CBAM Pulse
Institutional analysis / pathwaySector flagship · Published

The Future of European Steel Under CBAM

A country-by-country, route-by-route map of the evidence, physical constraints and policy decisions shaping Europe's steel transition.

This report separates observed and industry-reported data, adopted law, proposals, institutional pathways and held conclusions. It does not predict one winning technology, one steel price or one inevitable European outcome.

Research cut-off

12 August 2026

Retained sources

23

Atomic claims

58

Publication state

Published

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.

QuestionCanonical ownerTreatment here
Which steel CN codes are covered?Iron and steel sectorCompact boundary and link; no copied code list.
What did transitional Registry data show?CBAM by the NumbersNo repeated origin/emissions dashboard.
What is CBAM's dated overall state?State of CBAM 2026Only steel-specific status needed for the route decision.
What do macro models say about Europe?Economic impact reportNo 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 guideStrategic interaction only; no factor schedule.
What should a fastener buyer do?Steel-fastener buyer guideOne 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?

2008
236 Mt
78.4%
2009
233 Mt
55.5%
2010
236 Mt
69.1%
2011
233 Mt
72.1%
2012
229 Mt
69.4%
2013
225 Mt
68.6%
2014
224 Mt
70.1%
2015
223 Mt
69.6%
2016
222 Mt
69.5%
2017
219 Mt
73.5%
2018
219 Mt
73.1%
2019
216 Mt
69.6%
2020
213 Mt
62.1%
2021
213 Mt
71.7%
2022
213 Mt
64.0%
2023
210 Mt
60.1%
2024
198 Mt
65.4%
2025
194 Mt
64.8%
Accessible table: all 18 annual values
YearOperating capacity, MtUtilisation
200823678.4%
200923355.5%
201023669.1%
201123372.1%
201222969.4%
201322568.6%
201422470.1%
201522369.6%
201622269.5%
201721973.5%
201821973.1%
201921669.6%
202021362.1%
202121371.7%
202221364.0%
202321060.1%
202419865.4%
202519464.8%

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?

Austria7,553 kt
Belgium7,048 kt
Bulgaria466 kt
Croatia kt
Czech Republic2,503 kt
Finland3,742 kt
France9,916 kt
Germany34,090 kt
Greece1,342 kt
Hungary kt
Italy20,733 kt
Luxembourg1,822 kt
Netherlands6,483 kt
Others2,090 kt
Poland7,186 kt
Romania850 kt
Slovakia3,612 kt
Slovenia602 kt
Spain11,778 kt
Sweden3,976 kt

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 row2021, kt2022, kt2023, kt2024, kt2025, kt2025 share
Austria7,8847,5127,1337,1307,5536.0%
Belgium6,9097,0305,8647,1357,0485.6%
Bulgaria5484824894504660.4%
Croatia1851692121530.0%
Czech Republic4,7884,2623,3692,5482,5032.0%
Finland4,3403,5383,8113,6643,7423.0%
France13,94712,23410,01110,7539,9167.9%
Germany40,24136,86035,39537,23434,09027.1%
Greece1,4981,5431,1811,3361,3421.1%
Hungary1,1008574772320.0%
Italy24,41221,59921,05520,00720,73316.5%
Luxembourg2,0731,8751,9001,8251,8221.4%
Netherlands6,6206,1434,6776,3956,4835.2%
Others1,9531,8552,0401,9482,0901.7%
Poland8,4547,4076,4287,1137,1865.7%
Romania3,3752,6251,6221,3648500.7%
Slovakia4,8633,8724,3773,8663,6122.9%
Slovenia7016235595986020.5%
Spain14,23411,46411,35211,83211,7789.4%
Sweden4,6574,3824,2354,0023,9763.2%
EU27 printed total152,782136,332126,186129,586125,792100%

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?

