Green Steel Labels: Which Ones Matter?

In an era where industrial carbon dioxide emissions drive both environmental and regulatory headlines, steel has moved to the forefront as one of the world’s most polluting sectors. The steel industry is responsible for over 7% of worldwide CO₂ emissions—roughly the equivalent of all global road freight and aviation combined. Decarbonizing steel supply chains isn’t just a sustainability ambition—it’s becoming mission-critical for manufacturers, construction firms, automakers, and public sector procurers who must meet rapidly evolving green mandates.

This urgency has catapulted green steel “labels” into the limelight. But what really distinguishes a meaningful label from mere marketing? How can procurement teams, engineers, and sustainability leads ensure the steel they buy genuinely advances their climate goals, delivers value, and safeguards against mounting regulatory risks?

This in-depth tactical guide will demystify green steel labels, outline criteria for effective decarbonization, and present actionable strategies to future-proof your organization—blending industry realities, forward-looking trends, and practical decision-making frameworks.

Table of Contents

1. What Is Green Steel?

2. Why Steel Labels Are Crucial for Decarbonization

3. A Deep Dive: How Green Steel Is Produced

4. The Green Steel Label Landscape

   • ISO 14040/44 and LCAs

   • ResponsibleSteel™

   • EPDs (Environmental Product Declarations)

   • XCarb®, VERDE, and Proprietary Labels

5. Selecting the Right Label: What Really Matters?

6. Cost, Risk, and Compliance: The Decision Matrix

7. Actionable Tactics: Decarbonize Without Compromising

8. FAQs About Green Steel Labels

9. Conclusion: The Path to Low-Carbon Steel Operations

1. What Is Green Steel?

Green steel broadly refers to steel products manufactured via processes that drastically lower or eliminate carbon emissions compared to the conventional blast furnace-basic oxygen furnace (BF-BOF) route. While traditional blast furnaces rely on coal, green steel leans on breakthrough technologies and alternative materials to achieve net-zero goals.

Key Green Steel Production Pathways:

• Electric Arc Furnace (EAF): Utilizes recycled steel scrap and electricity (ideally, from renewables) to melt and reform steel, slashing both emissions and energy use.

• Hydrogen-based Direct Reduced Iron (H₂-DRI): Substitutes coal or natural gas for green hydrogen as a reductant, drastically curtailing CO₂ output during ironmaking.

• Carbon Capture, Utilization, and Storage (CCUS): Applies advanced capture technologies to trap emissions for re-use or secure storage, mitigating the climate impact of conventional and “transition” approaches.

• Innovative Zero-Carbon Methods: Start-ups are piloting molten oxide electrolysis (such as Boston Metal’s process), biocarbon feedstocks, and other next-generation solutions close to commercial scale.

However, the term “green” in steel is not yet standardized—raising player skepticism and regulatory scrutiny. This is where scientifically credible ecolabels become essential to cut through corporate greenwashing and ensure real decarbonization.

2. Why Steel Labels Are Crucial for Decarbonization

As businesses increasingly anchor climate targets in their procurement, carbon transparency and verification have transitioned from “nice-to-haves” to absolute requirements. For the steel industry—which constitutes roughly 30% of all industrial emissions—green labels serve as verified proof points for:

• Validating Emission Reductions: Procurement and sustainability teams use trusted labels to confirm reductions in embodied carbon, providing assurance to investors, clients, and regulators.

• Compliance with Expanding Regulation: New rules such as the European Union’s Carbon Border Adjustment Mechanism (CBAM), the US Securities and Exchange Commission’s (SEC) climate disclosure rules, and “Buy Clean” mandates are raising the bar for traceability and reporting. The risk of non-compliance—ranging from financial penalties to exclusion from bids—is escalating.

• Unlocking Incentives and Tax Credits: Numerous jurisdictions and green building standards (e.g., LEED v4, BREEAM, U.S. Buy Clean) now mandate or reward the specification of low-carbon materials quantified by labels such as EPDs and ResponsibleSteel™.

• Gaining Market Advantage: In automotive, real estate, and consumer goods, clients and end-users are demanding full life-cycle transparency and verified climate credentials.

Case in Point: Volkswagen Group’s ID.4 Launch

When VW launched the ID.4 electric SUV, it specified steel from Salzgitter AG, produced with EAF and renewable energy. Certified EPDs enabled VW to proudly claim lower product carbon intensity, helping both its brand and regulatory standing.

The Challenge:

Not every green label offers meaningful assurance, and the misuse or misinterpretation of low-rigor labels has led to increased greenwashing allegations. As organizations face rising due diligence expectations, only accurate and fully verified labels will withstand regulatory and stakeholder scrutiny.

