Pollution

Why it matters

Steelmaking involves high temperature processes, combustion activities and large-scale material handling, all of which generate emissions. Emission of air and water pollutants is an area of significant operational and compliance focus.

Key objectives

The double materiality assessment identified multiple material impacts and risks related to the pollution of air, water and soil.

To support our company-wide commitment, this year we have introduced the pollution control policy. It is meant to guide our measures to prevent or mitigate pollution of air, water and soil.

Reduction of NOx emissions remains one of our key priority areas. This year, we have progressed with preparations for the construction of the DeNOx installation at the pelletising plant.

Once complete, this will allow us to reduce site-wide emissions by 30%.

Additional process optimisation, combustion air optimisation, and the expansion of the waste-heat network were executed during the year and are expected to achieve additional reduction in NOx emissions by 2026.

Furthermore, TSN is taking actions to improve the measurement and monitoring of emissions. TSN also submitted the updated ZZS inventory and the Avoidance and Reduction Plan (Vermijdings- en Reductieplan), which is now under assessment by the competent authority.

Looking ahead, we plan to implement the pollution related measures included in the Green Steel Project Phase 1 – subject to the Tailor-Made Agreement, including actions on dust, slag processing, odour and management of substances of very high concern.

The steel industry inherently produces emissions to air, water and soil and therefore requires robust pollution prevention and control measures. TSN is committed to reducing these adverse impacts on the environment.

Table. Summary of IROs, policies, key actions, metrics and targets related to pollution

Impacts, risks and opportunities

Category

Key Policies

Key Actions

Key Metrics

Key Targets

Pollution of Air: Air pollution arises both in TSN’s own operations and in its upstream value chain. TSN’s upstream steel supply chain contributes to air pollution through mining and transportation of raw materials. TSN’s steelmaking processes emit air pollutants.

Actual negative impact

Pollution Control Policy

  • DeNOx and dedusting installation

  • Process optimisation; combustion air optimisation; expansion waste-heat network

  • Installation of lining pipes and changing fuel gas mixture on some of the batteries of CGP1 to prevent gas leakages

Pollution of air

No targets have been set for the current reporting period

Compliance with Regulation on Air Pollution: Financial risk arising from potential non‑compliance with air quality regulations, which could result in regulatory enforcement actions, financial penalties and adverse reputational impacts.

Risk

See the Risk and Compliance section of the Management Report for a description of mitigation measures under Environmental Compliance risk section.

Pollution of Water: TSN’s upstream steel supply chain contributes to water pollution through the extraction and handling of raw materials such as iron ore and coal, while its own operations emit water pollutants in its wastewater.

Actual negative impact

  • Upgrade of the BIO2000 facility into the CombiBio installation to treat nitrate‑rich wastewater from the DeNOx process

Pollution of water

Compliance with Regulation on Water Pollution: Financial risk due to potential non-compliance with water quality regulations, which could result in regulatory enforcement actions, financial penalties and adverse reputational impacts. Timely investments in technical measures to ensure compliance may require significant capital expenditure.

Risk

See the Risk and Compliance section of the Management Report for a description of mitigation measures under Environmental Compliance risk section.

Pollution of Soil: At TSN-operated sites, incidental spills or leakages from steelmaking activities are contained by paved surfaces and concrete floors. If incidents occur, spills and leakages may directly contaminate the soil.

Actual negative impact

  • Clean up by contracted parties and follow-up soil measurements conducted by TSN and third parties

Entity-specific metric in development

Use of SoC/SVHC: TSN’s upstream steel supply chain contributes emission of substances of concern and very high concern through mining and transportation of raw materials. TSN’s steel manufacturing processes emit substances of concern and very high concern.

Actual negative impact

  • Submission of inventory for ZZS and avoidance and reduction plan (VRP)

Substances of very high concern

Compliance with regulation on SoC/SVHC: Financial risk due to potential non-compliance with regulations on substances of concern and substances of very high concern, which could result in fines, restrictions on product use, and adverse reputational impacts. Timely investments in technical measures to ensure compliance may require significant capital expenditure.

Risk

See the Risk and Compliance section of the Management Report for a description of mitigation measures under Environmental Compliance risk section.

Impact, risk and opportunity management

Current financial effects

TSN has assessed the effects of its material pollution‑related risks and opportunities on its financial position and financial performance for the reporting period. The identified risks and opportunities are described in the double materiality outcome, with the related current financial effects discussed below.

Compliance with regulation on air pollution

To comply with air quality regulations and the Environmental Agency’s (EA) notices regarding alleged non-compliance at the IJmuiden plants, the Group has incurred capital expenditures relating to technical compliance measures. The capital expenditures relating to such initiatives are included in the additions to property, plant and equipment as disclosed in Note 8 to the consolidated financial statements.

