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1Scan for outdated or missing drivers - takes under a minute2Repair Windows errors before they cause bigger problems3Fix the driver behind crashes, sound loss and screen glitchesTo verify whether steel is “recycled,” do not rely on a percentage printed in a brochure. Require a product-specific declaration that defines the percentage by mass, distinguishes pre-consumer from post-consumer material, states the production period and calculation method, and explains whether the content is physically present in the delivered steel or attributed through a mass-balance chain of custody. Then review the product’s Environmental Product Declaration (EPD) separately for greenhouse-gas and other life-cycle impacts, and verify any steelmaking-site certification independently.
These are three different evidence questions: what recycled material is claimed in the product, what environmental impacts are reported for the product, and whether the supplying site follows an independently audited standard. A credible construction submittal answers all three without treating one document as proof of the others.
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What “recycled steel” can mean
Steel is made from iron-bearing inputs in different process routes, and recycled material can enter the charge as scrap. A claim is meaningful only when its boundaries are explicit. ISO 14021:2026 defines recycled content as the proportion by mass of recycled material in, or attributed to, a product or component. That definition allows more than one accounting approach, so the word “recycled” alone is not a sufficient specification.
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Percentage by mass
Ask for the recycled-content percentage on a mass basis, not a vague statement such as “contains recycled steel.” The declaration should identify the denominator: the mass of the finished steel product, a product family, or another defined unit. It should also identify whether alloying additions, coatings, fabrication losses, and purchased semi-finished material are included or excluded.
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Pre-consumer and post-consumer material
Pre-consumer material is recovered from manufacturing or processing before it reaches a consumer use. Post-consumer material is recovered after a product has been used and discarded. A supplier should report the categories separately when the project rule distinguishes them. A single combined percentage can conceal a material difference between the bids.
Physically present content versus mass-balance attribution
Under a physical-content claim, the supplier links the reported recycled material to the steel supplied through a defined production and traceability system. Under a mass-balance model, recycled inputs and other inputs may be processed in a shared system, with an equivalent amount of recycled content attributed to products according to documented rules. ISO 14021:2026 notes that mass-balance attribution cannot guarantee the claimed content in every individual supplied product. The contract should therefore state whether the project accepts attributed content and what records must support it.
Product, site-average and attributed claims
A percentage may describe one heat, one coil or bundle, a product family, an annual facility average, or an allocation across a chain of custody. These are not interchangeable. Record the exact scope in the submittal and do not convert a site-wide average into a guarantee for each shipment unless the supplier expressly provides that guarantee.
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|---|---|---|
| Product-specific physical content | Declared recycled material is linked to the identified product and production records. | It does not by itself prove lower greenhouse-gas emissions or responsible site management. |
| Site or period average | An average percentage for a defined facility and reporting period. | It does not show that every delivered item has the average percentage. |
| Mass-balance attribution | Recycled input is allocated to products under a documented chain-of-custody method. | It cannot guarantee the physical percentage in an individual supplied product. |
| Unqualified marketing statement | Only that the supplier uses the word “recycled.” | It provides no usable basis for acceptance. |
Set the project rule before reviewing bids
There is no universal recycled-content threshold for every construction project. Requirements depend on the governing jurisdiction, owner policy, funding conditions, contract language, product type and applicable structural or building code. Before contacting suppliers, identify exactly what the project must disclose or achieve.
- State whether the project requires a minimum recycled-content percentage, disclosure only, or a preferred attribute.
- Define whether pre-consumer material, post-consumer material, or both count.
- Decide whether mass-balance attribution is acceptable and what proof is required.
- Identify the steel products covered: reinforcing bar, plate, sections, sheet, wire, hollow sections or fabricated assemblies.
- Set the reporting period and whether a product-specific, heat-specific, shipment-specific or facility-average declaration is acceptable.
- Specify the required EPD program, product category rules (PCR), life-cycle modules and declared or functional unit.
- State substitution rules for a different grade, mill, facility, process route or product form.
