OECD complaint against Europe’s biggest steelmaker, ArcelorMittal

Opportunity Green has filed a complaint under the OECD Guidelines for Multinational Enterprises on Responsible Business Conduct (OECD Guidelines), arguing that Europe’s largest steel producer, ArcelorMittal, is failing to adequately address its climate impact. The complaint was submitted to the Luxembourg National Contact Point (NCP) in December 2025.  

Background

The iron and steel sector accounts for around 7% of global anthropogenic greenhouse gas emissions and 11% of global carbon dioxide emissions. To stand a chance of meeting internationally agreed climate goals, the steel industry must urgently transition away from coal-based production.

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 – comparable to the entire country of Belgium. However, the steel major hasn’t published an updated climate strategy since 2021. Since then, many of its green steel projects in Europe have been cancelled or postponed, while 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.

What is the complaint about?

Opportunity Green submits that the targets, strategies and actions undertaken by ArcelorMittal to address its adverse climate impact fall short of the expectations set out in the OECD Guidelines. In particular, 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.

Opportunity Green is engaging with the Luxembourg NCP’s complaint procedure with a view to reaching an agreement with ArcelorMittal on the actions it must take to adequately address its climate impact in conformity with the OECD Guidelines. This includes publishing a revised climate action strategy and robust climate mitigation targets to ensure that its greenhouse gas emissions are consistent with the internationally agreed global temperature goal of 1.5°C.

Read more in our press release and in the full complaint, linked below.