes country output, capacity, trade or embedded emissions. The EU table covers 19 named rows plus Others. The world table covers 50 countries plus Others. OECD's 2025 and 2028 excess-capacity values retain estimate and projection labels. JRC's project energy stack retains its “all announced plants” and electrolysis conditions.
Audit trail
Claim ledger: 49 supported, 9 held
C-001CBAM applies only to the iron and steel goods listed in Annex I, not to every steel-containing downstream product.
Adopted law
CBAM applies only to the iron and steel goods listed in Annex I, not to every steel-containing downstream product.
- Source / locator
- S-005, S-022 · Regulation 2023/956, Article 2 and Annex I
- Canonical owner
- /sectors/iron-steel and the goods checker
- Limitation
- Correct treatment depends on the goods code and current consolidated annex.
- Prohibited inference
- Do not use this summary as a customs-classification conclusion.
C-002Ferrous waste and scrap under CN 7204 is excluded from the Annex I iron-and-steel chapter listing.
Adopted law
Ferrous waste and scrap under CN 7204 is excluded from the Annex I iron-and-steel chapter listing.
- Source / locator
- S-005 · Annex I, iron and steel exclusions
- Canonical owner
- /sectors/iron-steel
- Limitation
- The exclusion is code-specific and does not resolve other goods or precursor treatment.
- Prohibited inference
- Do not infer that all recycled-content products or scrap-derived emissions are outside CBAM.
C-003CBAM certificate surrender is adjusted to reflect EU ETS free allocation for equivalent EU production.
Adopted law
CBAM certificate surrender is adjusted to reflect EU ETS free allocation for equivalent EU production.
- Source / locator
- S-005, S-014 · Regulation 2023/956 Article 31; Regulation 2025/2620
- Canonical owner
- /guides/cbam-factor-free-allocation-phase-in
- Limitation
- The adjustment requires the adopted calculation rules and product/installation facts.
- Prohibited inference
- Do not calculate a company obligation from the high-level interaction described here.
C-004EU ETS free allocation for CBAM goods is multiplied by a declining CBAM factor under the adopted ETS Directive.
Adopted law
EU ETS free allocation for CBAM goods is multiplied by a declining CBAM factor under the adopted ETS Directive.
- Source / locator
- S-013 · Directive 2003/87/EC Article 10a(1a)
- Canonical owner
- /guides/cbam-factor-free-allocation-phase-in
- Limitation
- The exact schedule and benchmark application are owned by the phase-in guide.
- Prohibited inference
- Do not duplicate or paraphrase the detailed factor schedule here.
C-005The December 2025 downstream-CBAM file is a Commission proposal in the ordinary legislative procedure, not adopted law at the research cut-off.
Proposal — not law
The December 2025 downstream-CBAM file is a Commission proposal in the ordinary legislative procedure, not adopted law at the research cut-off.
- Source / locator
- S-009, S-018 · COM(2025)989; procedure 2025/0419(COD); Council mandate 12 June 2026
- Canonical owner
- This steel sector flagship
- Limitation
- Procedure status can change and must be rechecked before publication.
- Prohibited inference
- Do not state that all proposed downstream goods are currently in CBAM scope.
C-006The proposed downstream extension was designed to apply from 1 January 2028 if adopted in the proposed form.
Proposal — not law
The proposed downstream extension was designed to apply from 1 January 2028 if adopted in the proposed form.
- Source / locator
- S-009 · COM(2025)989 application provisions
- Canonical owner
- This steel sector flagship
- Limitation
- A proposed application date can change in negotiations or final adoption.
- Prohibited inference
- Do not present 1 January 2028 as an operative obligation.
C-007The Commission proposal describes around 180 additional CN codes and an estimated 7,500 additional importers.
Proposal — not law
The Commission proposal describes around 180 additional CN codes and an estimated 7,500 additional importers.
- Source / locator
- S-009 · COM(2025)989 digital implications
- Canonical owner
- This steel sector flagship
- Limitation
- These are proposal impact estimates, not current scope counts.
- Prohibited inference
- Do not imply all downstream steel products or importers are covered today.
C-008Regulation (EU) 2026/1384 is adopted steel trade law, distinct from CBAM and the earlier safeguard.
Adopted law
Regulation (EU) 2026/1384 is adopted steel trade law, distinct from CBAM and the earlier safeguard.
- Source / locator
- S-016, S-023 · Regulation 2026/1384 and Implementing Regulation 2026/1457
- Canonical owner
- This steel sector flagship
- Limitation
- The replacement tariff-quota regime requires its implementing distribution act; trade protection and CBAM remain different legal mechanisms.