In December 2024, the EA imposed two penalty orders on TSIJ with a maximum exposure of €27 million following measured exceedances of MVP1, MVP2 and g.O₂ emission thresholds at CGP1 and CGP2. An amount of €8.5 million relating to exceedances of MVP1 and MVP2 was paid on 2 January 2026. For further details, refer to the Litigations chapter of this Annual report.

As of 31 March 2026, the Group recognised provisions of €14 million related to penalty orders received for MVP1, MVP2 and CGM21. These liabilities are recognised as part of environmental provisions in Note 18 to the consolidated financial statemements.

Compliance with regulation on water pollution

TSIJ has made capital investments in upgrades of the water treatment plant and related installation systems, however, these investments were undertaken to maintain and improve the Group's water management systems and capabilities and not directly to address risks related to non-compliance. No liabilities related to non-compliance with water quality regulations have been recognised in the balance sheet.

Compliance with regulation on substances of (very) high concern

TSN continues to undertake operational and capital improvements to address the risks related to substances of concern and substances of very high concern. Significant efforts are in progress across all areas of the Group and as such, we do not isolate and consider these costs separately from the overall costs allocated to its transition plans and projects. No liabilities have been recognised in the balance sheet, except for the provisions relating to the above-mentioned penalty orders for non-compliance with MVP1 and MVP2.

Pollution policies

To support its ambition to lower its pollution-related impacts, TSN developed a new Pollution Control Policy in the beginning of 2026 which applies to all TSN operations and employees.

Table. Policies related to pollution

Background

Key Content

Scope & key stakeholders

  • TSN developed a Pollution Control Policy to support its commitment to lower its pollution-related impacts

  • Compliance with applicable laws, regulations, and permits

  • Commitment to achieve reductions across a broad range of pollutants through the Green Steel Project and site-specific measures across all of TSN’s operations

  • The Policy is applicable to all TSN sites and employees

  • Stakeholder collaboration informs planned actions under the Green Steel Project

Our current efforts focus primarily on TSN’s own activities, where we have the greatest ability to influence outcomes and implement improvements directly. TSN is committed to comply with all relevant laws and regulations. We also acknowledge that compliance with evolving environmental regulation requires significant investments and proactive and constructive alignment with the Environmental Agency. Our approach is guided by the Tata Steel Group’s Environmental Policy which sets out its commitment to environmental protection through pollution prevention, efficient use of resources, continuous improvement of environmental performance, and compliance with applicable environmental laws and standards across its operations, the TSN Code of Conduct, and specifically the Pollution Control Policy which together establish the framework for responsible environmental management. Given the scale and complexity of TSN’s industrial operations, pollution-related incidents remain an inherent risk. TSN has therefore implemented standard procedures aimed at preventing incidents and to manage any that may occur. In the event of an incident, TSN will aim to limit pollution, remediate polluted areas, engage transparently with stakeholders and authorities, and disclose information in accordance with regulatory requirements.

To strengthen pollution control, TSN applies technical solutions and, where permits are applied for or updated, TSN designs new or modified installations in line with Best Available Techniques (BATs) in both investment programmes and asset end-of-life decisions.

A key pillar of our improvement plan at Tata Steel IJmuiden (TSIJ) is the Roadmap programme (2019–2025) and its continuation of improvement under the Green Steel Project (2025–2045), which includes a comprehensive set of pollution-reduction measures. Structured dialogue with external stakeholders is an integral element of this approach as stakeholder input directly informs our actions, as demonstrated by the inclusion of additional pollution control in the Green Steel Project.

To support effective pollution control and continuous improvements across all major operations, TSN applies a set of instruments. These include environmental management systems accredited according to ISO 14001, a suite of internal standards, codes of practice and guidance documents, enterprise risk management processes, internal audits, and the use of independent external providers for certification and data assurance.

Recognising the importance of upstream pollution-related impacts, TSN seeks to strengthen pollution control within its value chain. This includes engagement and dialogue with suppliers, the use of questionnaires, due diligence checks, and the operation of a grievance mechanism to identify, address, and remediate potential pollution-related incidents.