- Require confirmation that the proposed steel meets design strength, toughness, weldability, coating, fire and durability requirements.
Put these rules in the invitation to tender and submittal schedule. If they appear only in an informal sustainability preference, suppliers may submit incomparable claims and the project team may be unable to reject an unsuitable substitution later.
Request a complete recycled-content declaration
Ask the bidder for a signed statement tied to the proposed manufacturer, facility and product. The following sequence makes the review repeatable.
- Name the product and source. Record the manufacturer, steelmaking facility where available, product designation, grade, form, sizes and anticipated delivery period.
- State the percentage and mass basis. Require the recycled-content percentage by mass and the denominator used in the calculation.
- Separate material categories. Request pre-consumer and post-consumer percentages, plus the definition used for each category.
- Describe the accounting method. Ask whether the figure is based on physical segregation, book-and-claim, mass balance, or another chain-of-custody approach.
- Define the time period. Record the production or reporting dates and whether the percentage is a one-time value, a rolling average or a recurring annual declaration.
- Identify the claim scope. Mark the statement as product-specific, heat-specific, shipment-specific, product-family, site-average or attributed.
- Ask about delivery assurance. Require the supplier to say explicitly whether the delivered steel itself is guaranteed to carry the stated percentage, or whether the claim applies only at an aggregated accounting level.
- Obtain traceability records. Request heat numbers, mill certificates, chain-of-custody statements, allocation records or other documents that connect the declaration to the proposed supply.
- Record exclusions and assumptions. Capture whether coatings, fabrication, scrap generated during production, purchased billets or imported semi-finished material affect the calculation.
- Set change control. Require advance approval for a different facility, production route, product family, reporting period or accounting method.
A supplier that cannot answer these questions may still provide compliant steel, but its recycled-content claim is not sufficiently defined for a controlled procurement decision.
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How to read the steel EPD
An EPD is an independently reviewed life-cycle declaration, not a recycled-content certificate. It can report greenhouse-gas emissions and other impacts for a defined steel product, but only within the scope and assumptions stated in the document. ISO 21930:2017 gives core rules for construction-product EPDs and complements ISO 14025; ISO identifies a 2026 edition of ISO 14025, so confirm the current standard and the applicable PCR when writing the specification.
Check applicability before looking at the headline number
Match the EPD to the steel being bid. Check the manufacturer, facility or facilities, product family, grade and product form. Confirm the EPD’s issue and expiry dates, geographic coverage, electricity data and whether the document covers the proposed production route. A generic EPD may be useful for screening but is not equivalent to a facility-specific declaration when the project requires the highest-resolution available data.
Verify the declared or functional unit
Steel EPDs commonly report impacts per mass of product, but the exact declared unit must be read from the document. Do not compare a result per tonne with one per kilogram, or compare a product declared unit with a structural functional unit, without conversion and a clear explanation. If fabrication, transport or installed performance is part of the project question, an A1–A3 result alone may not answer it.
Read the system boundary and life-cycle modules
Identify which modules are included. A1–A3 generally cover raw-material supply, transport to the manufacturer and manufacturing (the product stage), while later modules may cover transport to site, construction, use, replacement, end of life and benefits beyond the system boundary. Two EPDs with the same declared unit are not directly comparable if one reports only A1–A3 and the other includes additional stages.
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Check the PCR and allocation rules
The PCR sets category-specific calculation rules. Confirm that both EPDs use the same or demonstrably compatible PCR, version and program instructions. Review allocation for scrap, co-products, recycled inputs and recovered material. Differences in allocation can materially change reported results even when the physical steel is similar.