- Prohibited inference
- Do not describe the trade measure as a CBAM certificate rule.
C-009The April 2026 implementing regulation amended the pre-existing definitive steel safeguard, which expired after 30 June 2026.
Adopted law
The April 2026 implementing regulation amended the pre-existing definitive steel safeguard, which expired after 30 June 2026.
- Source / locator
- S-017 · Implementing Regulation 2026/846, recital 1
- Canonical owner
- This steel sector flagship
- Limitation
- This was the final period of the pre-existing safeguard, not the replacement regime applying from July 2026.
- Prohibited inference
- Do not describe the expired safeguard as the current August 2026 quota regime.
C-010The July 2026 ETS revision file is a Commission proposal, not current ETS law.
Proposal — not law
The July 2026 ETS revision file is a Commission proposal, not current ETS law.
- Source / locator
- S-019, S-013 · COM(2026)616 versus consolidated Directive 2003/87/EC
- Canonical owner
- This steel sector flagship
- Limitation
- The proposal post-dates the currently consolidated directive used for operative law.
- Prohibited inference
- Do not mix proposal provisions into the current free-allocation schedule.
C-011EU crude-steel output in the EUROFER table totalled 125.792 Mt in 2025.
Industry data
EU crude-steel output in the EUROFER table totalled 125.792 Mt in 2025.
- Source / locator
- S-002 · p. 15, EU27 total
- Canonical owner
- This steel sector flagship
- Limitation
- Industry-reported total differs by one thousand tonnes from the route table because of source rounding.
- Prohibited inference
- Do not call the number official Eurostat output or CBAM-covered trade.
C-012Germany represented 34.090 Mt, or 27.1%, of the 2025 EU total in that country table.
Industry data
Germany represented 34.090 Mt, or 27.1%, of the 2025 EU total in that country table.
- Source / locator
- S-002 · p. 15, Germany row
- Canonical owner
- This steel sector flagship
- Limitation
- The table reports crude output, not capacity, exports or emissions.
- Prohibited inference
- Do not infer Germany's CBAM liability or transition readiness.
C-013The source discloses 19 country rows plus an Others aggregate rather than 27 individual EU values.
Industry data
The source discloses 19 country rows plus an Others aggregate rather than 27 individual EU values.
- Source / locator
- S-002 · p. 15, complete printed population
- Canonical owner
- This steel sector flagship
- Limitation
- Croatia and Hungary display dashes for 2025 and Others aggregates undisclosed output.
- Prohibited inference
- Do not manufacture zeroes or assign the Others value to named countries.
C-014EU operating crude-steel capacity fell from 236 Mt in 2008 to 194 Mt in 2025 in EUROFER's series.
Industry data
EU operating crude-steel capacity fell from 236 Mt in 2008 to 194 Mt in 2025 in EUROFER's series.
- Source / locator
- S-002 · EUROFER p. 11
- Canonical owner
- This steel sector flagship
- Limitation
- Operating capacity is an industry-defined series, not all installed or technically possible capacity.
- Prohibited inference
- Do not infer closures, utilisation or profitability without the corresponding evidence.
C-015EU capacity utilisation was 64.8% in 2025 in EUROFER's series.
Industry data
EU capacity utilisation was 64.8% in 2025 in EUROFER's series.
- Source / locator
- S-002 · EUROFER p. 12
- Canonical owner
- This steel sector flagship
- Limitation
- Utilisation is a ratio against reported operating capacity and can differ from Commission approximations.
- Prohibited inference
- Do not label 64.8% a universal break-even threshold.
C-016EU 2025 crude output split 54.2% BOF/other and 45.8% EAF in EUROFER's table.
Industry data
EU 2025 crude output split 54.2% BOF/other and 45.8% EAF in EUROFER's table.
- Source / locator
- S-002 · EUROFER p. 16
- Canonical owner
- This steel sector flagship
- Limitation
- EAF output does not disclose metallic-input shares or electricity emissions; the source's 2020 printed components sum 10 kt below its printed total and its 2024 components sum 1 kt above the total.
- Prohibited inference
- Do not label all EAF steel recycled, green or low-emission or silently replace printed totals with component arithmetic.
C-017The JRC describes the EU's 2024 production split as roughly 55% BF-BOF and 45% EAF.
Institutional analysis / pathway
The JRC describes the EU's 2024 production split as roughly 55% BF-BOF and 45% EAF.
- Source / locator
- S-004 · p. 2
- Canonical owner
- This steel sector flagship
- Limitation
- Rounded JRC shares and EUROFER's later table use different vintages and labels.