3. A Deep Dive: How Green Steel Is Produced

Understanding how green steel is manufactured is the key to interpreting—and trusting—the meaning behind its ecolabels. Emission intensity depends critically on the chosen production route and feedstocks. Here’s a comparative look:

3.1. Electric Arc Furnace (EAF) with Scrap

• Emissions: Can reduce operational CO₂ emissions by up to 90% if using 100% renewable power.

• Relevance: Most adopted in the US (over 70% of steel production), less so in Asia/EU (due to scrap availability).

• Limitations: Quality/grade constraints and scrap contamination are technical hurdles.

3.2. Hydrogen Direct Reduction (H₂-DRI)

• Emissions: Potential for near-zero operational emissions if powered by green hydrogen and renewables.

• Trend: Major European producers (SSAB, ArcelorMittal) have begun pilot-scale delivery of H₂-DRI steel, with commercial ramp-up projected for 2025–2030.

• Barrier: Green hydrogen cost and infrastructure present short-to-medium-term obstacles, though costs are falling rapidly.

3.3. Carbon Capture, Utilization & Storage (CCUS)

• Effectiveness: Can eliminate up to 60% of site emissions.

• Concerns: High capex, ongoing opex, and questions over capture permanence. However, it remains a transition solution where EAF/DRI upgrades lag.

3.4. Groundbreaking Methods

• Examples: Molten Oxide Electrolysis (Boston Metal), biocarbon reductants (Tata Steel), and circular carbon schemes are under demonstration.

• Outlook: These could reshape “green steel” definitions by 2030, but mainstream adoption hinges on overcoming technical and economic barriers.

Key Decision Point:

Steel’s total carbon footprint results from technology, feedstock mix, energy source, and location. Without rigorous, properly bounded LCAs and third-party certification, it's nearly impossible to make “apples to apples” carbon comparisons.

4. The Green Steel Label Landscape

Given the proliferation of green claims in steel supply chains, a clear understanding of what each label offers—and where gaps may lie—is essential. These are the main categories of ecolabels and certificates shaping decarbonization decisions.

4.1 ISO 14040/44 and Life Cycle Assessments (LCAs)

• Purpose: ISO standards 14040 and 14044 are the global benchmarks for LCA methodology, detailing how to quantify environmental impacts (notably GHG emissions) across a product’s full life cycle.

• Use: In steel procurement, ISO-compliant LCAs are the backbone of objective carbon accounting, forming the basis of Environmental Product Declarations (EPDs) and many proprietary labels.

• Industry Standardization: The worldsteel Association maintains a harmonized “climate accounting methodology” for comparability, but always examine system boundaries (cradle-to-gate, gate-to-gate, or cradle-to-grave).

Tip for Practitioners:

Push suppliers to provide third-party-verified LCAs with explicit system boundaries and upstream energy sources—guard against selective reporting or “cherry-picking” of favorable process stages.

4.2 ResponsibleSteel™

• What It Is: The only global multi-stakeholder certification standard for responsible and low-carbon steel, combining environmental, social, and governance (ESG) criteria via rigorous, third-party-audited processes.

• Coverage: Includes climate mitigation, human rights, community impacts, and business integrity metrics.

• Certification Levels: Starts with site-level ResponsibleSteel™ certification, followed by more advanced “Chain of Custody” certification to enable product-level claims.

Why It’s Trusted:

Blue-chip clients (e.g. Daimler, Lendlease) use ResponsibleSteel™ as a procurement standard. The process includes comprehensive traceability, credible auditing, and alignment with global disclosure systems like CDP and GRI.

Case Study:

Norsk Hydro’s partnership with Tata Steel utilized ResponsibleSteel™ certification as a cornerstone in its green building projects, boosting eligibility for green finance and ESG funds.

4.3 EPDs (Environmental Product Declarations)

• Definition: EPDs are standardized, independently verified documents outlining LCA-derived GHG emissions and environmental impacts for specific steel products, under ISO 14025.

• Importance: EPDs provide quantified, product-specific data, which is critical for complying with procurement mandates and green building certifications.

• Requirements: Must specify scope (e.g., cradle-to-gate) and functional unit (typically, GHG emissions per tonne of steel).

Growing Significance:

In the US, the Inflation Reduction Act (IRA) ties federal funding for green infrastructure to use of steel with published, credible EPDs—making them a ticket to access pivotal public contracts.

Analytical Insight:

EPDs foster healthy competition and drive emission reductions: in Sweden, demand for low-carbon EPDs has spurred both legacy and startup producers to accelerate green transitions.

4.4 Proprietary & Market Labels: XCarb®, VERDE, and Others

• XCarb® (ArcelorMittal): Combines steel with certified green electricity and carbon offset purchases, issuing “green steel certificates” for buyers.