Pollution actions

To limit impacts on the local environment and on local residents arising from emissions, TSIJ launched the “Roadmap” improvement programme in 2019. In 2021, this programme was expanded and accelerated through “Roadmap Plus”, which introduced 30 targeted measures for the period 2021-2025.  Roadmap Plus represents more than 300 million euros in investments, fully financed by TSIJ without government support, aimed at reducing emissions of dust, heavy metals, lead, nitrogen oxides (NOx), and particulate matter (PM). For fine particulate matter (PM₁₀), a site-wide reduction of approximately 41% from 711,000 kg to 417,000 kg (based on the e-MJV of 2024) has been achieved compared to 2019 based on e-MJV data. The expected outcome of a 30% reduction in NOx has not yet been reached because the key DeNOx installation at the pellet plant is pending permit approval. For heavy metals and lead, the target scope was based on the emission sources in 2019. The measures included in Roadmap Plus explicitely targeted the sources which were already known in 2019. Thanks to these measures a clear reduction in emissions has been achieved for this group of sources. Reduction of heavy metals emissions resulted in 63% between 2019 and 2024, and 88% reduction for lead. The number of monitored emission sources has increased from 21 in 2019 to 61 in 2024, fundamentally altering the site‑wide reported emission profile. Current emissions reporting, also available in the form of the eMJV report is based on 61 sources of emissions. For coarse dust, the projected 65% reduction cannot be quantitatively demonstrated, as the 2019 baseline is not comparable due to differing measurement methodologies and a consistent monitoring dataset only being available from the end of 2021. In addition, strong weather-driven variability and the relatively small share of steelmaking-related dust in the total deposition make it difficult to isolate and measure the impact of specific reduction measures.

Further pollution-reduction measures beyond the Roadmap plus programme are part of our plan and subject to the Tailor-Made Agreement. This agreement is intended to consist of two main components:

  • Green Steel Phase 1, which focuses on reducing CO2 emissions alongside reductions in fine dust, SO2, substances of very high concern (SVHC), odour, noise, and NOx.

  • Additional environmental and health-related measures, which further target reductions in fine dust and noise.

While this section focuses on mitigation measures addressing negative pollution‑related impacts, further information on risks related to non‑compliance with environmental regulations and corresponding mitigation measures is disclosed in the Environmental Compliance Risk section within the Risk and Compliance section of the Annual Report.

Details on material legal proceedings related to pollution-specific issues are disclosed in the Litigation section of the Annual Report.

Pollution current actions 

An overview of a non-exhaustive list of key current actions, which were started, ongoing or were completed in 2025/2026, is provided in the table below. Please also refer to the Licence to Operate section of the Management Report for a concise overview of TSN’s actions in relation to nitrogen oxide, substances of very high concern and dust.

Table. Key current actions related to pollution

Key actions

Scope and timeframe

Expected outcome

DeNOx and dedusting installation

Pelletising plant, IJmuiden

Start: 2025

Completion: 2026

~80% reduction of NOx emissions at pellet factory contributing to ~30% reduction of NOx emissions site-wide

Process optimisation; combustion air optimisation; expansion waste-heat network

Site-wide, IJmuiden

Execution: 2026

Incremental NOx emission reduction, contributing to ~30% reduction of NOx emissions site-wide

Installation of new water treatment plant using CombiBio technology

IJmuiden

Start: 2024

Completion: 2026

Improvement of wastewater quality and reduction of thermal load on surface water

TSN has assessed whether significant financial resources have been allocated to the implementation of its key current actions. The capital expenditure of approximately €44 million was incurred for de‑NOx and dedusting installations, as well as a new water treatment plant (CombiBio) during the reporting period. The related expenditure is recognised as additions to property, plant and equipment and disclosed in Note 8 to the consolidated financial statements.

Other pollution-related actions, including process optimisation, clean-up and site-level control measures, do not involve significant financial resources, as the related costs are embedded within TSN’s existing operations and do not represent material capital or operational expenditure in the reporting year.

Air Pollution current actions

Air pollution is inherently associated with steelmaking, as the high‑temperature processes, combustion activities and material handling steps generate emissions. TSIJ’s Roadmap Plus programme translates this link into action by prioritising and implementing targeted measures to reduce air emissions across the site. Most measures under Roadmap and Roadmap Plus are close to completion, with only two ongoing actions pending permits approvals and technical engineering finalisation. One of the most significant ongoing measures is the DeNOx installation at the pelletising plant which is expected to reduce NOx emissions from the pelletising plant by approximately 80%. It reduces NOx by injecting ozone into the flue gas to make nitrogen oxides water‑soluble, after which they are washed out in a scrubber and the nitrate‑rich stream is sent to water treatment. This measure alone will nearly achieve TSIJ’s planned 30% site-wide reduction in NOx emissions. The DeNOx installation start-up depends on the permitting process for the installation and Dutch nitrogen regulations require an updated nature permit for operational changes that may affect Natura 2000 areas, even when these changes lead to environmental improvements. Commissioning will proceed as soon as approval of the revised nature permit and the DeNOx installation permit are granted. The second project at the pelletising plant concerns suppression of dust from raw materials. It is currently in the engineering and constructing phase and will be technically ready for commissioning/completion in 2026. 