01
China
960.8 Mt
02
India
164.9 Mt
03
United States
81.9 Mt
04
Japan
80.7 Mt
05
Russia
67.9 Mt
06
South Korea
62.2 Mt
07
Türkiye
38.1 Mt
08
Germany
34.1 Mt
09
Brazil
33.4 Mt
10
Iran
32.0 Mt
11
Viet Nam
24.7 Mt
12
Italy
20.7 Mt
13
Indonesiae
19.0 Mt
14
Taiwan, China
17.2 Mt
15
Mexico
13.5 Mt
16
Spain
11.8 Mt
17
Canada
11.5 Mt
18
Saudi Arabia
10.8 Mt
19
Egypt
10.6 Mt
20
France
9.9 Mt
21
Malaysia
7.7 Mt
22
Austria
7.6 Mt
23
Ukraine
7.4 Mt
24
Belgium
7.2 Mt
25
Poland
7.2 Mt
26
Netherlands
6.5 Mt
27
Algeria
5.5 Mt
28
Australia
5.2 Mt
29
Thailand
5.1 Mt
30
Bangladeshe
4.5 Mt
31
South Africa
4.5 Mt
32
Kazakhstan
4.3 Mt
33
Argentina
4.0 Mt
34
Sweden
4.0 Mt
35
United Arab Emirates
3.8 Mt
36
Finland
3.7 Mt
37
Slovakia
3.6 Mt
38
Pakistan
3.6 Mt
39
Iraq
3.0 Mt
40
Oman
3.0 Mt
41
United Kingdom
2.6 Mt
42
Czechia
2.5 Mt
43
Portugal
2.1 Mt
44
Luxembourg
1.8 Mt
45
Belaruse
1.8 Mt
46
Kenyae
1.8 Mt
47
Philippinese
1.8 Mt
48
Qatar
1.7 Mt
49
Peru
1.6 Mt
50
Morocco
1.5 Mt
51
Others
22.5 Mt
Accessible table: all 50 countries plus Others
Published row2025, Mt2024, MtStatus
China960.81,005.1Reported
India164.9149.4Reported
United States81.979.5Reported
Japan80.784.0Reported
Russia67.971.0Reported
South Korea62.263.6Reported
Türkiye38.136.9Reported
Germany34.137.3Reported
Brazil33.433.9Reported
Iran32.031.4Reported
Viet Nam24.722.0Reported
Italy20.720.0Reported
Indonesia19.018.6Estimate
Taiwan, China17.219.2Reported
Mexico13.514.3Reported
Spain11.811.9Reported
Canada11.512.3Reported
Saudi Arabia10.89.6Reported
Egypt10.610.7Reported
France9.910.8Reported
Malaysia7.79.0Reported
Austria7.67.1Reported
Ukraine7.47.6Reported
Belgium7.27.1Reported
Poland7.27.1Reported
Netherlands6.56.4Reported
Algeria5.54.5Reported
Australia5.24.7Reported
Thailand5.14.9Reported
Bangladesh4.54.5Estimate
South Africa4.54.7Reported
Kazakhstan4.34.2Reported
Argentina4.03.9Reported
Sweden4.04.0Reported
United Arab Emirates3.83.7Reported
Finland3.73.7Reported
Slovakia3.63.9Reported
Pakistan3.64.1Reported
Iraq3.03.0Reported
Oman3.03.0Reported
United Kingdom2.64.0Reported
Czechia2.52.5Reported
Portugal2.11.9Reported
Luxembourg1.81.8Reported
Belarus1.82.3Estimate
Kenya1.81.8Estimate
Philippines1.81.8Estimate
Qatar1.71.2Reported
Peru1.61.5Reported
Morocco1.51.4Reported
Others22.523.8Reported
Published world total1,848.91,886.8Source 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?