• VERDE (CELSA Group): Issues certificates detailing emission factors based on EAF production and renewables use.

• Others: Salzgitter AG’s SALCOS, SSAB’s Fossil-free Steel™, and Nippon Steel’s NSCarboleader all offer unique versions of green/low-carbon steel branding.

Caveat:

Proprietary programs often use flexible definitions of “green,” sometimes relying on mass balance or “book-and-claim” models—where credits may or may not reflect actual emission reductions at the batch level.

5. Selecting the Right Label: What Really Matters?

If you only remember one thing, remember this.
A label is not the asset. The underlying evidence is the asset.
Your job is to buy steel that stands up to:
Audit.
Regulation.
Customer scrutiny.
Future tightening of “green” definitions.
Start by separating three different needs that often get mixed up.

You need a number.
That is the product’s emissions intensity, usually reported as Global Warming Potential per tonne, within a stated system boundary. This is what lets you compare suppliers.

You need proof.
That is verification, rules for calculation, and data quality.

You need traceability.
That is how the claim follows the steel through processing, service centers, and fabrication.

Most failures happen because teams buy only one of the three.

Step 1. Anchor your baseline, then define what “better” means for you

Before you judge any label, set your baseline.
Worldsteel’s sustainability indicators give you a reality check by route:
BF-BOF around 2.32 tCO2 per tonne crude steel cast, 2023.
Scrap-EAF around 0.70 tCO2 per tonne crude steel cast, 2023.
DRI-EAF around 1.43 tCO2 per tonne crude steel cast, 2023.
Global average 1.92 tCO2 per tonne crude steel cast, 2023.
worldsteel.org

Use that as a first filter.
If a supplier calls BF-BOF steel “green” without showing deep reductions or a clear method, treat it as marketing until proven otherwise.

Then set your target.
Examples procurement teams actually use:
“At least 30% below BF-BOF average for this product category.”
“Verified Type III EPD for every structural shape we specify.”
“No offsets counted inside the footprint number, offsets can sit in a separate line item.”

Step 2. Treat Type III EPDs as your default starting point for carbon comparison

If you need a comparable number across suppliers, Type III EPDs are usually the cleanest entry point.

Why

An EPD is a Type III environmental declaration under ISO 14025.
It reports quantified life cycle results and is intended to be third-party verified under a program operator’s rules.
ISO

Where this matters in real buying

Green building specs and many “Buy Clean” style programs often expect EPD-based reporting.
LEED v4.1, for example, awards credit based on using at least 20 permanently installed products from at least five manufacturers that meet its EPD criteria.
USGBC

U.S. federal low embodied carbon procurement has moved toward EPD-backed requirements. The Federal Buy Clean effort and GSA IRA low embodied carbon requirements are clear signals that EPDs are becoming table stakes in major public procurement.sustainability.gov

What to watch inside an EPD

System boundary. Cradle-to-gate is common for steel purchasing decisions, but you must know what is included and excluded. Product Category Rules. PCR alignment drives comparability. Verification and program operator. Who reviewed it, under what rules.

Step 3. Add a governance label when your risk is bigger than carbon

Carbon is only one risk lane.
If your exposure includes human rights, community impacts, or supply chain integrity, you need a broader standard alongside EPD data.

ResponsibleSteel is built for this. It is a global multi-stakeholder standard with third-party audited site certification.
It also has chain of custody options that support downstream claims when properly applied.
ResponsibleSteel

A practical way to use it

Use EPDs to compare carbon numbers. Use ResponsibleSteel to reduce ESG and due diligence risk where you have public commitments, lender requirements, or high-stakes customers.
ResponsibleSteel

Also note the decarbonisation progress concept. ResponsibleSteel describes decarbonisation progress levels tied to disclosed product carbon footprint and scrap-variable thresholds. That helps you avoid simplistic “scrap is always green” thinking, while still rewarding real progress.
ResponsibleSteel

Step 4. Be blunt about proprietary “green steel” labels and certificates

Proprietary labels can be useful.
They can also confuse your internal reporting if you do not classify them correctly.

The key question

Does the claim map to your physical steel, or to a certificate that represents emissions reductions somewhere else?

Example you should understand before you buy

ArcelorMittal’s XCarb steel certificates are designed for flat steel products made from iron ore in a blast furnace, and the supporting material describes CO2 savings audited by DNV. That is a certificate structure, not the same thing as receiving a segregated, low-carbon batch by default.
corporate.arcelormittal.com
+1

How you handle this in procurement

If your goal is physical decarbonisation of your supply chain, prioritize product-specific footprints and traceable claims.

