Invitation

1

Background note for the Fourth meeting of the Ministerial Alliance for Energy-

Intensive Industries

8th December 2025

At the second meeting of the Ministerial Alliance for Energy-Intensive Industries on the

18th of July, chaired by France, a joint declaration titled “Strengthening Europe’s energy -

intensive industries and securing our industrial future” was signed by ten Member States

(Austria, Czech Republic, France, Greece, Hungary, Italy, Luxembourg, Poland, Slovakia,

and Spain). The document highlights the following priorities regarding:

- European carbon markets: stability of the ETS carbon price and revision of CBAM;

- Energy: competitive prices and build a genuine Energy Union;

- Trade: risks of trade diversion from other regions towards the internal market,

promote a level-playing field, appropriate use of the EU toolbox in certain markets;

- Decarbonisation efforts: develop lead markets, sustainable, resilience and preference

criteria, notably in EU public procurement and financial support schemes, promote

circularity. Meeting the needs of industrial decarbonisation requires a balanced

approach that supports the use of technologies/solutions that bring us closer to

climate neutrality, taking into account economic, environmental and social factors.

- Investments: remove barriers to the internal market and create quality jobs.

During the third meeting held on 30 September 2025, chaired by Spain, the delegations of 17

Member States gathered to reflect on the needs of energy-intensive industries in the 2028-

2034 MFF, with a particular focus on the European Competitiveness Fund.

In these days, the European Commission is expected to publish several legislations and

policies that represent key steps to relaunch European competitiveness of energy intensive

industries and to support a sustainable transition:

 on 3rd December the “Economic Security Package” including the “RESource EU”;

 on 10th December:

1. the “Industrial Accelerator Act”,

2. the two proposals for the CBAM revision, including measures to effectively

address loopholes and provide concrete solutions to prevent downstream and

export carbon leakage, and to discourage resource shuffling practices.

As regards critical and strategic raw materials, RESource EU stands as a flagship initiative

for European strategic autonomy in the realm of critical raw materials with the aim of

securing access to alternative sources of materials for European industry. Main actions

include: (i) speeding up critical material partnerships with countries (Ukraine, Australia,

Canada, Kazakhstan, Uzbekistan or Chile), (ii) enhancing Europe’s domestic recycling

efforts, (iii) joint purchasing and stockpiling and (iv) boosting investment in strategic projects

for production and processing of critical raw materials.

Furthermore, the Commission recently announced the creation of the Critical Chemical

Alliance, to be convened for the first time in early January 2026. Its mandate will be to

develop criteria for identifying key chemical molecules and production sites that are

essential for maintaining Europe’s critical industrial capabilities, thereby paving the way for

targeted support and safeguard measures, and for the related legislative initiatives. The

Commission will draw on the work of the Alliance to outline a complex roadmap for

2

defining new strategic industrial policy directions for a sector facing the challenges of

transitioning to more sustainable and technologically advanced productions and molecules,

for which the appropriate industrial assets and reference markets need to be developed.

As regards the steel, aluminium and ferroalloys sectors, there is the need to ensure a

framework of fair conditions in international trade, technological neutrality for the clean

transition, competitive energy prices, and a framework that ensures the availability of scrap.

In view of the expiration of the steel safeguard measure in June 2026, the Commission

presented in October a new instrument to protect the EU steel sector from unfair impacts of

global overcapacity. We underline the importance of completing swiftly the legislative

process and setting an appropriate review mechanism, with the aim of ensuring that the

Regulation can be in place ahead of June 2026, when the current safeguard measure expires.

In addition, we welcome the decision to impose definitive safeguard measures on imports of

certain ferroalloys and encourage the European Commission to also consider implementing

trade protection on other products, such as silicon, in the coming months.

Within this context, an urgent issue concerns the introduction of restrictions on exports of

steel, copper, and aluminium scrap to protect European industry from achieving its

decarbonization goals. Scrap also plays a crucial role in reducing dependency on critical raw

materials and in supporting the circular economy and decarbonisation, thanks to the

significant energy and CO₂ savings enabled by recycling. Rising global demand has

increased prices and driven exports to non-EU countries, widening the gap between the EU’s

scrap needs and actual availability. This trend raises the risk of shortages of ferrous,

aluminium, and copper scrap, with potential disruptions to supply chains and to production

in strategic sectors.

It is therefore essential to adopt effective measures to address these shortages by recognising

the strategic importance of metal scrap, monitoring and limiting exports, and promoting the

development and use of high-quality secondary raw materials within the EU.

Finally, protection of EU market from unfair competition goes beyond the steel and

aluminium sectors, as now witnessed by the textile and the recycling of plastic sectors. EU’s

strong focus on product regulation, that will be strengthened by the implementation of the

Ecodesign regulation, combined with the lower energy costs and environmental standards in

many geographical areas, could result in endangering EU market integrity, competitiveness,

consumer’s safety and to disrupt recycling industry. Reaching the European goals in this

field implies a substantial strengthen of market surveillance, to ensure that all products sold

in the EU, included those that are imported, are safe, and sustainable, and compliant with

EU requirements. However, a reality check of targets set by relevant EU acts should be run,

taking account of current technical and economic capabilities.

Ministers/Representatives of the Members of the Alliance are invited to express their views

on the above mentioned topics, choosing one or more of the following questions:

1. What are your first reactions to the RESource EU plan? Are there any key points

missing?

2. In light of the already presented safeguard measures on steel and ferroalloys, what

additional actions could be taken to protect EU industries from products that do

3

not comply with Union standards and that create market distortions, as seen in

sectors such as plastics and textiles?

3. The European Commission is considering restrictions on scraps exports: how do

you assess the situation in your country, and what measures should be taken at EU

level?