Other measures are process optimisation, combustion air optimisation and the expansion of the waste-heat network. These are in execution and expected to achieve additional reduction in NOx emissions by 2025/2026. In addition, TSIJ monitors air emissions at stacks in line with permit requirements and, if an exceedance or abnormal emission is identified, TSN takes immediate corrective action and reports this to the competent authority as an environmental notification, alongside external oversight by regulators through inspections and compliance verification.

In relation to exceedances of emission thresholds for MVP1, MVP2 and g.O2 substances at the CGP1 and CGP2 oven stacks, TSIJ initiated a root-cause analysis to understand the underlying drivers of the deviations. For MVP1, the root‑cause assessment led to further technical evaluations of potential engineering solutions. Initial results at CGP2 are very promising. TSIJ will continue assessing the most effective and feasible implementation options. For MVP2, the analysis identified gas escaping through expansion joints at the CGP, which allowed gas to escape to the atmosphere before combustion. Based on these findings, TSIJ initiated a remediation measure involving use of the blast furnace gas on three out of four batteries and the installation of lining pipes to prevent future leakages and to ensure meeting the MVP2 emission limit. As of the reporting date, approximately 2000 pipes have been installed, and the project is ongoing.

In relation to exceedance of Nickel, Chromium and HF at Sinter Plant, TSIJ has mobilised the project team to work on the root cause analysis. As a result of this, material input was changed and continuous measurements were implemented. In addition to the measures taken at the Sinter Plant. In relation to the temporary suspension of DSP operations in April 2026 due to chromium‑6 emission levels exceeding permit thresholds, TSIJ continues to assess and address emission‑related performance at the DSP installation, as reported in the “” section of the Management report.

In relation to exceedance of dust at the Continuous Caster Machine (CGM22), TSIJ implemented measures, including installation of water separators and extra slats, to mitigate emissions at source.

Stichting Frisse Wind has filed a collective action against Tata Steel with the North Holland court, seeking to hold the company liable for damage allegedly caused by emissions of hazardous and/or harmful substances.

Health and a clean living environment are priorities for us. At the same time, stakeholder concerns and regulatory scrutiny remain, and feedback is part of ongoing efforts to reduce emissions, including dust, noise and odour.

Since the inception of steelmaking in the IJmond region, environmental measures have been progressively implemented as part of ongoing operations. The current Roadmap programme builds on this approach, although improvements remain ongoing and subject to further development and regulatory requirements. It reflects input from a broad range of stakeholders, including community representatives, local authorities and regulators. Measures include, for example, targeted reductions in emissions of lead, other heavy metals and PAHs.

Looking ahead, the Green Steel Project will introduce further measures, in line with the commitments set out in the Joint Letter of Intent between the Dutch State and Tata Steel. Through these combined efforts, we aim to contribute to a continuous improvement of the living environment in the IJmond region.

Odour current actions

TSIJ is currently working on odour-reduction measures mandated under the Geurbesluit 2027 (odour regulation, which will only become active from 2027, under the Dutch Omgevingswet), including substantial emission cuts at CGP1, CGP2 and the Basic Oxygen Steel Plant via prescribed reduction factors, alongside the shutdown of older high odour equipment such as Dry Stand 1 and the introduction of new, lower emission drying capacity with afterburners. Additional ongoing actions supporting the reduction include the potential application of vapour condensation technology at the HO6 granulation stack, major odour decreases at Indaver’s ovens, and upgrades to wastewater treatment (CombiBio) and flue gas treatment (DeNOx at PeFa and CGP2).

Water Pollution current actions

TSIJ uses water in its IJmuiden operations for both process use and cooling. These activities generate wastewater that may contain metals, suspended solids, or organic material. All wastewater is treated before discharge to surface waters of the Hoogoven haven and the Staal haven via Rijkswaterstaat approved discharged points. The discharge of wastewater into receiving water bodies is regulated through environmental permits that define allowable discharge volumes, the maximum concentration levels of individual pollutants, and the required monitoring frequency.

Treatment methods (including oil skimming, sand filtration, biological treatment and chemical treatment) are applied depending on wastewater composition. The treatment method depends on the composition of the wastewater. TSIJ monitors wastewater at multiple discharge points, with high-frequency testing at selected critical points to verify compliance with discharge requirements. Where deviations occur, corrective actions are taken (e.g. treatment optimisation or source measures) and reported to Rijkswaterstaat. Compliance is also independently verified by Rijkswaterstaat.

TSIJ is in the process of implementing advanced water treatment systems for new installations using CombiBio technology to improve wastewater quality. CombiBio is currently under construction and is expected to be completed in 2026. CombiBio upgrades TSIJ’s existing Bio2000 wastewater treatment by using biological denitrification, where bacteria are fed with an external carbon source, to break down the nitrate‑rich water stream generated by the DeNOx process, supported by treatment steps such as settling/filtration to remove suspended solids. This technology provides enhanced treatment capacity and is expected to significantly reduce nitrate concentrations in wastewater streams. In addition to nitrogen reduction, it is expected that the treatment plant will also reduce concentrations of other components, including metals.

