Comments on the proposal for a European Climate Law

To the European Commission
Jernkontoret d-nr: 29/20

Jernkontoret, the Swedish steel producers' association, comments on the proposal for an EU Climate Law. Jernkontoret also support the contribution from Eurofer.

Setting a long-term target, such as the proposed climate neutrality 2050, gives the opportunity to development and deployment of new technologies in a resource efficient and economically feasible way. Such a target must work in parallel with economic growth both to have a chance to succeed and for EU to be an example for other countries. The development of ambitions by all signatories of the Paris agreement need to be taken into account in EU's climate law and related legislation to retain a sustainable development with a global perspective. Policies and measures to reach the target needs specifically to take account for effects on international competitiveness and long-term profitability of European industry.

Swedish steel industry has developed a climate roadmap describing technical possibilities and needed supportive conditions to reach net zero GHG emission 2045, being the Swedish climate target. The major solution to decrease GHG emissions in steel industry, and other sectors, is electrification. Access to fossil free electricity to competitive cost is thus an important enabler. The second main enabler is long term support for research and development. Emission elimination need development and deployment of new technologies.

Ambitious activities have already started in the steel industry such as research on using hydrogen as reducing agent for iron making, hydrogen as heating fuel in steel processing and development of biobased raw materials and energy. Climate policies should focus on supporting and enabling measures to continue this positive development.

For industries that 1) need to develop new breakthrough technologies (R&D&I) and 2) need to adjust implementation of new technology to investment cycles (resource efficiency) the emission reductions will be a stepwise development. Thus, the assessment of Union progress and national measures as well as the setting of a trajectory for the progress towards the target need also to consider sector specificities and roadmaps to take account for non-linear development. Jernkontoret would like to stress that using simple linear models for emission reduction as a base for policy measures may counteract ambitious efforts by industrial companies and thus slow down the transition.

Concerning the review of the 2030 target and the proposed setting of a trajectory with review every five years it is important that this is decisions taken by the member states to ensure the collective responsibility among all member states.

Jernkontoret

Bo-Erik Pers, CEO

Helén Axelsson, Senior Advisor