- Prohibited inference
- Do not treat the rounded 2024 split as a 2025 exact value.
C-018The EU blast-furnace fleet averaged about 50 years and 25% had operated for over 60 years in the JRC synthesis.
Institutional analysis / pathway
The EU blast-furnace fleet averaged about 50 years and 25% had operated for over 60 years in the JRC synthesis.
- Source / locator
- S-004 · p. 2
- Canonical owner
- This steel sector flagship
- Limitation
- Fleet-age evidence does not identify individual asset condition or retirement decisions.
- Prohibited inference
- Do not predict a plant closure or investment from fleet averages.
C-019JRC reports that almost half of EU blast furnaces are set to retire before 2035.
Institutional analysis / pathway
JRC reports that almost half of EU blast furnaces are set to retire before 2035.
- Source / locator
- S-004 · p. 2
- Canonical owner
- This steel sector flagship
- Limitation
- The statement is an asset-timing synthesis, not proof of closure or replacement delivery.
- Prohibited inference
- Do not equate scheduled retirement with lost production or completed low-emission capacity.
C-020World crude-steel output was 1,848.9 Mt in 2025 in worldsteel's country table.
Industry data
World crude-steel output was 1,848.9 Mt in 2025 in worldsteel's country table.
- Source / locator
- S-001 · p. 9, World row
- Canonical owner
- This steel sector flagship
- Limitation
- Industry-reported crude output differs from OECD scenario-table definitions and vintages.
- Prohibited inference
- Do not substitute the total for demand, capacity or CBAM goods mass.
C-021China produced 960.8 Mt and India 164.9 Mt in worldsteel's 2025 country table.
Industry data
China produced 960.8 Mt and India 164.9 Mt in worldsteel's 2025 country table.
- Source / locator
- S-001 · p. 9, first two country rows
- Canonical owner
- This steel sector flagship
- Limitation
- National crude output is not EU import volume or installation emissions.
- Prohibited inference
- Do not rank CBAM exposure using global crude output alone.
C-022EUROFER's 2025 all-qualities import-origin table totals 29.727 Mt.
Industry data
EUROFER's 2025 all-qualities import-origin table totals 29.727 Mt.
- Source / locator
- S-002 · p. 37, Total row
- Canonical owner
- This steel sector flagship
- Limitation
- The product population is not identical to CBAM Annex I or worldsteel finished-steel trade.
- Prohibited inference
- Do not convert the tonnage into certificate cost or embedded emissions.
C-023Türkiye was the largest named origin row in that 2025 table at 4.815 Mt.
Industry data
Türkiye was the largest named origin row in that 2025 table at 4.815 Mt.
- Source / locator
- S-002 · p. 37, Türkiye row
- Canonical owner
- This steel sector flagship
- Limitation
- Origin tonnage does not identify supplier, route or verified emissions.
- Prohibited inference
- Do not infer Türkiye-wide carbon intensity or circumvention.
C-024The same table reports 2.636 Mt from Indonesia in 2025 versus 0.088 Mt in 2016.
Industry data
The same table reports 2.636 Mt from Indonesia in 2025 versus 0.088 Mt in 2016.
- Source / locator
- S-002 · p. 37, Indonesia row
- Canonical owner
- This steel sector flagship
- Limitation
- The endpoints do not establish a causal effect or consistent product mix.
- Prohibited inference
- Do not attribute the increase to CBAM or trade diversion without causal evidence.
C-025EU scrap consumption was 74.424 Mt in 2025 in EUROFER's series.
Industry data
EU scrap consumption was 74.424 Mt in 2025 in EUROFER's series.
- Source / locator
- S-002 · p. 58
- Canonical owner
- This steel sector flagship
- Limitation
- Gross scrap consumption does not report grade, contamination or yield.
- Prohibited inference
- Do not equate all tonnes with high-quality feedstock for every EAF product.
C-026EU scrap imports were 4.797 Mt and exports 16.309 Mt in 2025.
Industry data
EU scrap imports were 4.797 Mt and exports 16.309 Mt in 2025.
- Source / locator
- S-002 · pp. 56–57
- Canonical owner
- This steel sector flagship
- Limitation
- Trade flows and domestic suitability are different questions.
- Prohibited inference
- Do not assume all exported scrap could be retained or used domestically without cost or quality constraints.
C-027Published 2025 EU net scrap exports were 11.511 Mt; gross-flow subtraction differs by one thousand tonnes because of rounding.