Soil Pollution current actions

TSIJ has implemented operational controls to prevent soil contamination at its IJmuiden site. Incidents involving more than 50 litres of liquid (classified severe), are promptly reported to the relevant environmental authorities. TSIJ initiates clean-up actions, which are carried out by contracted parties. Following remediation, TSIJ conducts follow-up soil measurements to verify that the affected area has been restored. Only once the contamination has been removed and verification is complete will the incident formally be closed.

The Human Environment and Transport Inspectorate (Inspectie Leefomgeving en Transport (ILT)) and the National Institute for Public Health and the Environment (Rijksinstituut voor Volksgezondheid en Milieu (RIVM)) have highlighted potential environmental and health risks associated with certain steel slag streams, particularly related to leaching of alkaline substances and trace metals, and the generation of dust. These insights are relevant not only for downstream applications of steel slag but also for the handling and temporary storage of steel slag on our IJmuiden site. In this context, the Omgevingsdienst Noordzeekanaalgebied (OD NZKG) has raised concerns about the permissibility of temporary storage of slag. TSN has removed the temporarily stored steel slag to a permissible and suitable location.

Substances of (very high) concern (SVHC) current actions

In December 2025, TSIJ submitted a mandatory inventory for ZZS and the mandatory Avoidance and Reduction Plan (Vermijdings en Reductieplan (VRP)) to avoid or reduce the use of SVHC wherever possible. For this inventory, TSIJ consulted all available information sources, including consultation with external stakeholders, to identify hazardous substances and determine where avoidance or reduction of SVHC is possible.

Upstream pollution current actions

In our upstream value chain, TSN monitors and supports initiatives aimed at minimising harmful emissions and wastewater discharge. TSN expects partners to implement practices that optimise the use of natural resources and mitigate negative environmental impacts throughout the life cycle of their operations and products. For example, effective tailings management in mining is essential to prevent environmental contamination, protect water and soil quality and reduce the risk of tailings dam failures. During the reporting period, TSN engaged with two mining companies on this topic: one operating in the Amazon region, where discussions focused on the management of tailing dams and another involved in tin mining in Brazil, where engagement addressed the management of tailings facilities and associated water emissions. More broadly, TSN asks relevant suppliers to describe their tailings management practices and follows up through challenging suppliers on these during mine visits by TSN staff.

Pollution future actions 

As part of the Tailor-Made Agreement, TSIJ plans to implement a set of measures under the sub-projects Green Steel Phase 1 and “Additional Environmental and Health Measures” including slag processing and storage to reduce air emissions and air immissions. Further emission reductions are connected to the Green Steel Phase 2 that will prepare TSN to reach Net Zero by 2045, and foresees the replacement of Blast Furnace 6 and Coke and Gas Plant 1. The future financial resources expected to be allocated for the implementation of key actions under Green Steel Project Phase 1 are disclosed in the Climate change chapter.

To ensure that the protection of health, people and nature becomes an integral part of daily operations and long-term management control, TSN is developing the HSE Turnaround Programme, a single emissions data platform, to strengthen data governance and reliability. Read more about HSE Turnaround in the Strategy chapter.

Air Pollution future actions

An overview of a non-exhaustive list of key future actions is provided in the table below.

Table. Key future actions related to pollution of air

Key actions

Scope and timeframe

Expected outcome

DRP-EAF

Replacement of Blast Furnace 7 and Coke and Gas Plant 2 through DRP-EAF

IJmuiden-site, Closure Coke and Gas Plant and Closure Blast Furnace planned for Phase 1

