Structural steel GWP varies by up to 7x depending on production route — from BF-BOF at 1,600–2,100 kg CO2e/tonne to H2-DRI green steel approaching 300 kg. DPPs make this visible at product level for every order.
Production routes
GWP A1–A3 in kg CO2 equivalent per tonne of structural steel. The production route is the dominant variable. Two products with identical mechanical properties can have GWP differing by a factor of 7. The DPP surfaces this for procurement decisions.
Dominant route globally. Coal-fired blast furnace for iron reduction. High GWP. Limited by iron ore and coking coal dependency.
Lower GWP when powered by low-carbon electricity. GWP is electricity-grid-dependent. EU EAF GWP is lower than US or Asian average due to cleaner grid.
DRI (direct reduced iron) produced from natural gas instead of coal. Lower GWP than BF-BOF but still fossil-dependent without H2 substitution.
Frontier pathway using green hydrogen for iron reduction. SSAB HYBRIT, ArcelorMittal XCarb, and H2 Green Steel are leading commercial pilots. Approaching commercial scale 2026–2030.
Ranges indicative. Actual GWP depends on electricity grid carbon intensity, scrap quality, and process efficiency. Source: published EN 15804+A2 EPD data.
Lifecycle modules
EN 15804+A2 requires at minimum modules A1–A3. For structural steel, Module D (recycling potential) is particularly important because steel scrap displaces virgin iron ore — the net benefit can be substantial.
Raw material extraction, transport to works, manufacturing. Mandatory declared scope.
Transport from factory gate to construction site.
Installation into the building. Sometimes declared for structural steel.
Deconstruction, transport, waste processing, disposal.
Recycling potential beyond system boundary. Important for steel — scrap credit can be significant.
Green steel frontier
Hydrogen direct reduction (H2-DRI) replaces coking coal with green hydrogen for iron ore reduction. Combined with an EAF powered by renewable electricity, H2-DRI green steel approaches near-zero GWP — well below 300 kg CO2e/tonne.
Pilot production since 2021. Commercial scale plant planned 2026.
Commercial plant under construction. First production targeted 2025–2026.
DRI+ EAF conversion programme underway. 'Smart Carbon' and H2 DRI routes.
Steel FAQ
Steel GWP is dominated by the ironmaking step. BF-BOF uses coking coal to reduce iron ore at ~1,500°C, releasing ~1.8 t CO2 per tonne of steel. EAF uses electricity to melt scrap — if the grid is low-carbon, the GWP drops dramatically. The same steel product (e.g. S355 I-section) can have GWP ranging from <300 kg CO2e/tonne (H2-DRI) to >2,000 kg CO2e/tonne (BF-BOF), depending entirely on production route. The DPP makes this visible.
Module D (recycling potential beyond system boundary) is not mandatory but is strongly recommended for structural steel because steel is one of the most recyclable materials in construction — end-of-life scrap typically displaces virgin iron ore in the EAF route. A well-declared Module D can significantly offset A1–A3 GWP on a net basis. However, EN 15804+A2 and most PCRs require Module D to be reported separately and not netted against A1–A3.
EN 10025 is the harmonised standard series for hot-rolled structural steel products: EN 10025-1 (technical delivery conditions), -2 (non-alloy structural steels), -3 (normalized), -4 (thermomechanically rolled), -5 (weather-resistant), -6 (high-yield quenched and tempered). Hollow sections for structural use are covered by EN 10210 (hot-finished) and EN 10219 (cold-formed). All are CE marked under CPR and will be subject to the DPP delegated act.
The CPR/ESPR delegated act for structural steel (referencing the EN 10025 series hENs) is estimated for Q4 2026. An 18-month transition then follows, making mandatory compliance estimated from approximately Q2 2028.
CBAM full enforcement covers steel products from 2026. Importers must declare embedded carbon and purchase CBAM certificates. The GWP A1–A3 value in a structural steel DPP provides the embedded carbon data foundation for CBAM compliance, though CBAM uses a specific calculation methodology (production-route benchmarks) that may differ slightly from EN 15804 LCA boundaries. A verified DPP is strong evidence for CBAM declarations.
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