Assess data quality and specificity
Look for the proportion of primary, plant-specific data; the age of background datasets; geographic and electricity assumptions; and any cut-off, proxy or estimated data. A product-specific EPD with current facility data generally answers a procurement question more precisely than an industry-average declaration, but it still must be checked for boundary and PCR compatibility.
| EPD field | Acceptance question | Reason it matters |
|---|---|---|
| Manufacturer and facility | Does it cover the proposed source, or clearly state the facilities included? | Production route and energy mix can vary by site. |
| Product scope | Does the grade, form and product family match the bid? | A bar, plate and coil may have different processes and data. |
| Declared or functional unit | Are units identical or legitimately convertible? | Unlike units produce misleading rankings. |
| Modules and boundary | Are the same life-cycle stages included? | A1–A3 cannot be ranked against a full-life result without adjustment. |
| PCR and version | Are the category rules compatible and current? | Calculation rules affect allocation and reported impacts. |
| Validity and verifier | Is the document current and third-party verified under its program? | An expired or unverified declaration is weak procurement evidence. |
| Data quality | How much is facility-specific primary data versus generic background data? | Specificity affects how well the result represents the proposed steel. |
Compare recycled content and greenhouse-gas intensity separately
Recycled-content percentage and greenhouse-gas intensity measure different things. A higher recycled-content figure does not, by itself, prove lower emissions or better overall environmental performance. Process route, electricity generation, fuel use, raw-material preparation, yield, transport and allocation can all affect the EPD result.
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For an emissions comparison, align all of the following before ranking suppliers:
- the declared or functional unit;
- the manufacturer and facility scope;
- the steel grade and product form;
- the system boundary and included modules;
- the PCR, standard and version;
- allocation rules for scrap, co-products and recycled inputs;
- electricity mix, fuel assumptions and geographic data;
- the reporting period and dataset age;
- the treatment of transport, fabrication and end-of-life; and
- the level of third-party review and data quality.
worldsteel’s chain-of-custody guideline, version 1.2 (February 2026), recommends reporting cradle-to-gate greenhouse-gas intensity without burdens or credits associated with end-of-life scrap recycling, using a recognized methodology and a third-party-verified report such as an ISO 14025-conformant EPD. Its instruction is explicit: “Calculate the ‘cradle to gate’ GHG emissions intensity without burdens/credits associated with end-of-life scrap recycling.” Apply that rule consistently when the project is comparing steel-product emissions.
Do not rank unlike EPDs by one bold number. If one declaration includes only A1–A3 and another includes end-of-life credits, explain the difference or obtain comparable results. ResponsibleSteel’s 2026 reporting also emphasizes that methodological differences can significantly affect product-level greenhouse-gas values; transparency, comparability and consistency are therefore procurement requirements, not optional presentation details.
Verify EPD assurance and steelmaking-site assurance independently
EPD verification
Check the EPD program operator, independent verifier, verification date, standard basis and validity period. Confirm that the verifier reviewed the actual declaration and that the product scope matches the bid. Keep the accepted PDF and verification information in the project record.
ResponsibleSteel site certification
ResponsibleSteel certification is site-based. Its current standards page identifies International Production Standard v2.1.1, launched in October 2024, with requirements related to greenhouse-gas emissions and sourcing input materials. Core Site Certification evaluates more than 300 core requirements. The Certified Steel designation adds progress-level auditing for decarbonisation and responsible materials sourcing.
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A site certificate can provide useful assurance about management practices and site performance, but it does not automatically prove the recycled content of a particular shipment. Verify the certificate number, site identity, scope, status and expiry independently, then match it to the mill named in the product and EPD documents. Treat the certificate and the recycled-content declaration as separate submittal items.
Jurisdiction-specific disclosure: the Canadian example
The Government of Canada standard illustrates why the governing rule must be identified first. For projects covered by that standard, procurement documentation calls for disclosure of A1–A3 greenhouse-gas emissions and, where available, recycled steel content, substantiated by qualifying EPDs. It also calls for the highest-resolution available source and facility-specific steelmaking data.