~10% PM10 immission reduction

~10% NOx reduction

Raw material processing

Construction of windbreaker

Ore blending field 1 (MV1), IJmuiden, Phase 1

~ 3% PM10, coarse dust reduction

Construction of coverage and shed design

Ore blending field 2 (MV2), IJmuiden, Phase 1

~ 2% PM10, coarse dust reduction

Construction of enclosure design

Scrapyard 3 (SOP 3), IJmuiden, Phase 1

~ 2.5% PM10, coarse dust reduction, noise reduction

Construction of coverage

Ore storage field 2 (EO2), IJmuiden, Phase 1

~ 2% PM10, coarse dust reduction

As part of the Green Steel Project Phase 1, TSIJ plans to construct a Direct Reduction Plant and Electric Arc Furnace (DRP-EAF) replacing Blast Furnace 7 and Coke and Gas Plant 2. This transition will not only reduce TSIJ’s scope 1 CO2 emissions but is also expected to lower fine dust (PM10) immissions and NOx emissions by approximately 10%, alongside reductions in coarse dust, SO2, SVHC, odour, and noise. This 10% as stated expected outcomes in the Joint Letter of Intent should not be understood as targets set by the Management at the time of preparing these Sustainability Statements. These reductions will be achieved through a range of measures, including the installation of encasing and dust extraction systems on conveyor belts, the construction of covered scrapyards SOP4 and SOP5, and a reduction of NOx emissions using a DeNOx installation on the Electric Arc Furnace (via Selective Catalytic Reduction / Selective Non-Catalytic Reduction), as well as by low-NOx burners and an SCR system on the DRP process gas heater. Further details on the DRP-EAF and the associated investments are provided in the Climate change chapter, Future actions and resources.

TSIJ also plans to address fine dust emissions and noise through three initiatives (i) reducing dust from raw materials, (ii) reducing dust from slag storage and processing, and (iii) noise reduction. More information on noise measures can be found in the Affected communities in the IJmond Region chapter, Future Actions and Resources.

A large share of dust emissions originates from TSIJ’s raw material storage and handling areas near the deep-sea harbour, where coal and ores are offloaded, blended and transported. To minimise both coarse and fine dust from these activities, TSIJ plans to enclose these activities by constructing coverages and windbreakers between 2026 and 2030.

  • At Ore Blending Field 1, TSIJ plans to build a windbreaker to reduce wind speeds and associated dust dispersion.

  • Ore Blending Field 2 will be relocated and enclosed in a fully covered hall.

  • Scrapyard 3 is planned to be enclosed in a building equipped with mechanical ventilation and a dry fog system, while acoustic panels will help to reduce peak noise coming from the scrapyard.

  • Ore Stockyard 2 will also be relocated to the current site of Ore Blending Field 2 and fully enclosed.

The processing and storage of steel slag also generates fine dust, particularly during transportation, metal recovery, crushing, and screening, and refinement into a final product suitable for use in construction and other industries. TSIJ is investigating different measures to reduce dust emissions by around 4%.

When the planned EAF is commissioned, EAF slag will be produced and will require cooling. The conventional slow cooling method – using water sprays and heavy machinery – generates steam and dust. To avoid dust formation, TSIJ explores two different options. Implementation is subject to the Tailor-Made Agreement.

Odour future actions

TSIJ will further reduce odour levels in the coming years through the transition to the Green Steel production route, which eliminates CGP2, which is currently one of the strongest contributors to odour nuisance in Wijk aan Zee, and replaces it with the new DRI and EAF facilities whose odour output is significantly lower. Additional planned measures include introducing an active carbon filter technology in 2027 at the pickling line (beitsbaan). This measure will contribute to lowering odour in the Beverwijk area. Additional future improvements include the commissioning of modern odour‑managed units such as the DRP water treatment plant, the DRP desulphurisation system and the EAF fume treatment installation, all designed to release far lower odour loads than the processes they replace. If implemented, the CCS variant will further reduce odour by removing the remaining H₂S‑bearing stream from the DRP desulphurisation vent.

Water Pollution future actions

Further improvements in wastewater quality are anticipated due to the reduced process-water load once Coke and Gas Plant 2 (CGP2) and Blast Furnace 7 (BF7) are taken out of operation at the end of Phase 1.

The future actions described above depend on several external and operational preconditions that may affect TSIJ’s ability to implement them timely and as planned. These are disclosed under "Key dependencies" in the Climate change chapter.

Metrics and targets

Pollution targets

In line with TSN’s ambition to limit its impacts on the local environment and on local residents, the planned actions described above are expected to contribute to reductions in air emissions and immissions, as well as reductions in Substances of Very High Concern (SVHC). TSN is currently working with the Dutch government on the Tailor-Made Agreement, which includes defining the intended direction for future pollutant reduction efforts. As this agreement is still under development and has not yet been formally finalised, TSN is not reporting specific pollutant-reduction targets for this reporting year. Expected outcomes of the future actions reported as part of the Green Steel Project, which is subject to the Tailor-Made Agreement. The stated expected outcomes should not be understood as targets set by the Management at the time of preparing these Sustainability Statements. Due to the planned actions, TSN anticipates that emissions of most pollutants will decrease over time. Some emissions levels may increase with the Green Steel Project, for example, increasing scrap use will have a beneficial impact by increasing circularity and reducing GHG emissions, however it may increase dioxin emissions above today’s level which is well below the Maximaal Toelaatbaar Risico MTR levels (see the Circular economy and resource use chapter). Changes in emissions and immissions will continue to be tracked through TSN’s annual monitoring and reporting process.