If your goal is financing, internal carbon pricing, or a transition plan, certificates can play a role, but only if your reporting rules allow it and you clearly separate certificate-based claims from product footprint numbers.
newclimate.org

Step 5. Map label requirements to your compliance reality

If you sell into the EU, CBAM changes the minimum bar. CBAM entered its transitional phase on October 1, 2023.
Importers must report embedded emissions during the transitional phase through December 31, 2025.
The definitive phase starts January 1, 2026.
Taxation and Customs Union

What this means for your label selection

You want suppliers who can produce emissions data in the format and boundary you need for reporting, not just a marketing PDF.
You want contract language that forces timely data delivery, because missing data becomes your operational risk.

If you are U.S.-facing and bid on public work, “Buy Clean” signals matter.
GSA has published IRA low embodied carbon requirements for steel tied to federal projects.
Multiple policy paths point toward EPD-backed disclosure as a default expectation.
U.S. General Services Administration
+2
sustainability.gov
+2

If you cite SEC climate disclosure as a driver, keep it current.
The SEC adopted climate disclosure rules in March 2024.
The SEC later voted to end its defense of those rules in March 2025.
So you should treat the SEC piece as unstable, and rely on investor-grade disclosure discipline regardless.
SEC
+1

Step 6. Use this buyer checklist, then send it to suppliers

Minimum bar, do not negotiate these

• Product-specific Type III EPD under ISO 14025, or a clearly equivalent product carbon footprint disclosure with stated boundary and method.
  ISO
  +1

• Third-party verification details, including who verified and under which program operator.

• Explicit system boundary and functional unit, usually per tonne of steel.

• Production route disclosure, BF-BOF, scrap-EAF, DRI-EAF, plus site location.

• Electricity claim evidence. Specify whether renewable electricity is contractual, grid-based, or certificate-based.

• A clear statement on offsets. Are they excluded from the footprint number, or bundled into it.

Traceability questions you should ask

• Can you trace this claim through processing and distribution, or does it stop at the mill gate?

• Is the claim batch-linked, mass-balance, or book-and-claim certificate-based?

• If it is mass-balance or certificate-based, show the accounting rules and how double counting is prevented.

Red flags that should trigger a “no”

• “Green steel” with no quantified footprint.

• An intensity number with no boundary.

• A label that counts offsets inside the footprint number without separating them.

• A certificate that is presented as if it were a physical low-carbon batch.

Two quick examples to keep you grounded

• If you see scrap-EAF with credible renewable power claims, the route-level intensity can be far below BF-BOF averages. Worldsteel’s route indicators show that gap clearly.
  worldsteel.org

• If you see blast furnace steel paired with certificates, treat it as a different instrument. It may support transition claims, but it is not the same as buying a low-emissions production route.
  corporate.arcelormittal.com
  +1

6. Cost, Risk, and Compliance: The Decision Matrix

If you treat “green steel” as a branding choice, you will overpay, misreport, or both. You need a cost view, a compliance view, and a risk view, all tied to one thing: verified kg CO2e per tonne for the product you actually buy.

6.1 Start with the emissions math you can defend

Worldsteel’s 2025 figures give you a useful baseline for “order of magnitude” thinking:

• Global average CO2 intensity, 2023: 1.92 tCO2 per tonne of crude steel cast worldsteel.org+1

• Average BF-BOF intensity: 2.32 tCO2 per tonne worldsteel.org

• Average scrap-EAF intensity: 0.70 tCO2 per tonne worldsteel.org

• Average DRI-EAF intensity: 1.43 tCO2 per tonne worldsteel.org

• 2024 global production share: BOF 70.4%, EAF 29.1% worldsteel.org

What this means for you in plain terms:

• “EAF” alone is not enough. Scrap-EAF can be far lower than DRI-EAF. worldsteel.org

• Location matters. Your grid mix can swing the result.

• Any label that cannot show boundaries, electricity assumptions, and verification is weak for procurement and reporting.

6.2 Cost reality: where the premium comes from

You pay more for low-carbon steel for reasons that have nothing to do with logos:
Electricity and hydrogen are the big levers.

• Scrap-EAF depends on power price and power emissions.

• H2-DRI depends on hydrogen cost, electrolyser capex, and cheap clean power.

A worked example you can use internally (replace with your actual numbers):

• If carbon is €84 per tCO2 (December 2025 EUA futures show ~€84), then embedded emissions start to look like money. CME Group+1

• BF-BOF at 2.32 tCO2 per tonne implies ~€195 per tonne of steel in carbon exposure (2.32 × 84). worldsteel.org+1

• Scrap-EAF at 0.70 implies ~€59 per tonne (0.70 × 84). worldsteel.org+1

• The “gap” is ~€136 per tonne before you even talk about product performance or supply risk.