Industry data
Published 2025 EU net scrap exports were 11.511 Mt; gross-flow subtraction differs by one thousand tonnes because of rounding.
- Source / locator
- S-002 · p. 58 and arithmetic from pp. 56–57
- Canonical owner
- This steel sector flagship
- Limitation
- The source's printed net value should be retained with its rounding tolerance.
- Prohibited inference
- Do not call the one-thousand-tonne difference a data error.
C-028JRC estimates EU import reliance of 77% for iron ore in its 2024 supply-chain assessment.
Institutional analysis / pathway
JRC estimates EU import reliance of 77% for iron ore in its 2024 supply-chain assessment.
- Source / locator
- S-003 · Figure 6 discussion
- Canonical owner
- This steel sector flagship
- Limitation
- Import reliance uses the JRC supply-mix method and is not a shortage forecast.
- Prohibited inference
- Do not infer supply interruption probability or country-specific exposure.
C-029JRC reports that around 75% of EU iron-ore and coking-coal supply comes from extra-EU sources.
Institutional analysis / pathway
JRC reports that around 75% of EU iron-ore and coking-coal supply comes from extra-EU sources.
- Source / locator
- S-003 · highlights
- Canonical owner
- This steel sector flagship
- Limitation
- This combines two primary-input dependencies at a rounded level.
- Prohibited inference
- Do not apply the share to scrap-EAF routes or finished-steel imports.
C-030JRC's 2035 announced-capacity estimate shifts EU carbon-steel capacity toward 32% BF-BOF, 50% scrap-EAF and 18% DRI-EAF.
Institutional analysis / pathway
JRC's 2035 announced-capacity estimate shifts EU carbon-steel capacity toward 32% BF-BOF, 50% scrap-EAF and 18% DRI-EAF.
- Source / locator
- S-003 · Figure 10
- Canonical owner
- This steel sector flagship
- Limitation
- The 2035 values depend on announced capacities becoming operational and relatively stable production assumptions.
- Prohibited inference
- Do not report the mix as a forecast or delivered capacity.
C-031JRC estimates EU scrap use at about 77 Mt in 2024 and projects 92 Mt in 2035 under its stated route-mix assumptions.
Institutional analysis / pathway
JRC estimates EU scrap use at about 77 Mt in 2024 and projects 92 Mt in 2035 under its stated route-mix assumptions.
- Source / locator
- S-003 · Figure 12 discussion
- Canonical owner
- This steel sector flagship
- Limitation
- The 2035 value is conditional on the estimated mix and relatively stable steel production.
- Prohibited inference
- Do not state a verified future scrap requirement or shortage.
C-032JRC reports H2-DRI-EAF at TRL 6–8 with an average abatement-cost range of EUR 122–171 per tonne CO2.
Institutional analysis / pathway
JRC reports H2-DRI-EAF at TRL 6–8 with an average abatement-cost range of EUR 122–171 per tonne CO2.
- Source / locator
- S-004 · p. 5
- Canonical owner
- This steel sector flagship
- Limitation
- The cited range comes from a referenced technology comparison and is sensitive to hydrogen and power costs.
- Prohibited inference
- Do not turn the range into a plant quote, steel premium or investment recommendation.
C-033JRC reports scrap-EAF production costs 35–68% above BF-BOF in the cited comparison.
Institutional analysis / pathway
JRC reports scrap-EAF production costs 35–68% above BF-BOF in the cited comparison.
- Source / locator
- S-004 · p. 5
- Canonical owner
- This steel sector flagship
- Limitation
- The comparison is assumption- and input-price-dependent, especially for high-purity scrap and electricity.
- Prohibited inference
- Do not apply the range to every mill, product, country or year.
C-034JRC identifies natural-gas DRI-EAF as a bridge configuration until sufficient hydrogen is available.
Institutional analysis / pathway
JRC identifies natural-gas DRI-EAF as a bridge configuration until sufficient hydrogen is available.
- Source / locator
- S-004 · p. 5
- Canonical owner
- This steel sector flagship
- Limitation
- A bridge label does not quantify lock-in, emissions or commercial suitability.
- Prohibited inference
- Do not call natural-gas DRI zero-emission or guarantee conversion to hydrogen.
C-035JRC states that state-of-the-art DRI plants can be hydrogen-ready.
Institutional analysis / pathway
JRC states that state-of-the-art DRI plants can be hydrogen-ready.
- Source / locator
- S-004 · p. 5
- Canonical owner
- This steel sector flagship
- Limitation
- Hydrogen-ready describes technical design, not the fuel actually used or its carbon intensity.