1

Background note for the Fourth meeting of the Ministerial Alliance for Energy-

Intensive Industries

8th December 2025

At the second meeting of the Ministerial Alliance for Energy-Intensive Industries on the

18th of July, chaired by France, a joint declaration titled “Strengthening Europe’s energy -

intensive industries and securing our industrial future” was signed by ten Member States

(Austria, Czech Republic, France, Greece, Hungary, Italy, Luxembourg, Poland, Slovakia,

and Spain). The document highlights the following priorities regarding:

- European carbon markets: stability of the ETS carbon price and revision of CBAM;

- Energy: competitive prices and build a genuine Energy Union;

- Trade: risks of trade diversion from other regions towards the internal market,

promote a level-playing field, appropriate use of the EU toolbox in certain markets;

- Decarbonisation efforts: develop lead markets, sustainable, resilience and preference

criteria, notably in EU public procurement and financial support schemes, promote

circularity. Meeting the needs of industrial decarbonisation requires a balanced

approach that supports the use of technologies/solutions that bring us closer to

climate neutrality, taking into account economic, environmental and social factors.

- Investments: remove barriers to the internal market and create quality jobs.

During the third meeting held on 30 September 2025, chaired by Spain, the delegations of 17

Member States gathered to reflect on the needs of energy-intensive industries in the 2028-

2034 MFF, with a particular focus on the European Competitiveness Fund.

In these days, the European Commission is expected to publish several legislations and

policies that represent key steps to relaunch European competitiveness of energy intensive

industries and to support a sustainable transition:

 on 3rd December the “Economic Security Package” including the “RESource EU”;

 on 10th December:

1. the “Industrial Accelerator Act”,

2. the two proposals for the CBAM revision, including measures to effectively

address loopholes and provide concrete solutions to prevent downstream and

export carbon leakage, and to discourage resource shuffling practices.

As regards critical and strategic raw materials, RESource EU stands as a flagship initiative

for European strategic autonomy in the realm of critical raw materials with the aim of

securing access to alternative sources of materials for European industry. Main actions

include: (i) speeding up critical material partnerships with countries (Ukraine, Australia,

Canada, Kazakhstan, Uzbekistan or Chile), (ii) enhancing Europe’s domestic recycling

efforts, (iii) joint purchasing and stockpiling and (iv) boosting investment in strategic projects

for production and processing of critical raw materials.

Furthermore, the Commission recently announced the creation of the Critical Chemical

Alliance, to be convened for the first time in early January 2026. Its mandate will be to

develop criteria for identifying key chemical molecules and production sites that are

essential for maintaining Europe’s critical industrial capabilities, thereby paving the way for

targeted support and safeguard measures, and for the related legislative initiatives. The

Commission will draw on the work of the Alliance to outline a complex roadmap for

2

defining new strategic industrial policy directions for a sector facing the challenges of

transitioning to more sustainable and technologically advanced productions and molecules,

for which the appropriate industrial assets and reference markets need to be developed.

As regards the steel, aluminium and ferroalloys sectors, there is the need to ensure a

framework of fair conditions in international trade, technological neutrality for the clean

transition, competitive energy prices, and a framework that ensures the availability of scrap.

In view of the expiration of the steel safeguard measure in June 2026, the Commission

presented in October a new instrument to protect the EU steel sector from unfair impacts of

global overcapacity. We underline the importance of completing swiftly the legislative

process and setting an appropriate review mechanism, with the aim of ensuring that the

Regulation can be in place ahead of June 2026, when the current safeguard measure expires.

In addition, we welcome the decision to impose definitive safeguard measures on imports of

certain ferroalloys and encourage the European Commission to also consider implementing

trade protection on other products, such as silicon, in the coming months.

Within this context, an urgent issue concerns the introduction of restrictions on exports of

steel, copper, and aluminium scrap to protect European industry from achieving its

decarbonization goals. Scrap also plays a crucial role in reducing dependency on critical raw

materials and in supporting the circular economy and decarbonisation, thanks to the

significant energy and CO₂ savings enabled by recycling. Rising global demand has

increased prices and driven exports to non-EU countries, widening the gap between the EU’s

scrap needs and actual availability. This trend raises the risk of shortages of ferrous,

aluminium, and copper scrap, with potential disruptions to supply chains and to production

in strategic sectors.

It is therefore essential to adopt effective measures to address these shortages by recognising

the strategic importance of metal scrap, monitoring and limiting exports, and promoting the

development and use of high-quality secondary raw materials within the EU.

Finally, protection of EU market from unfair competition goes beyond the steel and

aluminium sectors, as now witnessed by the textile and the recycling of plastic sectors. EU’s

strong focus on product regulation, that will be strengthened by the implementation of the

Ecodesign regulation, combined with the lower energy costs and environmental standards in

many geographical areas, could result in endangering EU market integrity, competitiveness,

consumer’s safety and to disrupt recycling industry. Reaching the European goals in this

field implies a substantial strengthen of market surveillance, to ensure that all products sold

in the EU, included those that are imported, are safe, and sustainable, and compliant with

EU requirements. However, a reality check of targets set by relevant EU acts should be run,

taking account of current technical and economic capabilities.

Ministers/Representatives of the Members of the Alliance are invited to express their views

on the above mentioned topics, choosing one or more of the following questions:

1. What are your first reactions to the RESource EU plan? Are there any key points

missing?

2. In light of the already presented safeguard measures on steel and ferroalloys, what

additional actions could be taken to protect EU industries from products that do

3

not comply with Union standards and that create market distortions, as seen in

sectors such as plastics and textiles?

3. The European Commission is considering restrictions on scraps exports: how do

you assess the situation in your country, and what measures should be taken at EU

level?