[SMM Stainless Steel Flash] EU ETS Reform: Protecting Big Steel's Balance Sheets While SMEs Bear the Burden
The EU Commission's latest ETS reform proposal (COM(2026) 616), presented as a competitiveness measure, adds further layers of funds, investment conditions, and reporting obligations on top of already complex ETS and CBAM rules without meaningful simplification. Free allocation for CBAM sectors is extended to 2038, while historic certificate surpluses accumulated by the steel industry remain entirely untouched — allowing European producers to meet current obligations with previously free-allocated certificates while importers must provide upfront CBAM capital. SMEs appear in funding programs but receive no exemptions or reserved quotas. The case of Saarstahl illustrates the asymmetry: the company benefits simultaneously from historic ETS surpluses, extended free allocation, decarbonisation subsidies, CBAM border protection, and steel tariffs, with over half of its EUR 4.6 billion hydrogen investment publicly funded. Meanwhile, Germany's 2026 industrial electricity price of around 16.7 cents/kWh has returned to 2014 levels, undermining the steel industry's persistent claims that energy costs are the sector's primary burden.