Licence to Operate
The third pillar of our strategy focuses on maintaining our licence to operate. This will be critical for the long‑term continuity of Tata Steel Nederland and for the successful execution of our transformation. As an operator in a hard‑to‑abate sector, we recognise that steelmaking is associated with significant environmental and social impacts. Decarbonisation, pollution and impacts on nearby communities are outlined in the Joint Letter of Intent (JLoI) between TSN, TSL, the Province of North-Holland and the Dutch government and reflect the topics of greatest importance to our stakeholders, including local communities, NGOs, local authorities and regulators. We address these topics within our licence to operate pillar, together with steel slag, in response to growing societal attention. We are therefore committed to maintaining steelmaking in the IJmond region while fundamentally transforming the way we operate, with the objective of preventing and/or mitigating adverse impacts, and operating in a manner that is aligned with our neighbours’ expectations.
Over recent years, TSN has taken actions to strengthen its licence to operate. Through targeted investments, operational improvements and stricter governance, we have reduced emissions, improved monitoring and reinforced our control framework. While progress has been made, further improvements remain necessary. Strengthening our licence to operate is therefore an ongoing journey.
Our licence to operate plays a central role in our SCALE strategy. It means we not only continue to reduce emissions, odour and nuisance at source, but also be demonstrably more in control of our operations, strengthen compliance and governance, and embed responsibility and accountability throughout the organisation. Discussion about accelerated closure of the Cokes and Gas Plants is ongoing, see Basis of Preparation.
In this chapter, we outline how TSN strengthens its licence to operate across four interconnected areas: decarbonisation, pollution, steel slag and communities. It describes the measures already implemented, the additional actions currently underway and those planned for the coming years, as well as the reinforcement of our HSE, Risk & Compliance function and control frameworks and how we monitor and steer progress.
Decarbonisation
Decarbonising steel production is a key component of TSN’s licence to operate, reflecting our responsibility as one of the largest industrial emitters in the Netherlands. As a hard‑to‑abate sector, steelmaking is inherently energy‑intensive and associated with significant greenhouse gas emissions, and reducing these emissions requires fundamental process transformation, substantial long‑term investment and time. In line with the JLoI, this transition is pursued in close cooperation with the Dutch State and regional authorities, with the dual objective of significantly reducing CO₂ emissions while also limiting impacts on the local environment and health of surrounding communities.
Nitrogen oxide
We are reducing nitrogen oxide (NOx) emissions, which are a key environmental focus area given their impact on air quality and nitrogen deposition in biodiversity-sensitive areas. Over the past twenty years, we already reduced our NOx emissions by around 20%.
To achieve further reductions, a DeNOx installation has been installed at the Pelletising Plant. The installation is designed to reduce emissions from this process by approximately 80% compared to 2019 levels. However, commissioning is currently contingent upon obtaining the required regulatory permit approvals and, as such, the installation is not yet operational. Once commissioned, the DeNOx installation is expected to materially reduce TSN’s contribution to nitrogen deposition, including in nearby Natura 2000 sites.
Further information on nitrogen emissions, assumptions, monitoring and the link to nature‑permit requirements is provided in the Sustainability Statements (Environment – Pollution and Biodiversity).
Dust
To prevent dust nuisance, TSN has implemented a broad set of measures aimed at reducing both coarse and fine particulate emissions across the IJmuiden site. These include the installation of dust extraction and dedusting systems at pelletising plants, blast furnaces and other key installations, as well as windscreens around raw‑material handling and storage areas to limit wind‑driven dispersion. As part of our Roadmap Plus and the Green Steel transformation, large‑scale physical barriers and enclosures are being implemented. This includes, among other things, windbreakers of approximately 800 metres in length and over 20 metres in height at ore blending fields, as well as the progressive enclosure of stockyards. These measures structurally reduce wind exposure and dust formation during storage, processing and transport of materials.
Looking ahead, the transition to carbon-neutral steelmaking will structurally reduce dust emissions further. The closure of coal‑based installations and coke and gas plants will eliminate several dust‑intensive activities, while new DRI and EAF facilities are designed with modern containment, extraction and filtration systems that limit dust emissions by design.
More detailed information on dust-reduction measures, underlying assumptions and monitoring can be found in the Sustainability Statements (Environment – Pollution).
Noise and odour
TSN’s operations can negatively affect the local living environment through noise and odour. We operate an extensive engagement and grievance system and we are investing in mitigation. We are also working on an extended monitoring system with an automated data dashboard as part of the HSE turnaround to create more consistent transparency on improvement outcomes and to strengthen trust.
Noise-reduction measures have been implemented across several installations and operational activities to minimise disturbance for neighbouring communities. We have also reduced night‑time activities as much as possible, and together with our neighbours we will install new noise monitoring systems at critical locations to trace noise more accurately to its source. In response to persistent concerns about materials‑handling noise, we have placed sound meters on cranes involved in scrap handling, installed sound silencers at our steel factory, and prohibited night‑time scrap handling.
We are also taking proactive measures to minimise odour in the surrounding area by implementing a comprehensive set of odour-reduction measures in line with the Geurbesluit 2027. These measures target key emission sources such as coke and steelmaking operations through defined reduction requirements, while phasing out older high‑odour installations and replacing them with lower‑emission alternatives. These efforts are supported by targeted technical upgrades, including improved vapour capture at granulation processes, enhanced performance of third‑party treatment facilities, and upgrades to wastewater and flue gas treatment systems. We use e-nose networks and third-party event analysis to match complaints with wind and sensor data, identifying sources and adjusting operations when needed.