- Prohibited inference
- Do not report hydrogen-ready capacity as hydrogen-based production.
C-036JRC reports current EU steel electricity use of 75 TWh/year, including 55 TWh purchased from the grid.
Institutional analysis / pathway
JRC reports current EU steel electricity use of 75 TWh/year, including 55 TWh purchased from the grid.
- Source / locator
- S-004 · p. 6
- Canonical owner
- This steel sector flagship
- Limitation
- The remainder is described as generation from industrial residual gases in primary steelmaking.
- Prohibited inference
- Do not treat all current electricity as fossil-free or grid-supplied.
C-037Running all announced projects would require 75 TWh/year of direct electricity plus about 2.12 Mt/year of hydrogen in the JRC pathway.
Institutional analysis / pathway
Running all announced projects would require 75 TWh/year of direct electricity plus about 2.12 Mt/year of hydrogen in the JRC pathway.
- Source / locator
- S-004 · pp. 6–7
- Canonical owner
- This steel sector flagship
- Limitation
- The statement is conditional on announced projects running, not a current observation.
- Prohibited inference
- Do not call it secured demand, supply or a forecast.
C-038Producing that hydrogen by water electrolysis corresponds to 90 TWh/year, bringing the JRC total to about 165 TWh/year of fossil-free electricity.
Institutional analysis / pathway
Producing that hydrogen by water electrolysis corresponds to 90 TWh/year, bringing the JRC total to about 165 TWh/year of fossil-free electricity.
- Source / locator
- S-004 · pp. 6–7
- Canonical owner
- This steel sector flagship
- Limitation
- The arithmetic assumes electrolysis and the announced-project pathway.
- Prohibited inference
- Do not add the current 75 TWh baseline again or imply the power has been contracted.
C-039JRC reports EUR 31 billion CAPEX and EUR 54 billion OPEX for the announced near-zero projects through 2030 in the cited scenario.
Institutional analysis / pathway
JRC reports EUR 31 billion CAPEX and EUR 54 billion OPEX for the announced near-zero projects through 2030 in the cited scenario.
- Source / locator
- S-004 · p. 6
- Canonical owner
- This steel sector flagship
- Limitation
- These are scenario totals tied to announced projects and source assumptions, not audited project budgets.
- Prohibited inference
- Do not use EUR 85 billion as committed finance or a firm forecast.
C-040OECD estimated global excess steel capacity at 640 Mt in 2025.
Institutional analysis / pathway
OECD estimated global excess steel capacity at 640 Mt in 2025.
- Source / locator
- S-010 · p. 11, Figure 1.1 discussion
- Canonical owner
- This steel sector flagship
- Limitation
- Excess capacity is the OECD gap between its capacity and demand measures.
- Prohibited inference
- Do not equate excess capacity with idle EU capacity or dumped imports.
C-041OECD projects global excess capacity could reach 745 Mt by 2028.
Institutional analysis / pathway
OECD projects global excess capacity could reach 745 Mt by 2028.
- Source / locator
- S-010 · Executive summary and p. 11
- Canonical owner
- This steel sector flagship
- Limitation
- The projection is based on announced projects underway and planned plus OECD demand estimates.
- Prohibited inference
- Do not present 745 Mt as observed or guaranteed.
C-042OECD reports global 2025 steelmaking capacity at a record 2,445 Mt and demand contraction for a fourth year.
Institutional analysis / pathway
OECD reports global 2025 steelmaking capacity at a record 2,445 Mt and demand contraction for a fourth year.
- Source / locator
- S-010 · p. 37
- Canonical owner
- This steel sector flagship
- Limitation
- Capacity and demand use OECD/worldsteel series with specified definitions.
- Prohibited inference
- Do not combine the value arithmetically with differently defined regional production tables.
C-043OECD projects EU27 plus UK steel output at 130.6 Mt in 2025, 132.4 Mt in 2026 and 136.3 Mt in 2030.
Institutional analysis / pathway
OECD projects EU27 plus UK steel output at 130.6 Mt in 2025, 132.4 Mt in 2026 and 136.3 Mt in 2030.
- Source / locator
- S-010 · Table 2.2
- Canonical owner
- This steel sector flagship
- Limitation
- The combined geography and projection method differ from EUROFER's observed EU27 table.
- Prohibited inference
- Do not compare the combined forecast directly to EU27 observed output without stating the boundary difference.
C-044JRC finds multiple international low-carbon-steel definitions and initiatives rather than one universal threshold.
Institutional analysis / pathway
JRC finds multiple international low-carbon-steel definitions and initiatives rather than one universal threshold.
