Call for Evidence – ESPR Delegated Act on iron and steel products

Response to the Call for Evidence – Ecodesign for Sustainable Products Regulation Delegated Act on iron and steel products

Sirk Norge fully support integrating circularity criteria into key industrial product value chains, and therefore welcome the Commission's initiative to
establish ecodesign requirements for iron and steel products under the ESPR.

We urge the Commission to ensure that the definition of low-carbon steel includes high post-consumer recycled content to prevent primary material reliance. Only in this way public procurement rules can incentivize demand for secondary iron and steel. Defining low-carbon steel to align with public procurement targets will provide predictability in the market demand
which is needed for investments to enhance circularity infrastructure.

Harmonized and clear definitions for recycled content are essential to create a level playing field, prevent greenwashing, and drive market demand for post-consumer recycled metal. It is critical that regulatory frameworks clearly distinguish between pre-consumer production scrap and post-consumer waste, ensuring that market incentives directly support the collection and
recycling of end-of-life products from post-consumer waste.

We support the focus on substances and contaminants that hinder the recyclability of steel. To enhance scrap quality and boost secondary steel production, standards must incentivize high-quality sorting and de-contamination early in the waste value chain.

Digital Product Passports (DPP) can become a powerful enabler for secondary iron and steel. However, implementation must reflect operational realities in the recycling sector. Data requirements should target the start of the product life cycle (producers), while requirements for collectors and recyclers must focus on workable, batch-level reporting. Standardized and automated data flows are essential to avoid shifting disproportionate compliance costs onto the
recycling stage, ensuring resources are directed toward high-quality material recovery rather than administration.

Sirk Norge remains committed to providing technical expertise and data from the Norwegian recycling sector to assist the Commission in formulating effective delegated acts.