OECD complaint filed against steel major ArcelorMittal over climate inaction

Opportunity Green has filed an unprecedented complaint under the OECD Guidelines for Multinational Enterprises on Responsible Business Conduct, arguing that Europe’s largest steel producer, ArcelorMittal, is failing to address its climate impact. 

(9 December 2025)

Climate change NGO Opportunity Green has filed Europe’s first climate-related complaint in the steel sector to the Luxembourg National Contact Point (NCP) under the OECD Guidelines, with support from SteelWatch, BankTrack and Ecologistas en Acción. It requests that steel giant ArcelorMittal publishes a revised climate action strategy to address its ongoing climate impact.

The complaint highlights ArcelorMittal’s lack of a robust, science-based climate strategy and outlines how it is failing to take adequate action to reduce its emissions at the pace and scale required to adhere to the 1.5ºC global temperature limit. Opportunity Green argues that this contravenes the OECD Guidelines, which expect multinational enterprises to adopt – and fundamentally, to implement – science-based targets and strategies consistent with international climate commitments. Given the intrinsic link between the adverse impacts of climate change and human rights, the complaint also contends that the company is not meeting human rights expectations.

ArcelorMittal is Europe’s biggest steelmaker – and one of the world’s largest – but around 75% of its steel is still produced using coal. As a result, it has a major carbon footprint, annually producing over 100m tonnes of carbon dioxide equivalent (CO2e) – comparable to the entire country of Belgium.

Despite indicating on several occasions that a revised climate strategy would be published in 2024, the steelmaker has not published a new version of its climate strategy since July 2021, citing policy uncertainty as a reason. But in the face of an undeniable climate emergency, waiting for a ‘settled’ policy environment is not any justification for not meeting expectations under the OECD Guidelines.

In the meantime, despite having had around €3bn in public funding earmarked to help it transition, and even though green steel technologies are developing at pace, many of ArcelorMittal’s green steel projects in Europe have been cancelled or postponed. And beyond Europe, the company continues to invest in coal-based production, with plans to construct new coal-dependent blast furnaces in India through a 60%-owned joint venture.

The company has itself indicated it is unlikely to meet its 2030 targets, reporting slow progress (from 2018, its carbon intensity has decreased by 5% in Europe; far below its 2030 target of 35%). Further, emissions from joint-owned ventures, such as the one in India, are not even covered by the company’s 2030 climate targets, nor are the upstream coal mine methane emissions associated with the company’s coal consumption.

Kirsty Mitchell, Legal Manager at Opportunity Green says:

“If ArcelorMittal is going to live up to its promise of achieving net zero emissions by 2050, it needs to take decisive, transformative action right now. Instead, the company is signalling a retreat from action and a lack of strategic clarity – with alarming knock-on effects for the climate and communities. By bringing this complaint, we hope to engage with ArcelorMittal on the actions it must take to address its climate impacts in line with the OECD Guidelines, and demonstrate that the company – and the wider industry – are accountable for climate action.”

Caroline Ashley, Executive Director of SteelWatch says:

“SteelWatch welcomes the OECD complaint submitted by Opportunity Green to the Luxembourg National Contact Point regarding ArcelorMittal’s inadequate climate targets and strategy. Public scrutiny and independent oversight are essential to ensure companies like ArcelorMittal deliver credible climate action. The stakes are too high for further delay.”

Julia Hovenier, Banks and Steel Lead at BankTrack says:

“This complaint shows ArcelorMittal’s financiers that they cannot continue writing blank cheques to a company that’s been sitting on its hands since 2021 when it comes to climate action. It’s long past time that ArcelorMittal lives up to its responsibilities, starting with following the OECD guidelines.”

Sara López, responsible for the Industrial Transformation campaign at Ecologistas en Acción says:

“Ecologistas en Acción has long urged ArcelorMittal to meet climate and environmental goals affecting the communities of northern Spain. We support Opportunity Green’s complaint as the company must live up to its commitments by decarbonising its plants and reducing harmful air pollution.”

ENDS

Notes to editors

Read the complaint in full here.

• The complaint, also known as a ‘specific instance’, is being filed by Opportunity Green against ArcelorMittal to the Luxembourg National Contact Point (NCP) pursuant to the OECD Guidelines for Multinational Enterprises on Responsible Business Conduct (OECD Guidelines).

• The OECD Guidelines are endorsed by OECD governments and set non-binding expectations for multinational corporates across a range of issues, including the environment, climate change and human rights. The OECD Guidelines were revised in 2023 to respond to urgent priorities facing societies and business, including updated recommendations for enterprises to align with internationally agreed goals on climate change and biodiversity.

• To ensure the guidelines are adhered to, governments establish a non-judicial body called a National Contact Point to promote the OECD Guidelines and handle complaints about harmful business activity in contravention of the OECD Guidelines. Civil society can file complaints to NCPs when companies fall below the standards expected if they have an ‘interest’ in the matter.

• In short, Opportunity Green’s complaint submits that the targets, strategies and actions undertaken by ArcelorMittal to address its adverse climate impact fall short of the expectations set out in Guidelines A.12 of Chapter II (General Policies), Guidelines 1(b), 1(c), 1d, and 5(b) of Chapter VI (Environment) and Guidelines 1 and 2 of Chapter IV (Human Rights).

• The complaint is being filed by Opportunity Green. The initiative is being supported by SteelWatch, BankTrack and Ecologistas en Acción.

• The NCP will now assess the complaint and decide whether it is admissible based on a set of criteria in the OECD Guidelines. This initial assessment normally takes up to three months. If the NCP accepts the complaint, it will offer its ‘good offices’ to contribute to the resolution of the alleged issues, typically through mediation.

Opportunity Green is an NGO working to unlock the opportunities from tackling climate change using law, economics, and policy. We do this by amplifying diverse voices, forging ambitious collaborations and using legal innovation to motivate decision makers and achieve climate justice.

SteelWatch challenges the global steel industry to urgently deliver its fair contribution to a liveable planet.

BankTrack is the international tracking, campaigning and NGO support organisation focused on banks and the activities they finance.

Ecologistas en Accion is a Spanish grassroots confederation of 300 ecological groups.