You will still see a market premium even when policy does not fully price it yet. Some buyers have signaled willingness to pay 25–30% more for cleaner steel in early deals, mainly to lock supply and cut reported footprint. Financial Times

A real demand signal to watch: Stegra (formerly H2 Green Steel) said it had pre-sold over 1.5 million tonnes per year on multi-year offtake contracts against planned production volumes. stegra.com+1

6.3 Compliance: what is forcing labels to become “proof,” not marketing

CBAM is the main forcing function for steel imports into the EU.

• The European Commission states CBAM has a transitional phase from 2023 to 2025, and a definitive regime from 2026. Taxation and Customs Union

• In October 2025, the EU published amendments to simplify and strengthen CBAM. Taxation and Customs Union

• The Council text confirms CBAM certificate sales start 1 February 2027, meaning you still account for 2026 imports, but purchase happens in 2027. EU Data

What you should do now if CBAM touches you:

• Collect embedded emissions data by product and supplier now. Do not wait for 2026.

• Decide, in writing, when you accept “default values” versus verified actuals.

• Make verification a contract obligation for any supplier you plan to keep.

US federal procurement is another forcing function, especially for public projects.

• GSA’s IRA low-embodied-carbon requirements cover steel, among other materials, and point directly at EPD-based reporting for compliance. U.S. General Services Administration+1

• The Federal Buy Clean effort has explicitly tied lower-embodied-carbon specifications to federal construction pilots. sustainability.gov

• Independent summaries note that EPDs are required in these IRA low-embodied-carbon cases. carbonleadershipforum.org

Corporate reporting adds pressure even when procurement law does not.

• EU sustainability reporting expects value-chain information, which pulls suppliers into your reporting scope. EFRAG

• The SEC climate rule path has been unstable, including pauses and a later move to stop defending the rule in court, which increases uncertainty for US-only teams. AP News+1

Even with that uncertainty, your customers and EU-linked stakeholders can still demand verified product carbon data.

6.4 Risk: the hidden costs that hit after you buy

Three risks hit buyers hardest:

Greenwashing and mislabeling risk

• Proprietary “certificate” programs can use book-and-claim or mass-balance logic. That can be valid in some cases, but you must know what you are buying, and what claim you are allowed to make.

Audit failure risk

• If your claim depends on an EPD or LCA, you need the program operator, PCR alignment, and third-party verification. EPD systems rely on program operators and independent reviewers, not supplier marketing teams. EPD International+1

Supply risk

• Clean steel capacity is constrained. Early pilot volumes can be small. Example: SSAB notes it delivered 500 tonnes of fossil-free steel to strategic customers in 2022. SSAB+1

• If you need 50,000 tonnes, you must plan allocations, lead times, and technical substitutions.

7. Actionable Tactics: Decarbonize Without Compromising

7.1 Write a “buyer spec” that suppliers cannot dodge

Put these into your RFQ and contracts:

• Required document: product-specific Type III EPD, third-party verified, with declared unit per tonne and clear boundary (cradle-to-gate, at minimum). EPD International+1

• Required disclosure: electricity source and tracking method (grid average, PPA, certificates), plus scrap share for EAF routes.

• Required comparability: same PCR family and same functional unit across all bids. emidat.com

• Required evidence: verification statement, verifier name, issue date, expiry, and rules for updates when process inputs change.

Then add one hard gate:

• “No verified EPD, no award,” for projects where compliance or public disclosure is a factor.

7.2 Make the label work for your business outcome

Pick the label type based on what you need to prove:

If you need a number for procurement rules

• Use EPDs first. They map to embodied carbon thresholds and public procurement language. U.S. General Services Administration+1

If you need ESG and human-rights coverage plus climate

• Use ResponsibleSteel site certification, and push for chain-of-custody where available. ResponsibleSteel+1

If you need “project claims” across multiple batches

• Use a verified chain-of-custody approach, and document the accounting method in your claim language. ResponsibleSteel’s downstream chain-of-custody work is aimed at this buyer problem. ResponsibleSteel+1

7.3 Run a 90-day pilot that gives you decision-grade evidence

Do not start with a full switch. Start with three controlled pilots:

Pilot A: Scrap-EAF “low risk” products

• Target rebar, sections, standard plate, non-critical items.

• Goal: get verified EPDs into your systems and prove reporting flow.

Pilot B: “Primary-like” low-carbon (DRI-EAF or similar)

• Target products where you worry about residuals or quality.

• Goal: validate metallurgy, mechanical properties, weldability, and rework rates.

Pilot C: Certified sourcing and traceability

• Target a single high-visibility project.

• Goal: test chain-of-custody language, invoicing fields, and audit trail.