2016EAF 40.7%
2017EAF 41.6%
2018EAF 42.6%
2019EAF 42.3%
2020EAF 43.9%
2021EAF 43.5%
2022EAF 43.2%
2023EAF 44.7%
2024EAF 44.6%
2025EAF 45.8%
BOF and otherEAF
YearBOF/other, ktEAF, ktPrinted total, kt
201691,48962,809154,298
201793,92866,941160,869
201891,93768,129160,066
201986,65563,589150,244
202074,18958,018132,217
202186,26166,521152,782
202277,38958,943136,332
202369,72956,457126,186
202471,77557,812129,586
202568,23957,552125,791

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?

Current total electricity use75 TWh/yr
Current grid purchases55 TWh/yr
Direct power for announced plants75 TWh/yr
Electrolysis power for 2.12 Mt H₂90 TWh/yr
Total fossil-free power pathway165 TWh/yr
QuantityValueEvidence status
Current total electricity use75 TWh/yearObserved/synthesised baseline
Current grid purchases55 TWh/yearSubset of current total
Direct power for announced plants75 TWh/yearConditional pathway
Electrolysis power for 2.12 Mt H₂90 TWh/yearConditional pathway
Total fossil-free power pathway165 TWh/year75 + 90; not plus current 75
Hydrogen associated with pathway2.12 Mt/yearIf 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?

2016
85,818 kt
2017
90,882 kt
2018
88,459 kt
2019
83,787 kt
2020
75,255 kt
2021
87,852 kt
2022
79,340 kt
2023
75,183 kt
2024
76,648 kt
2025
74,424 kt
YearConsumptionImportsExportsPrinted net exports
201685,8184,46711,7147,246
201790,8824,91813,4108,492
201888,4594,55015,12210,572
201983,7874,26815,57911,311
202075,2554,12217,44613,324
202187,8525,52219,43013,907
202279,3403,95117,61213,661
202375,1833,89718,73814,842
202476,6484,74115,61810,876
202574,4244,79716,30911,511

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.

YearEvidence statusExcess capacityContract
2025OECD estimate640 MtRecord 2,445 Mt capacity; demand measure stated by OECD
2028OECD projection745 MtAnnounced 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?

Türkiye2,0444,815 kt
South Korea2,5233,345 kt
Indonesia882,636 kt
China, P. Republic5,2492,576 kt
India1,8222,411 kt
Ukraine2,9422,211 kt
Taiwan7051,949 kt
Vietnam451,869 kt
Africa2221,780 kt
United Kingdom2,0391,316 kt
Others9,0194,819 kt
20162025
Origin row2016, kt2025, ktChange, kt
Türkiye2,0444,8152,771
South Korea2,5233,345822
Indonesia882,6362,548
China, P. Republic5,2492,576-2,673
India1,8222,411589
Ukraine2,9422,211-731
Taiwan7051,9491,244
Vietnam451,8691,824
Africa2221,7801,558
United Kingdom2,0391,316-723
Others9,0194,819-4,200
Printed total26,69829,7273,029

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

LayerStatus at 12 August 2026Steel decisionBoundary
CBAM RegulationAdopted lawCovered goods, embedded-emissions evidence and certificate obligations.Only Annex I goods; use the goods checker and official text.
EU ETS / free-allocation adjustmentAdopted lawLinks import adjustment to equivalent EU free allocation.Detailed factor schedule belongs to the canonical phase-in guide.
Steel and Metals Action PlanOfficial operations / dataEnergy, 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 regimeAdopted lawRegulation 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 extensionProposal — not lawCould change exposure for selected steel-intensive downstream goods.Procedure 2025/0419(COD); proposed application from 2028 can change.
July 2026 ETS revisionProposal — not lawPotential 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