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This is an example of a covered Canadian procurement regime, not a global requirement. A project in another country, province, state or municipality may use different modules, thresholds, definitions or verification rules. Cite the actual project standard in the tender and state what happens when recycled-content data are unavailable: disclosure, an approved alternative, or non-compliance.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.Build the evidence into the tender and submittal review
Use a schedule that lets the design, sustainability and procurement teams review the same facts. A practical submittal should contain:
- the recycled-content declaration with percentage, mass basis, material categories and accounting method;
- the reporting period and claim scope;
- the physical-versus-attributed delivery statement;
- manufacturer, facility, product family, grade and product-form information;
- the current EPD, program operator, verifier, PCR, declared unit, modules and validity dates;
- the facility or site certificate, if required, with scope and status;
- mill certificates and traceability records connecting the accepted documents to deliveries;
- confirmation of structural, durability, welding, coating and code compliance; and
- the proposed process for approving substitutions or changes in source.
Assign each requirement an acceptance status such as accepted, clarification required or rejected. Preserve the final accepted declaration, EPD, certificate and traceability records with the contract and closeout documents. This prevents a sustainability claim from being lost when a mill, grade or product form changes during construction.
Common failure modes and how to correct them
“Made with recycled steel” without a percentage
Problem: The statement has no mass basis or material definition.
Correction: Request a signed percentage by mass, pre-consumer/post-consumer split, calculation method and reporting period.
A site-average percentage treated as a shipment guarantee
Problem: An annual or facility average is presented as the content of every beam or bar.
Correction: Label it as an average and obtain a product- or shipment-level guarantee if the contract requires one.
Mass balance hidden in general language
Problem: The buyer assumes the physical steel contains the stated percentage.
Correction: Require explicit disclosure of mass-balance attribution and state whether the project accepts it.
Recycled content used as a proxy for low carbon
Problem: A high recycled-content number is used to select the lowest-emission product without comparable EPDs.
Correction: Compare aligned EPD results and document the boundaries, PCR, data quality and allocation assumptions.
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EPDs compared across incompatible scopes
Problem: Different units, modules, PCR versions or facility scopes are ranked together.
Correction: Normalize the comparison or report the results as not directly comparable.
Expired or generic EPD accepted for a specific mill
Problem: The document does not represent the proposed source or is outside its validity period.
Correction: Obtain a current, applicable declaration or record the limitation and obtain the owner’s written acceptance.
Site certification treated as product certification
Problem: A site certificate is offered as proof of recycled content in a shipment.
Correction: Verify the site certificate separately and require the product-level recycled-content evidence.
Substitution made without re-review
Problem: A different mill or product family is supplied after bid acceptance.
Correction: Make source, grade, EPD and recycled-content documents conditions of substitution approval.
A decision framework for accepting a claim
Accept a recycled-steel submittal only when each applicable question has a documented answer:
| Decision question | Accept when | Hold or reject when |
|---|---|---|
| Is the claim defined? | Percentage, mass basis, material categories, method and period are stated. | The supplier uses only an unqualified marketing phrase. |
| Does the scope match the supply? | Manufacturer, facility, product family, grade and form are identified and consistent. | The evidence covers a different product or an unidentified source. |
| Is physical or attributed content clear? | The declaration states the accounting model and delivery assurance. | Mass balance is implied or concealed. |
| Is the EPD fit for purpose? | Unit, modules, boundary, PCR, validity and data quality meet the project rule. | Results are compared despite incompatible scopes. |
| Is assurance adequate? | EPD verification and any site certificate are current, authentic and correctly scoped. | Documents are expired, unverifiable or unrelated to the proposed source. |
| Does the steel perform as specified? | Grade, dimensions, fabrication and code requirements are confirmed by the design team. | Sustainability evidence is used to waive engineering requirements. |
What a defensible conclusion looks like
A defensible procurement record does not simply say “recycled steel approved.” It identifies the percentage and definition, says whether that percentage is physically present or attributed, names the product and facility, cites the applicable EPD scope and verification, records the aligned greenhouse-gas result, and confirms structural and code compliance. If a data point is unavailable, state that limitation and apply the project’s documented alternative rather than filling the gap with an assumption.
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