Measure five things, every time:

• kg CO2e per tonne (EPD value)

• Delivered premium in $ or € per tonne

• Yield loss or gain (scrap rate at fabrication)

• Lead time and allocation stability

• Claim strength (what you can say publicly without risk)

7.4 Build the business case using “cost per tonne CO2e avoided”

Procurement debates get stuck on price per tonne of steel. Move it to price per tonne of CO2e avoided.

Example:

• If switching from 2.32 to 0.70 tCO2 per tonne saves 1.62 tCO2 per tonne, then:

• A €130 premium equals ~€80 per tCO2 avoided (130 ÷ 1.62). worldsteel.org

That is a number your CFO can compare to:

• your internal carbon price

• your compliance exposure

• your customer contract value at risk

7.5 Future trends you should plan for now

Standards convergence is accelerating

• ResponsibleSteel announced 2025 agreements with CISA and Europe’s LESS, saying combined membership represents around 60% of global steel production. That points to fewer “wild west” claims over time. ResponsibleSteel+1

CBAM rules will keep shifting, but the direction is fixed

• The EU has already amended CBAM once to simplify and adjust timing. Expect more guidance, more verification, and more enforcement tools, not less. Taxation and Customs Union+1

Green steel supply is scaling, but capex stress is real

• Hydrogen-based projects keep raising capital, and cost overruns are part of the story. That can affect delivery timelines and premiums. Reuters

More buyers will demand proof at the batch or project level

• Chain-of-custody and digital traceability will matter more than brand names, because auditors and regulators want a clean trail. Website Files+1

8. FAQs About Green Steel Labels

Is “EAF steel” automatically green?

No. Scrap-EAF can be low, but your power source and your scrap share drive the result. Use the EPD number, not the furnace label. worldsteel.org

What is the single most useful document for procurement?

A third-party verified Type III EPD with a clear boundary and declared unit. EPD International+1

Can I compare two EPDs from different programs?

Sometimes. You need aligned PCRs, boundaries, and functional units. If those differ, your comparison can break in an audit. emidat.com

What is the biggest “gotcha” in green steel marketing claims?

Unclear accounting, especially around certificates, mass balance, and what was physically delivered versus what was claimed.

Does ResponsibleSteel replace EPDs?

No. ResponsibleSteel covers wider ESG and site performance. EPDs give product-level quantified impacts. Use both when you can. ResponsibleSteel+2ResponsibleSteel+2

If a supplier gives me an ISO 14040/44 LCA, is that enough?

Not always. You still need verification, declared unit, and a disclosure format that procurement teams and auditors accept, which is why EPDs are common. Ecochain LCA Software+1

How does CBAM change what I need from suppliers?

It forces embedded-emissions accounting for covered goods. You will need emissions data by product, and you should be ready for verification requirements as the regime matures. Taxation and Customs Union+1

CBAM certificate sales start in 2027 now, so can I wait?

No. The obligations relate to 2026 imports, and the reporting and data work starts before you buy. The timing change gives you more time to set up systems, not a reason to delay. EU Data +1

What does “low embodied carbon steel” mean in US federal work?

It usually means the steel has a verified EPD and meets specified GWP limits or thresholds set in agency requirements. U.S. General Services Administration+2U.S. General Services Administration+2

How do I avoid paying a premium for a weak claim?

Tie payment to documents and verification. Put “deliver EPD and verification by X date” into milestones. Add rejection rights for missing or expired declarations.

Are pilots like fossil-free steel only marketing stunts?

No. They can be small volume, but they prove routes and build supply relationships. Volvo’s early use of fossil-free steel with SSAB is an example of buyer-led learning before scale. volvotrucks.com+1

What if I cannot get enough low-carbon supply this year?

Cut embodied carbon through design and yield first. Reduce over-spec. Improve cutting plans. Lower scrap and rework. Then lock future allocations with offtakes or multi-year supply clauses.

9. Conclusion: The Path to Low-Carbon Steel Operations

Green steel labels only matter when they change what you can prove.
If you want results you can defend:

• Anchor everything on verified product numbers, mainly EPDs, and align boundaries before you compare bids. EPD International+1

• Use ResponsibleSteel when you need wider ESG assurance and site credibility, then add chain-of-custody when you need project claims. ResponsibleSteel+2ResponsibleSteel+2

• Treat CBAM and public procurement as design constraints, not paperwork. Build your data trail now. Taxation and Customs Union+2EU Data +2

• Pilot, measure, and scale what works. Track cost per tCO2 avoided, not just €/tonne steel. worldsteel.org

If you do this, you buy cleaner steel with fewer surprises, and you protect your bids, your reporting, and your margins.