SignalMinimum fieldsUpdate triggerFalse shortcut
Asset decisionInstallation, route, product, reline/retirement dateOwner-confirmed schedule changeAverage fleet age predicts this plant
Project stateAnnouncement, aid, FID, construction, commissioning, operationNew dated primary evidenceAll pipeline tonnes are future output
ElectricityQuantity, profile, connection, source treatment, price periodContract or grid milestoneNational renewable share proves project supply
HydrogenDelivery point, quantity, production route, carbon method, priceContract, FID or operationHydrogen-ready means hydrogen-fuelled
ScrapGrade, contaminants, yield, price, volume, locationContract or quality changeNet exports equal available feedstock
DR ore/pelletsSpecification, origin, capacity, contract and logisticsSupply agreement or project changeIron-ore import volume proves DR quality
DemandBuyer, product, volume, term, price and qualificationExecuted contract or deliveryMoU equals bankable offtake
PolicyDocument, status, operative date, product scopeOfficial Journal or procedure milestoneCommission 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.”

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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.

  1. Freeze: material PDFs and page text were retained locally with checksums where retrieval allowed.
  2. Classify: adopted law, official operations, proposal, institutional pathway, industry data and held conclusion remain separate.
  3. Atomise: every material claim records a source, locator, limitation, prohibited inference and canonical owner.
  4. Reconcile: complete printed populations are reproduced; dashes, aggregates and rounding differences remain visible.
  5. 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-001

CBAM applies only to the iron and steel goods listed in Annex I, not to every steel-containing downstream product.

Adopted law
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-002

Ferrous waste and scrap under CN 7204 is excluded from the Annex I iron-and-steel chapter listing.

Adopted law
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-003

CBAM certificate surrender is adjusted to reflect EU ETS free allocation for equivalent EU production.

Adopted law
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-004

EU ETS free allocation for CBAM goods is multiplied by a declining CBAM factor under the adopted ETS Directive.

Adopted law
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-005

The 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
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-006

The proposed downstream extension was designed to apply from 1 January 2028 if adopted in the proposed form.

Proposal — not law
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-007

The Commission proposal describes around 180 additional CN codes and an estimated 7,500 additional importers.

Proposal — not law
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-008

Regulation (EU) 2026/1384 is adopted steel trade law, distinct from CBAM and the earlier safeguard.

Adopted law
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-009

The April 2026 implementing regulation amended the pre-existing definitive steel safeguard, which expired after 30 June 2026.

Adopted law
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-010

The July 2026 ETS revision file is a Commission proposal, not current ETS law.

Proposal — not 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-011

EU crude-steel output in the EUROFER table totalled 125.792 Mt in 2025.

Industry data
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-012

Germany represented 34.090 Mt, or 27.1%, of the 2025 EU total in that country table.

Industry data
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-013

The source discloses 19 country rows plus an Others aggregate rather than 27 individual EU values.

Industry data
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-014

EU operating crude-steel capacity fell from 236 Mt in 2008 to 194 Mt in 2025 in EUROFER's series.

Industry data
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-015

EU capacity utilisation was 64.8% in 2025 in EUROFER's series.

Industry data
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-016

EU 2025 crude output split 54.2% BOF/other and 45.8% EAF in EUROFER's table.

Industry data
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-017

The JRC describes the EU's 2024 production split as roughly 55% BF-BOF and 45% EAF.

Institutional analysis / pathway
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-018

The EU blast-furnace fleet averaged about 50 years and 25% had operated for over 60 years in the JRC synthesis.

Institutional analysis / pathway
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-019

JRC reports that almost half of EU blast furnaces are set to retire before 2035.

Institutional analysis / pathway
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-020

World crude-steel output was 1,848.9 Mt in 2025 in worldsteel's country table.

Industry data
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-021

China produced 960.8 Mt and India 164.9 Mt in worldsteel's 2025 country table.

Industry data
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-022

EUROFER's 2025 all-qualities import-origin table totals 29.727 Mt.

Industry data
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-023

Türkiye was the largest named origin row in that 2025 table at 4.815 Mt.

Industry data
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-024

The same table reports 2.636 Mt from Indonesia in 2025 versus 0.088 Mt in 2016.

Industry data
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-025

EU scrap consumption was 74.424 Mt in 2025 in EUROFER's series.