Substances of Very High Concern (ZZS)
Tata Steel Nederland applies a structured, evidence‑based approach to manage and reduce emissions of substances of very high concern (ZZS). For example, between 2019 and 2022 polycyclic aromatic hydrocarbons (PAHs) emissions at the three largest sources were reduced by more than 50%.
Looking ahead, Tata Steel intends to further reduce emissions of ZZS by embedding substance‑specific reduction roadmaps into its environmental programmes and by implementing additional avoidance and reduction measures where technically feasible and permitted. The Green Steel transformation forms an important structural element of this next phase: the gradual replacement of coal‑based installations by DRI–EAF technology is expected to substantially reduce the formation and release of ZZS such as PAHs, and certain metal compounds. These developments are subject to regulatory processes and stakeholder engagement and are aimed at achieving stable, long‑term compliance and further reductions in environmental impact over time.
Steel slag
The use of steel slag, a by‑product of our steelmaking process, supports circularity by replacing primary raw materials particularly in infrastructural applications.
However, due to current temporary regulatory restrictions in the Netherlands, TSN is not supplying steel slag for these applications at present, reflecting concerns around its safe
use and application. Recognising that improper handling, treatment or application of steel slag may lead to environmental impact, TSN is strengthening its Duty of Care efforts to ensure that slag is used responsibly. This includes providing steel slag customers with clear risk documents on safe applications. It should be noted that the continued offloading and distribution of steel slag is existential to the viability of TSN.
Further details on slag management, environmental risks and governance measures are provided in the Sustainability Statements (Environment – Resource use and Circular economy).
Our neighbours
The prevention and mitigation of impacts, including GHG emissions, pollution and steel slag, are critical components of TSN’s licence to operate. Equally important is how TSN engages with affected communities and addresses their concerns. This requires not only compliance with permits and regulatory requirements, but also credible action to address local communities’ concerns, including noise, odour and dust.
The ongoing acceptance and trust granted by neighbouring communities depend on TSN’s ability to engage in a transparent, accessible and respectful manner and, where necessary, to remedy adverse impacts associated with its activities.
TSN engages with affected communities through dialogue and informs on its activities and impacts. Channels are in place through which community members can raise concerns or complaints, supported by defined follow‑up processes. TSN undertakes measures aimed at limiting local disturbances such as noise and odour, as part of its approach to managing pollution‑related impacts.
Meaningful dialogue, timely responses to questions and grievances, and the integration of community perspectives into decision‑making are essential elements in sustaining this trust. Looking ahead, TSN is further developing its stakeholder engagement framework and considers the potential positive impacts of its transition for communities, including green job creation, as described in the Sustainability Statements under Affected communities in the IJmond region chapter.
Sustainability Statements
The Sustainability Statements build on TSN’s Licence to Operate foundation by providing a comprehensive overview of TSN’s material sustainability impacts, risks and opportunities, including topics such as water management, biodiversity, own workforce, responsible value chain and governance, and serve as the primary source of detailed sustainability information.
Embedding responsibility and control
While the measures described above are essential to reduce our environmental impact, maintaining our licence to operate requires more than technical solutions alone. It requires that responsibility, discipline and proactive risk management are structurally embedded in the way we operate and take decisions. Strengthening our licence to operate is therefore a continuous effort. It means being demonstrably more in control of our operations, anticipating regulatory and societal expectations, and sustaining improvements over time.
HSE turnaround
The HSE Turnaround Programme plays a central role in embedding these principles into the organisation by ensuring that the protection of health, people and nature becomes an integral part of daily operations and long‑term management control.
As part of the HSE Turnaround Programme, we are reshaping the HSE operating model and strengthening both capabilities and reporting systems. This includes the development of a single emissions data platform to serve as the foundation for both internal oversight and external disclosure.
The platform is being developed with clear governance, defined ownership and traceable data flows to enhance consistency, reliability and decision-making as we advance our transition to net zero steelmaking.
As monitoring coverage and measurement methodologies are expanded, TSN is gaining deeper insight into emissions at installation level. In some cases, enhanced monitoring has led to the identification of substances exceeding applicable limits at specific emission points, including chromium‑6 at our Direct Sheet Plant (DSP). This insight results from increased measurement resolution and transparency rather than a change in underlying operations, and it enables timely corrective action in close coordination with regulators. Such insights support more targeted follow‑up measures and continuous improvement of environmental performance.
In parallel, we are strengthening the governance and execution of environmental projects. This includes further improving the quality, consistency and auditability of regulatory submissions such as Substances of Very High Concern (ZZS) and the annual environmental report (eMJV). We are also developing substance-specific roadmaps to reduce priority emissions. In addition, we are applying a more systematic approach to managing emission point registers, odours and noise. Together, these measures are intended to support more predictable environmental performance and sustained compliance over time.
Through the HSE Turnaround Programme, we are reinforcing the foundations to sustain our licence to operate and successfully deliver our transition to net zero steelmaking, while strengthening the confidence of regulators, governments and local communities.
“Strengthening our licence to operate is an ongoing journey – one in which progress has been made, but in which continued action remains essential.”