Copy-paste RFQ section you can send suppliers

Start of RFQ text

Scope of supply

Steel product(s): [rebar, HSS, hot-rolled sections, plate, cold-formed framing, coil, other]

Grades/standards: [EN/ASTM/JIS], tolerances, coatings, finish

Annual volume estimate: [x tonnes], first delivery window: [dates]

Delivery terms: [EXW/FOB/CIF/DDP], destination: [city, country]

Mandatory carbon and verification package

You must submit all items below with your quotation. Missing items make the bid non-compliant.

A. Product-specific Type III EPD

Product-specific Type III EPD, third-party verified

Declared unit: kg CO2e per metric tonne of steel

Boundary/modules stated clearly (A1–A3 at minimum)

Program operator, EPD ID, version, issue date, expiry date included

PCR referenced and attached or linked

Verification statement included with verifier name and verification date

(If you are bidding on U.S. federal work, align your EPD and PCR to GSA IRA Low Embodied Carbon steel documentation requirements.) U.S. General Services Administration

B. Manufacturing route and site disclosure

Route: BF-BOF, scrap-EAF, DRI-EAF, other

Producing facility name and country

Scrap share for EAF products (%, by mass) and scrap type (post-consumer, pre-consumer, closed-loop)

Electricity disclosure for the steelmaking step:

Grid region

Method used (location-based, market-based)

Evidence for market-based claims (contract type, instrument type, volumes, matching period)

C. Traceability fields (batch level)

Heat number or batch ID format you will provide on Mill Test Reports

Mapping method from shipped batches to the EPD (product family rules if used)

If you use mass-balance or book-and-claim, state it plainly and provide the accounting rules and what buyer claim you permit

D. Exclusions and separations

State whether offsets are used. If yes, keep them separate from product GWP and itemize them.

Optional but preferred certifications

• ResponsibleSteel site certification and chain-of-custody, if available

• ISO 14040/14044 LCA report that backs the EPD, if shareable

Commercial details to quote

Base price: [currency/tonne]

Low-carbon premium, shown as a separate line item: [currency/tonne]

Minimum order quantity (MOQ)

Lead time and allocation limits

Validity of offer: [days]

Change rules for price and availability

Technical and quality package

Mill Test Report format and frequency

Chemistry limits, residuals disclosure (Cu, Sn, Cr, Ni, Mo), as applicable

Mechanical properties and test standards

Non-conformance handling and replacement lead time

End of RFQ text

Sample contract clauses for EPD delivery, verification, and audit rights

Note: These are sample clauses. Have your counsel fit them to your contract and local law.

EPD deliverable and timing

Supplier must provide a product-specific Type III, third-party verified EPD for each steel product supplied under this Agreement. The EPD must be delivered no later than (a) bid submission for project work or (b) 10 business days before first shipment, whichever is earlier. U.S. General Services Administration

EPD content minimums

Each EPD must include, at minimum:

• Declared unit as kg CO2e per metric tonne

• Stated system boundary and modules (A1–A3 at minimum)

• Program operator, EPD ID, version, issue date, and expiry date

• PCR reference and verification statement with verifier name and date U.S. General Services Administration

Warranty of accuracy

Supplier warrants that all EPDs, GWP figures, route disclosures, and supporting statements provided are complete and accurate to Supplier’s knowledge, and prepared and verified under the referenced program rules.

Change notification and updated EPD

Supplier must notify Buyer in writing within 15 business days of any material change that could alter the product’s GWP (including route, scrap share, electricity sourcing method, major process changes, or facility change). Supplier must provide an updated verified EPD within 90 days of such change.

Records retention

Supplier must retain EPD working papers and supporting records relevant to the EPD and route disclosures for at least 7 years from final delivery, or longer if required by applicable buyer reporting duties.

Audit and information rights

Upon reasonable notice, Buyer may:

• Request the EPD verification statement and confirmation from the program operator

• Request supporting evidence for electricity sourcing claims used in the EPD boundary

• Request batch traceability evidence that links shipped material to the declared product covered by the EPD

If confidentiality limits disclosure, Supplier must provide third-party attestation or allow review by an independent auditor under NDA.

Non-compliance remedies

If Supplier fails to provide compliant documentation, or documentation is found materially inaccurate:

• Buyer may withhold payment for the affected shipments until cured

• Buyer may reject affected shipments without penalty

• Buyer may require replacement material that meets the documentation requirements

Public claims approval

Buyer may reference Supplier’s EPD and certification status in bids, ESG reporting, and customer disclosures, provided Buyer uses the exact boundary, dates, and product identification stated in the EPD. Supplier must respond to claim-review requests within 5 business days.

Claim language examples you can safely use in marketing, bids, and ESG reports

Use these as fill-in templates. Keep the parts in brackets accurate.