- Source / locator
- S-012 · comparative analysis and conclusions
- Canonical owner
- This steel sector flagship
- Limitation
- Definitions vary by boundary, scrap treatment, accounting and ambition.
- Prohibited inference
- Do not label a product green or near-zero without naming the applicable method and evidence.
C-045The Commission Steel and Metals Action Plan spans energy, lead markets, circularity, trade, investment and CBAM rather than treating CBAM as a standalone solution.
Official operations / data
The Commission Steel and Metals Action Plan spans energy, lead markets, circularity, trade, investment and CBAM rather than treating CBAM as a standalone solution.
- Source / locator
- S-007 · COM(2025)125 sections 2–6
- Canonical owner
- This steel sector flagship
- Limitation
- The Action Plan is a policy programme containing actions at different implementation states.
- Prohibited inference
- Do not describe every announced action as adopted law or delivered support.
C-046Industry steel-use data allocate 52% of global 2025 steel use to building and infrastructure.
Industry data
Industry steel-use data allocate 52% of global 2025 steel use to building and infrastructure.
- Source / locator
- S-001 · p. 30
- Canonical owner
- This steel sector flagship
- Limitation
- This is a global sector split, not EU downstream demand or CBAM scope.
- Prohibited inference
- Do not apply 52% to EU imports, certificate cost or a specific buyer portfolio.
C-047CBAM will save or destroy European steel.
Held — not claimed
CBAM will save or destroy European steel.
- Source / locator
- S-005, S-007, S-010 · No source establishes this binary causal conclusion
- Canonical owner
- This steel sector flagship — held ledger
- Limitation
- Steel outcomes depend on policy, technology, energy, input, demand and global-market conditions.
- Prohibited inference
- Do not publish a deterministic single-cause future claim.
C-048All announced near-zero steel projects will operate by 2030.
Held — not claimed
All announced near-zero steel projects will operate by 2030.
- Source / locator
- S-004 · pp. 1 and 5–7
- Canonical owner
- This steel sector flagship — held ledger
- Limitation
- JRC explicitly conditions the pathway on project realisation and a viable business case.
- Prohibited inference
- Do not convert announcements, aid or targets into operating capacity.
C-049Hydrogen DRI-EAF will be the single winning European route.
Held — not claimed
Hydrogen DRI-EAF will be the single winning European route.
- Source / locator
- S-003, S-004, S-020 · Route portfolios and constraints
- Canonical owner
- This steel sector flagship — held ledger
- Limitation
- Product needs, assets, power, hydrogen, scrap and regional conditions differ.
- Prohibited inference
- Do not make a universal technology or investment recommendation.
C-050Every EAF tonne is low-emission or circular steel.
Held — not claimed
Every EAF tonne is low-emission or circular steel.
- Source / locator
- S-002, S-003, S-011 · Route tables and intensity methodology
- Canonical owner
- This steel sector flagship — held ledger
- Limitation
- Metallic inputs and electricity emissions vary; EAF is a furnace route, not a verified product claim.
- Prohibited inference
- Do not use EAF as a universal emissions label.
C-051Europe has a quantified physical shortage of hydrogen for steel.
Held — not claimed
Europe has a quantified physical shortage of hydrogen for steel.
- Source / locator
- S-004 · announced-project demand pathway
- Canonical owner
- This steel sector flagship — held ledger
- Limitation
- The retained source quantifies conditional demand, not secured supply or a dated shortfall.
- Prohibited inference
- Do not subtract unrelated supply headlines to manufacture a shortage.
C-052Europe has a quantified shortage of usable steel scrap.
Held — not claimed
Europe has a quantified shortage of usable steel scrap.
- Source / locator
- S-002, S-003 · scrap trade and quality discussion
- Canonical owner
- This steel sector flagship — held ledger
- Limitation
- Volume, grade, contaminants, collection, price and product requirements are not one interchangeable balance.
- Prohibited inference
- Do not turn net exports into an immediately recoverable shortage figure.
C-053Country crude-steel output predicts CBAM liability or competitiveness.
Held — not claimed
Country crude-steel output predicts CBAM liability or competitiveness.
- Source / locator
- S-001, S-002, S-005 · country tables versus CBAM methodology
- Canonical owner
- This steel sector flagship — held ledger
- Limitation
- CBAM applies to covered imported goods and embedded emissions, not national crude output totals.
- Prohibited inference
- Do not create a country score from incomparable production and trade data.
C-054The downstream-CBAM proposal already covers all steel-containing goods.
Held — not claimed
The downstream-CBAM proposal already covers all steel-containing goods.
