What emissions threshold does steel have to meet to be EU Taxonomy aligned?

Under activity 3.9 of the EU Climate Delegated Act, each process step must stay below a fixed value per tonne of product: for example 1.331 t CO2e for hot metal and 0.209 t CO2e for EAF carbon steel. An electric arc furnace can pass instead with at least 90% scrap input, or 70% for high alloy steel.

The values in activity 3.9

These are the values in the consolidated text of Delegated Regulation (EU) 2021/2139, Annex I, section 3.9, as checked in October 2026. Earlier versions of the act carried different figures, so test a plant against the version that applies to your reporting year.

• Hot metal: 1.331 t CO2e per tonne of product.
• Sintered ore: 0.163 t CO2e per tonne.
• Coke, excluding lignite coke: 0.144 t CO2e per tonne.
• Iron casting: 0.299 t CO2e per tonne.
• EAF high alloy steel: 0.266 t CO2e per tonne; EAF carbon steel: 0.209 t CO2e per tonne.
• Alternative for EAF: steel scrap input relative to product output of at least 90% for carbon steel or 70% for high alloy steel.

Why most Indian plants do not pass on CO2

The values are set at the level of the best performing EU installations. A blast furnace plant needs every step it runs below its value, not an average across the plant. Coal based DRI, common in India, has no value of its own in the table, so agree with the buyer or financier how a DRI and EAF route will be assessed before you run numbers. Scrap based EAF plants are the most likely to pass, through either the emission value or the scrap share.

Make the comparison on the same boundary

1. Use the boundary the values are built on, the EU ETS product benchmark definition for each product; check it before comparing a figure that includes purchased electricity.
2. Measure per tonne of the named product, not per tonne of finished steel or of all output.
3. Use one year of measured data, not design values.
4. Remember the threshold is only one test: the activity must also meet the DNSH criteria and minimum safeguards.

How this differs from CBAM default values

CBAM default values in Implementing Regulation (EU) 2025/2621 price the embedded emissions of an imported good when actual data is missing. They are a cost rule, not a pass or fail test. A plant can beat the CBAM default for India and still be far above the Taxonomy value.

Worked example: a scrap based EAF plant making carbon steel

• Crude steel output: 100,000 tonnes; scrap charged: 92,000 tonnes
• Scrap share: 92,000 / 100,000 = 92%, above 90%, so the scrap route passes
• Direct emissions on the benchmark boundary: 18,000 t CO2e; intensity 18,000 / 100,000 = 0.18 t CO2e per tonne, also below 0.209
• Next: check DNSH and minimum safeguards before calling it aligned

Plant figures are illustrative. Threshold values from Annex I, section 3.9, as consolidated in October 2026; check for amending acts.

What Senseible does here

Senseible computes Scope 1 fuel and Scope 2 electricity emissions from a supplier's invoices and bills, which with production tonnes give an intensity you can set against the published value. It does not decide Taxonomy alignment; for EU import cost, use the CBAM calculator.

• Benchmarking a steel supplier's intensity
• CBAM cost calculator
• EU Taxonomy do no significant harm
• Steel industry

Sources: Commission Delegated Regulation (EU) 2021/2139, Annex I, section 3.9 Manufacture of iron and steel, on EUR-Lex, Implementing Regulation (EU) 2025/2621 (CBAM default values)

Last reviewed 2026-10-17. The Commission consulted on revising the Taxonomy delegated acts in 2026, including ETS-based steel thresholds; recheck Annex I, section 3.9, for amendments.