Simple EPD-based product claim

“We purchased [X tonnes] of [product name] steel supported by a third-party verified Type III EPD. The EPD reports an upfront (A1–A3) global warming potential of [Y] kg CO2e per tonne for this product, issued on [date] by [program operator].” U.S. General Services Administration

Comparative claim with a stated baseline

“Compared with our stated baseline of [baseline product and source, same boundary A1–A3], this steel shows a reported reduction of [Z%] in A1–A3 GWP, based on the supplier’s verified EPDs dated [dates].”

No-offsets statement

“The product GWP figure above is reported from the EPD boundary and does not include offsets. Any offsets, if used for separate purposes, are disclosed separately.”

Route statement with caution

“This steel is produced via [scrap-EAF / DRI-EAF / other], as disclosed by the supplier, and supported by a third-party verified EPD for the supplied product.”

Procurement bid claim for U.S. federal projects

“This steel meets the documentation requirement of a product-specific Type III EPD and is below the applicable GWP threshold for [category] under the GSA IRA Low Embodied Carbon Steel Requirements, based on the EPD-reported GWP.” U.S. General Services Administration

Responsible sourcing claim

“The producing site holds [ResponsibleSteel site certification / chain-of-custody], which supports our responsible sourcing due diligence for steel.” (Only use if you have the certificate ID and scope.)

Buyer ESG disclosure sentence

“For steel, we prioritize supplier-provided, third-party verified EPDs and capture A1–A3 GWP (kg CO2e/tonne) by product family, supplier, and facility for audit-ready reporting.” U.S. General Services Administration

3–5 buyer case studies with numbers, by sector

Automotive, Volvo Cars, recycled steel agreement with SSAB

What they did: Volvo Cars highlighted steel as a major materials emissions driver and pointed to SSAB recycled steel as a key cut.

Numbers: Volvo Cars states steel is about 25% of material-related emissions for a new car. They state SSAB recycled steel generates “almost 100% less CO2” per tonne versus traditionally produced steel in Europe and is made with around 90% recycled content. Volvo Cars

What you can copy: put “steel share of materials emissions” and “EPD-backed A1–A3 numbers” into your product footprint story, then track it by model line.

Automotive, BMW Group, global CO2-reduced steel sourcing

What they did: BMW signed supply agreements for CO2-reduced steel across regions.

Numbers: BMW says it plans to supply its global production network with over one third CO2-reduced steel from 2026 and expects this to cut supply chain carbon footprint by 900,000 tonnes per year. BMW also states steel is around 20% of supply chain CO2 emissions for a mid-sized fully electric vehicle. BMW Group PressClub

What you can copy: set a “share of supply covered” target (example: one third by a date), then report expected annual CO2 impact in tonnes.

Automotive, Mercedes-Benz, CO2-reduced flat steel in Europe

What they did: Mercedes-Benz sources CO2-reduced flat steel and outlined the routes and savings.

Numbers: Mercedes-Benz states scrap-based EAF steel can reduce CO2 emissions for the steel grades by more than 60% versus the conventional blast furnace route, and the savings potential rises to more than 75% with green electricity. Mercedes-Benz Group+1

What you can copy: disclose the route, then disclose the claimed reduction range, and keep it tied to “for the respective steel grades,” not a blanket claim.

Construction, Peab, first SSAB Zero deliveries and a fossil-free steel building

What they did: Peab ordered SSAB Zero for construction use and used fossil-free steel in a landmark project.

Numbers: Peab’s initial order was 300 tonnes, split roughly half for micro piles and half for other construction work. The SSAB Zero claim cited is “less than 0.05 kg CO2e per kg steel” for scope 1 and 2. peab.pl

Project result: SSAB states the Lund building represented a climate saving of around 14.5 tonnes CO2. SSAB also states that replacing all steel in key components with fossil-free steel would reduce climate impact from materials by around 30% for that project. SSAB

What you can copy: start with a defined pilot tonnage, then publish a project-specific CO2 saving with the assumptions stated.

Public procurement, U.S. GSA, IRA low-embodied-carbon steel requirements

What they did: GSA ran a six-month pilot applying low embodied carbon material requirements to 11 federal projects, backed by IRA funding for procurement. U.S. General Services Administration

Numbers you can use in specs: GSA published EPD-reported GWP limits by steel category. Examples include fabricated rebar top 20% limit 728 kgCO2e/tonne, unfabricated rebar top 20% limit 611, and unfabricated hot-rolled sections better-than-average limit 869. U.S. General Services Administration

What you can copy: set your bid gate as “Type III product-specific EPD required,” then set a numeric GWP cap by category aligned to the project’s procurement rules. U.S. General Services Administration+1