- Source / locator
- S-009, S-018 · procedure 2025/0419(COD)
- Canonical owner
- This steel sector flagship — held ledger
- Limitation
- The file remained a proposal at the research cut-off and contains a specific proposed code list.
- Prohibited inference
- Do not state proposed scope as current law.
C-055The OECD 745 Mt projection is a verified 2028 observation.
Held — not claimed
The OECD 745 Mt projection is a verified 2028 observation.
- Source / locator
- S-010 · Figure 1.1 note
- Canonical owner
- This steel sector flagship — held ledger
- Limitation
- The projection incorporates announced planned capacity and demand estimates.
- Prohibited inference
- Do not remove the projection label or scenario conditions.
C-056Implementing Regulation (EU) 2026/1457 distributed the replacement steel tariff quotas and applies from 1 July through 31 December 2026.
Adopted law
Implementing Regulation (EU) 2026/1457 distributed the replacement steel tariff quotas and applies from 1 July through 31 December 2026.
- Source / locator
- S-023 · Articles 1 and 6; Annexes I and II
- Canonical owner
- This steel sector flagship
- Limitation
- The implementing regulation has a six-month application period and should not be treated as a permanent unchanged quota distribution.
- Prohibited inference
- Do not infer current quota availability or company duty exposure without the applicable product category, origin and customs record.
C-057JRC reports a EUROFER projection of 81.5 MtCO2 in annual emissions reductions by 2030 from a 145 MtCO2 2023 baseline if the announced near-zero projects are completed.
Institutional analysis / pathway
JRC reports a EUROFER projection of 81.5 MtCO2 in annual emissions reductions by 2030 from a 145 MtCO2 2023 baseline if the announced near-zero projects are completed.
- Source / locator
- S-004 · p. 6, EUROFER-attributed project pathway
- Canonical owner
- This steel sector flagship
- Limitation
- This is a conditional industry projection reported in a JRC synthesis, not a JRC forecast or observed abatement.
- Prohibited inference
- Do not report 81.5 MtCO2 as achieved, guaranteed or attributable to CBAM alone.
C-058The May 2026 JRC INCITE report record describes approximately 17 Mt/year of direct-reduced-iron capacity across eight plants and about 35 Mt/year of new electric-arc-furnace capacity across sixteen plants for 2026–2030.
Institutional analysis / pathway
The May 2026 JRC INCITE report record describes approximately 17 Mt/year of direct-reduced-iron capacity across eight plants and about 35 Mt/year of new electric-arc-furnace capacity across sixteen plants for 2026–2030.
- Source / locator
- S-021 · JRC146558 publication-record abstract
- Canonical owner
- This steel sector flagship
- Limitation
- The JRC record describes a 2026–2030 deployment pipeline; its use of confirmed does not establish commissioning, utilisation, output or a complete live project-status inventory.
- Prohibited inference
- Do not report the pipeline tonnes as operating capacity, annual production or proof that all plants will run.
Source register
23 retained sources
Locator: pp. 8–30; major producers, routes, trade, use · Frozen evidence: S01-world-steel-in-figures-2026.pdf
Locator: pp. 11–16, 23, 37, 56–58 · Frozen evidence: S02-european-steel-in-figures-2026.pdf
S-003
Analysis of the EU Steel Supply Chain: Current Trends and Circularity Opportunities
European Commission Joint Research Centre · 2025
Locator: highlights; Figures 6, 10 and 12 · Frozen evidence: S03-jrc-eu-steel-supply-chain-2025.pdf
S-004
Mapping the Transition of the EU Steel Industry to Carbon Neutrality
European Commission Joint Research Centre · 24 February 2026
Locator: pp. 1, 2 and 5–7 · Frozen evidence: S04-jrc-steel-transition-factsheet-2026.pdf
S-005
Regulation (EU) 2023/956 establishing a carbon border adjustment mechanism — consolidated text
European Parliament and Council · consolidated to 20 October 2025
Locator: Articles 1, 7, 22 and 31; Annexes I and IV · Frozen evidence: eu-cbam-consolidated.txt
S-006
Regulation (EU) 2025/2083 simplifying and strengthening CBAM
European Parliament and Council · 8 October 2025
Locator: amendments to Regulation (EU) 2023/956 · Frozen evidence: eu-reg-2025-2083.txt
Locator: COM(2025) 125 final, sections 2–6 · Frozen evidence: eu-com-2025-125.txt
Locator: COM(2025) 783 final; Annex 4 data through Q2 2025 · Frozen evidence: eu-com-2025-783.txt
S-009
Proposal to extend CBAM to downstream goods and strengthen anti-circumvention
European Commission · 17 December 2025
