The Jacques Delors Institute warns that the EU's Steel & Metals Action Plan creates a complex "green spaghetti bowl" of overlapping regulations beyond the Carbon Border Adjustment Mechanism. The cumulative framework includes low-carbon labeling, circularity requirements, & permanent safeguard measures that could disincentivize global decarbonization. Small enterprises face particular challenges due to limited compliance capacity, while high tariffs may eclipse green premium benefits for international producers.