Pollution metrics

Pollution of air metrics

During the 2025/26 reporting year, TSN's particulate matter (PM10 and PM2.5) and SO2/SOx remained broadly stable, with year‑on‑year variations within approximately 10%. However, nitrogen oxides (NOx/NO₂) increased by 12%. The increase in NOx emissions reflects operational adjustments that are part of normal process variation across key installation units, including sintermaking, the energy plant and the hot-strip mill. The year-on-year comparison is also affected by improvements in monitoring, which have contributed to a more comprehensive capture of emissions, and by production dynamics, notably the restart of Blast Furnace 6 in early 2024, which lowered the comparative amounts.

Table. Pollution of air

Amount of pollutant emitted

2025/26

2024/25

kg

kg

Nitrogen oxides (NOx/NO2)

5,675,258

5,061,832

Particulate matter (PM10)

386,968

417,179

Sulphur oxides (SOx/SO2)

3,086,814

2,964,740

Fine dust (PM2.5)

168,257

172,610

Note1: particulate matter (PM10) of 1417,179 kg and fine dust (PM2.5) of 172,610 kg of FY 2024/25 in the current report is not comparable with the previous report dust figure of (1,498 kg). This difference arises because in previous year, dust reported number has different scope and methodology. This year, TSN has decided to follow a methodology that monitor PM10 and PM2.5 as separate pollutants which makes this incomparable to last year's dust reported figure. 

Note2: air pollutants values are based on the calender year and not on the reporting year.

Accounting policies for air pollution metrics

Methodology, assumptions and limitations

For the current year, TSN identified the entities in scope for air pollution metrics reporting through a scoping analysis. This analysis applied a threshold focusing on entities with pollutants surpassing the IEPR thresholds listed in the IEPR database. Based on this assessment, the reporting scope includes TSIJ and four TSDEs: Tata Steel Maubeuge SAS, Société Européenne de Galvanisation (SEGAL) SA, Tata Steel Nederland Tubes BV (Oosterhout), and Thomas Steel Strip Corp. For the previous year, only TSIJ is in scope.

For all relevant pollutants, the current year data are based on the interim eMJV report submitted to OD, final amounts are currently under validation by authorities and are subject to change before final publication. The final eMJV report is publicly available on an annual bases after the annual report publication date. The eMJV reporting scope is greater than the scope of pollutants in line with ESRS E2 thresholds. 

An analysis was performed to identify material pollutants to air in line with ESRS E2 Pollution standard requirements. As a result of the analysis, a number of pollutants were identified relevant for reporting. TSN is working on reporting emissions of all relevant pollutants, starting this year with four: NOx, SOx, PM10, and PM2.5 which were reported in previous year. As mentioned in the Strategy chapter, TSN is running the HSE Turnaround programme to improve the accuracy of pollution measurements and reporting. We aim to expand the number of reported pollutants to reflect all material pollutants in line with ESRS E2 thresholds in future reporting periods. 

Air‑emission monitoring and calculation are designed around permit requirements and measurement plans. Material pollutants include those that exceed the IEPR Annex II release thresholds (TSIJ and TSDE) as well as additional pollutants identified as relevant in the context of TSIJ’s ongoing discussions with the Dutch authorities on future environmental performance, with the list reviewed annually based on e‑MJV data and data from downstream entities.

TSIJ reports the annual mass of each material air pollutant emitted from its operations, expressed as kg/year. Emissions are calculated annually in connection with the e‑MJV process using a combination of direct measurements and calculations: pollutant emissions = measured pollutant concentration (or emission factor) × relevant process/activity data, with conversions applied to derive annual totals.

Input data come from (i) measurement results (sampling and/or monitoring performed by accredited internal or external laboratories following NEN standards in accordance with the site measurement plan under environmental permits) and (ii) process data provided by the respective working units (e.g., production volumes, gas flows, operating hours, energy use, batch counts). Based on the measurement data and process data collected, different approaches are used to determine the total amount of pollutants released during the year.

Where emissions are continuously measured, the reported figures are based directly on these monitoring systems operated by the responsible production units. In some cases, emissions are not measured continuously but are instead estimated using stable and well‑understood emission factors, which are typically applied for smaller emission sources and updated periodically.

For pollutants measured per hour, measured emission rates are combined with the number of operating hours to calculate annual emissions. Where measurement data is available as volumes or concentrations, this information is combined with process data — such as material quantities or flow rates — and converted into total emissions using appropriate calculation factors. In situations where both concentration data and process volumes are required, these inputs are combined to reflect actual operating conditions.

Where measurements are periodic rather than continuous, TSIJ applies the assumption that measured concentrations remain representative until the next measurement; where operating hours cannot be tracked directly, shift schedules or production planning may be used as an estimate. Limitations therefore relate mainly to measurement frequency (some pollutants are measured only periodically) and the use of estimates for operating time in specific cases. 