Industry data
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-026

EU scrap imports were 4.797 Mt and exports 16.309 Mt in 2025.

Industry data
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-027

Published 2025 EU net scrap exports were 11.511 Mt; gross-flow subtraction differs by one thousand tonnes because of rounding.

Industry data
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-028

JRC estimates EU import reliance of 77% for iron ore in its 2024 supply-chain assessment.

Institutional analysis / pathway
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-029

JRC reports that around 75% of EU iron-ore and coking-coal supply comes from extra-EU sources.

Institutional analysis / pathway
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-030

JRC's 2035 announced-capacity estimate shifts EU carbon-steel capacity toward 32% BF-BOF, 50% scrap-EAF and 18% DRI-EAF.

Institutional analysis / pathway
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-031

JRC 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
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-032

JRC reports H2-DRI-EAF at TRL 6–8 with an average abatement-cost range of EUR 122–171 per tonne CO2.

Institutional analysis / pathway
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-033

JRC reports scrap-EAF production costs 35–68% above BF-BOF in the cited comparison.

Institutional analysis / pathway
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-034

JRC identifies natural-gas DRI-EAF as a bridge configuration until sufficient hydrogen is available.

Institutional analysis / pathway
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-035

JRC states that state-of-the-art DRI plants can be hydrogen-ready.

Institutional analysis / pathway
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-036

JRC reports current EU steel electricity use of 75 TWh/year, including 55 TWh purchased from the grid.

Institutional analysis / pathway
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-037

Running 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
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-038

Producing 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
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-039

JRC 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
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-040

OECD estimated global excess steel capacity at 640 Mt in 2025.

Institutional analysis / pathway
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-041

OECD projects global excess capacity could reach 745 Mt by 2028.

Institutional analysis / pathway
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-042

OECD reports global 2025 steelmaking capacity at a record 2,445 Mt and demand contraction for a fourth year.

Institutional analysis / pathway
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-043

OECD 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
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-044

JRC finds multiple international low-carbon-steel definitions and initiatives rather than one universal threshold.

Institutional analysis / pathway
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-045

The 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
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-046

Industry steel-use data allocate 52% of global 2025 steel use to building and infrastructure.

Industry data
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-047

CBAM will save or destroy European steel.

Held — not claimed
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-048

All announced near-zero steel projects will operate by 2030.

Held — not claimed
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-049

Hydrogen DRI-EAF will be the single winning European route.

Held — not claimed
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-050

Every EAF tonne is low-emission or circular steel.

Held — not claimed
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-051

Europe has a quantified physical shortage of hydrogen for steel.

Held — not claimed
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-052

Europe has a quantified shortage of usable steel scrap.

Held — not claimed
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-053

Country crude-steel output predicts CBAM liability or competitiveness.

Held — not claimed
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-054

The downstream-CBAM proposal already covers all steel-containing goods.

Held — not claimed
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-055

The OECD 745 Mt projection is a verified 2028 observation.

Held — not claimed
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-056

Implementing Regulation (EU) 2026/1457 distributed the replacement steel tariff quotas and applies from 1 July through 31 December 2026.

Adopted law
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-057

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.

Institutional analysis / pathway
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-058

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.

Institutional analysis / pathway
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

S-001

World Steel in Figures 2026

World Steel Association · 2026

Industry-reported statistics

Locator: pp. 8–30; major producers, routes, trade, use · Frozen evidence: S01-world-steel-in-figures-2026.pdf

S-002

European Steel in Figures 2026

EUROFER · 2026

Industry-reported statistics

Locator: pp. 11–16, 23, 37, 56–58 · Frozen evidence: S02-european-steel-in-figures-2026.pdf

S-010

OECD Steel Outlook 2026

OECD · 2026

Institutional projection

Locator: Executive summary; Figures 1.1 and 3.1–3.2; Table 2.2 · Frozen evidence: S10-oecd-steel-outlook-2026.pdf

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.