Netherlands Enacts Temporary Ban on Steel Slag Applications Over Safety Risks

The Dutch government has imposed a temporary ban on the use of LD and ELO steel slag in land-based applications, citing significant risks to human health and the environment. The measure, effective from 23 July 2025, was announced by the State Secretary for Infrastructure and Water Management and targets all unshaped construction materials containing more than 20% steel slag used in layers thicker than 0.5 metres or in areas with direct human exposure.

This policy shift directly affects stakeholders across the chemicals and construction industries, disrupting material flows and highlighting the need for tighter control over secondary raw materials in the circular economy.

Steel Slag Under Scrutiny After Decades of Use

Steel slag, a by-product of steelmaking, has been widely used in the Netherlands and Europe for decades as a substitute for sand in road construction and other civil works. While this practice supports circular economy goals by reducing reliance on primary raw materials, recent investigations have exposed shortcomings in risk management.

The new restriction follows a series of reports and studies by the National Institute for Public Health and the Environment (RIVM) and the Human Environment and Transport Inspectorate (ILT). Findings revealed that in several locations, applications of LD steel slag—even when meeting regulatory emission limits—still led to soil contamination and posed health risks, particularly from airborne dust and contact exposure.

REACH Implications and EU Involvement

The temporary Dutch measure banning the land-based use of LD/ELO steel slag was notified to the European Commission under Article 129 of the REACH Regulation (EC) No 1907/2006. The ban is currently under review by the European Commission under the REACH regulation. If approved, the Netherlands must submit an EU-wide restriction proposal within three months. Failure to gain approval would see the ban revoked immediately.

In parallel, the ILT has issued a warning to Tata Steel, citing improper hazard classification of LD slag under REACH and CLP regulations. Tata Steel had previously marked the material as non-hazardous, despite findings that it can cause severe eye injury and respiratory irritation.

"The ban is currently under review by the European Commission under the REACH regulation. If approved, the Netherlands must submit an EU-wide restriction proposal within three months."

— REACH Regulation Article 129

New Policy Framework in Development

Looking ahead, the Dutch government is developing a comprehensive policy framework for secondary construction materials. This includes mandatory registration of usage locations, enhanced monitoring, and a potential permanent permit regime for high-risk applications.

The State Secretary has committed to engaging with industry stakeholders through a proposed "industrial steel slag table" to explore safer and more innovative uses of these materials. A policy update is expected before the end of 2025.

Key Regulatory Details

The ban specifically targets unshaped construction materials containing more than 20% steel slag used in layers thicker than 0.5 metres or in areas with direct human exposure. This targeted approach reflects the government's commitment to addressing specific risk scenarios while maintaining flexibility for safer applications.

• Effective Date: 23 July 2025
• Scope: LD and ELO steel slag in land-based applications
• Threshold: Materials containing more than 20% steel slag
• Application Limits: Layers thicker than 0.5 metres or direct human exposure areas

Circular Economy Impact

This policy shift directly affects stakeholders across the chemicals and construction industries, disrupting material flows and highlighting the need for tighter control over secondary raw materials in the circular economy. The ban represents a significant challenge to the traditional approach of using steel slag as a sustainable construction material.

As the steel industry continues to focus on sustainability and circular economy principles, the development of safe and effective steel slag applications remains crucial. The Dutch ban highlights the importance of robust safety testing and regulatory oversight in ensuring that waste reuse initiatives deliver both environmental and economic benefits without compromising public safety.