The reporting boundary for reporting pollution does not include the Velsen Power Plants (acquisition recognised in the Financial Statements as of 1 January 2026). TSN is using the relief for mergers and acquisitions for the 2025/26 reporting period. We will analyse materiality of impacts, risks and opportunities in relation to the acquired power plants and identify material information to be reported in the 2026/27 Sustainability Statements. Preliminary analysis points at likely materiality of the impacts related to the topic of pollution, particularly air pollution.

Pollution of water metrics

For the 2025/26, water pollution emissions were primarily driven by nutrient and organic discharges. Total nitrogen represented the largest share of emissions, amounting to 494,389 kg, followed by total organic carbon (TOC) at 156,055 kg, reflecting the significance of process water and wastewater streams. Fluorides also constituted a material contribution, with emissions of 129,450 kg, indicating their widespread presence across operations. Moderate emission levels were reported for specific hazardous substances, including halogenated organic compounds (AOX) at 11,756 kg, total phosphours at 7,926, and cyanides at 5,322 kg. Emissions of heavy metals such as zinc, nickel, lead, arsenic and mercury were comparatively low by mass with a total of 1,451 kg. Overall, the emission profile indicates that water pollution for the reporting year was dominated by nutrients and organic substances, while emissions of metals and other toxic substances were limited in comparison.

Table. Pollution of water

Amount of pollutant emitted

2025/26

kg

Arsenic and compounds (as As)

39.1

Cyanides (as total CN)

5,322

Fluorides (as total F)

129,450

Halogenated organic compounds (as AOX)

11,756

Lead and compounds (as Pb)

156.9

Mercury and compounds (as Hg)

1.7

Nickel and compounds (as Ni)

270.6

Total nitrogen

494,389

Total organic carbon (TOC) (as total C or COD/3)

156,055

Total phosphorus

7,926

Zinc and compounds (as Zn)

983.4

Note1: water pollutants values are based on the calender year and not on the reporting year. 

Accounting policies for water pollution metrics

Methodology, assumptions and limitations

TSN identified the entities in scope for water pollution metrics reporting through a scoping analysis. This analysis applied a threshold focusing on entities with pollutants surpassing the IEPR thresholds listed in the IEPR database. Based on this assessment, the reporting scope includes TSIJ and one TSDEs: Thomas Steel Strip Corp.

Water‑pollution measurement and reporting are site‑ and permit‑driven, reflecting the characteristics of the receiving waters and discharge points at TSIJ and TSDE. Monitoring frequency and thresholds are defined through applicable permits and are designed to capture variability in flows (including seasonal cooling demand and rainfall effects) and pollutant concentrations. Material pollutants include those that exceed the IEPR Annex II release thresholds (TSIJ and TSDE), with the list reviewed annually based on e‑MJV data and data from downstream entities. TSIJ reports the annual mass (load) of material water pollutants discharged from steelmaking activities to receiving waters, expressed in kg/year per pollutant.

Pollutant load is calculated as Load = Concentration × Volume, where concentrations are derived from a combination of manual and automatic sampling analysed by an accredited laboratory and volumes are based on metered flows or, where necessary, calculated volumes (including certain rainwater‑influenced streams); quarterly loads are summed to derive annual totals to reflect seasonal variability. Key assumptions/limitations include that some discharge volumes can be influenced by rainfall capture at certain points and that a limited number of streams (e.g., specific scrapyard and selected process streams) are calculated rather than directly metered.

The current year data are based on the interim eMJV report submitted to OD, final amounts are currently under validation by authorities and are subject to change before publication. The final eMJV report is publicly available on an annual bases after the annual report publication date. 

Substances of very high concern metrics

For substances of very high concern (SVHC) emitted to air and water, TSN is monitoring and reporting relevant SVHC using a site‑ and permit‑based approach. Emission points, monitoring frequency, and thresholds are defined in the applicable permits. SVHC emitted to air and water are periodically reported to ZZS.

As mentioned in the Strategy chapter, TSN is running the HSE Turnaround programme to improve accuracy of pollution measurements and reporting. We aim to include metrics for (SVHC) emitted to air and water in line with ESRS E2 in future reporting periods. Detailed information on our HSE Turnaround programme is included in the Strategy chapter.

For substances of very high concern (SVHC) used in production metrics, TSN is currently working on establishing robust and reliable reporting and data collection processes. We aim to include metrics for SVHCs used in production in line with ESRS E2 in future reporting periods. 

Soil pollution metrics

Soil pollution metrics are not reported for the current reporting year. TSN is curruntly working to strengthen and improve data quality and establish robust and reliable reporting processes. Reporting on soil pollution‑related metrics is expected to be included in future reporting periods once data quality improvements have been completed.