EU Steel and Metals Action Plan — COM(2025) 122 final

Mechanism

The Plan is a Communication — not a Regulation — so it operates as the overarching policy umbrella under which DG GROW, DG TRADE, DG CLIMA and DG ENER subsequently issue concrete instruments. The six work strands:

1. Affordable energy — temporary state-aid framework for energy-intensive industries (CISAF), grid build-out, support for long-term PPAs and industrial-scale electrification, alignment with the Action Plan for Affordable Energy presented the same week. 2. Trade defence & circularity — tightened steel safeguard from 1 April 2025 (operationalised by Reg. 2025/612 on 24 Mar 2025), a commitment to replace the safeguard with a "highly effective" long-term measure before its 30 June 2026 expiry, a forthcoming melt-and-pour rule of origin to close circumvention via third-country processing, scrap-export controls, and CRMA-aligned secondary-raw-materials policy. 3. Lead markets — Steel and Metals Industrial Decarbonisation Bank (EUR 100bn target), EUR 1bn pilot auction within the Innovation Fund in 2025, and "Made in EU" criteria in public and defence procurement. 4. Capacity & investment — EUR 150m through the Research Fund for Coal and Steel for 2026-27, EUR 600m via Horizon Europe partnerships, plus a revamped Innovation Fund with sectoral steel/aluminium windows. 5. Circularity & critical inputs — proposed CBAM extension to downstream steel and aluminium products by end-2025 (anti-circumvention against downstream-product rerouting), scrap-availability trade measures, Circular Economy Act in Q4 2026. 6. Skills & just transition — expanded European Globalisation Adjustment Fund coverage and reskilling envelopes for the affected workforce.

Downstream implications

• Sequencing: The 24 Mar 2025 EU steel safeguard tightening

(Reg. 2025/612) is the first concrete instrument under this Plan; the end-2025 CBAM downstream-products extension and the post-30 Jun 2026 successor safeguard are the two outstanding instruments expected to close the residual leakage routes.

• Trade flows: The melt-and-pour origin rule will materially reduce

the value of third-country processing of Chinese / Russian-origin semi-finished steel — affects flows via Türkiye, Vietnam, MENA hubs.

• Carbon-cost competitiveness: EUR 100bn Decarbonisation Bank target

is the supply-side counterpart to CBAM's import-side levelling; together they form the EU's response to the IRA-style Western industrial-policy build-out.

• ETF exposure: EU steelmakers (ArcelorMittal, ThyssenKrupp,

Voestalpine, SSAB, Aperam) and EU aluminium (Norsk Hydro, Aurubis) gain policy tailwind; non-EU exporters face progressively tighter access.

Open questions

• Detailed design of the post-30 Jun 2026 successor safeguard — the

Commission has committed to the principle but not the instrument (tariff-rate quota, pure quota, or hybrid).

• Scope of the CBAM downstream extension — which CN codes, what default

embedded-carbon values, how the credit mechanism for verified third- country carbon prices will work.

• Quantum and disbursement profile of the EUR 100bn Decarbonisation

Bank — currently a target, not a committed envelope.