Locator: COM(2025) 989 final; 2025/0419(COD) · Frozen evidence: eu-com-2025-989.txt
Locator: Executive summary; Figures 1.1 and 3.1–3.2; Table 2.2 · Frozen evidence: S10-oecd-steel-outlook-2026.pdf
S-011
Greenhouse Gas Intensities of the EU Steel Industry and Its Trading Partners
European Commission Joint Research Centre · 2022
Locator: methodology, route and country-intensity results · Frozen evidence: S11-jrc-steel-ghg-intensities-2022.pdf
S-012
Defining Low-Carbon Emissions Steel: A Comparative Analysis of International Initiatives
European Commission Joint Research Centre · 23 April 2025
Locator: comparative framework and conclusions · Frozen evidence: S12-jrc-low-carbon-steel-definitions-2025.pdf
S-013
Directive 2003/87/EC establishing the EU ETS — consolidated text
European Parliament and Council · consolidated to 1 March 2024
Locator: Article 10a(1a), CBAM factor · Frozen evidence: eu-ets-consolidated.txt
S-014
Implementing Regulation (EU) 2025/2620 on the CBAM free-allocation adjustment
European Commission · 2025
Locator: calculation rules and annexes · Frozen evidence: eu-reg-2025-2620.txt
S-015
Implementing Regulation (EU) 2025/2547 on calculation of embedded emissions
European Commission · 2025
Locator: monitoring methodology and precursor rules · Frozen evidence: eu-reg-2025-2547.txt
S-016
Regulation (EU) 2026/1384 addressing global steel overcapacity effects
European Parliament and Council · 17 June 2026
Locator: operative tariff-rate-quota regime and annexes · Frozen evidence: eu-reg-2026-1384.txt
S-017
Implementing Regulation (EU) 2026/846 amending the steel safeguard
European Commission · 9 April 2026
Locator: amendments to Implementing Regulation (EU) 2019/159 · Frozen evidence: eu-reg-2026-846.txt
S-018
Council moves to strengthen the EU carbon border adjustment mechanism
Council of the European Union · 12 June 2026
Locator: Council negotiating mandate; downstream proposal remains in procedure
S-019
Proposal revising the EU ETS for competitiveness and cost-effective decarbonisation
European Commission · 17 July 2026
Locator: COM(2026) 616 final · Frozen evidence: eu-com-2026-616.txt
Locator: technology, cost and standards sections
S-021
INCITE frontloading report for the Best Available Technique Reference document for iron and steel production
European Commission Joint Research Centre · 18 May 2026
Locator: JRC146558 publication-record abstract
Locator: iron and steel sector resources
S-023
Implementing Regulation (EU) 2026/1457 distributing steel tariff quotas
European Commission · 29 June 2026
Locator: Articles 1 and 6; Annexes I and II · Frozen evidence: eu-reg-2026-1457.txt
Decision FAQs
What the evidence can—and cannot—answer
Will CBAM save European steel?
The evidence does not support that binary conclusion. CBAM changes the treatment of covered imported emissions, but route viability also depends on assets, energy, hydrogen, scrap, ore, finance, demand and global market pressure.
Is all EAF steel low-carbon steel?
No. EAF emissions depend on electricity and metallic inputs; EAF does not reveal scrap share, DRI fuel or product-level verified emissions.
Will all announced green-steel plants run by 2030?
That is not supported. The JRC pathway is conditional on realisation and a business case. Track aid, FID, construction, commissioning and operation separately.
Does Europe have enough scrap?
The admitted data show consumption, trade and a conditional demand pathway, but not one interchangeable quality-adjusted balance. A universal shortage number is held.
Does Europe have enough hydrogen and electricity?
JRC quantifies conditional demand for the announced-project pathway. The retained evidence does not prove corresponding supply, grid access, storage or contracts.
Are downstream steel products already covered?
Only goods in the current Annex I scope are covered. The December 2025 downstream extension remained a proposal at the research cut-off.
Which country is best positioned?
No defensible cross-country score is produced. Country output, routes, electricity, projects and import exposure use different populations and periods.
Can I estimate my company's CBAM cost from these figures?
No. Use your goods, quantities, verified/default emissions, free-allocation adjustment and applicable price assumptions in the cost calculator; this article's country and route data are contextual.
What should I do first?
Confirm goods scope, map supplier/installations, identify the emissions and precursor evidence gaps, and separate current law from proposals before changing sourcing or contracts.