In a decision on objection from Tata Steel, the Executive Council (GS) of North Holland upholds the earlier decision of the Environmental Service North Sea Canal Area (OD NZKG) regarding the notice concerning Coke Gas Plant 2 (KGF2) of Tata Steel.

With the notice dated December 19, 2024, Tata Steel was given the opportunity to rectify the violations within 12 months and thereby comply with the regulations. If it appears that the violations have not been remedied and it becomes clear that KGF 2 cannot be brought into compliance with the rules, the OD NZKG will consider the step towards revoking the permit for KGF 2. 

Extensive Investigation

The notice followed after the OD NZKG conducted an extensive investigation into compliance with the rules at KGF 2. The investigation by OD NZKG into KGF 2 revealed the following shortcomings:

  • Poor condition of the oven walls
  • Lower filling level of the ovens to postpone necessary maintenance
  • Failure to repair oven walls as soon as possible
  • Failure to act in accordance with an approved inspection and maintenance plan for oven walls
  • Poor maintenance condition
  • Emission of black/dark gray smoke plumes from the battery chimneys
  • Unacceptable degradation of KGF 2

Objection from Tata Steel and Advice from Hearing and Advisory Committee

Tata Steel objected to the notice decision. The objection concerns various parts of the notice decision. The Hearing and Advisory Committee (HAC) issued advice to GS after a public hearing on April 24, 2025, regarding Tata Steels objection. The main point of the HAC advice is that the OD NZKG should have better motivated the decision. The key points are the proportionality of the decision and that it has not been conclusively established that the black plumes are caused by leaks through the oven walls.

Decision on Objection

Based on the HAC advice, GS made the decision on objection on December 9, 2025. The earlier notice was further substantiated. For this further substantiation, the OD NZKG conducted additional research between April and August 2025.

GS gave Tata Steel another opportunity to submit a viewpoint (“hearing”) as part of the legal procedure based on the results of this additional research. The response to this additional viewpoint is included in the decision on objection.

The essence of the decision is the same as the notice decision from last December: Tata Steel must demonstrably have ended the violations at KGF2 and comply with the rules by December 24, 2025. If it appears that the violations have not been ended and it becomes clear that KGF 2 cannot be brought into compliance with the rules, the OD NZKG will consider the step towards revoking the permit for KGF 2.

Follow-up Process

The objection procedure is now completed. The next important step follows after the 12-month period expires. After December 24, 2025, the OD NZKG will conduct inspections at KGF 2 to determine whether KGF 2 has been brought into compliance with the rules. Depending on the situation observed by the OD NZKG, the revocation of the permit may be initiated.

Tata Steel can appeal (and subsequently appeal further) against this decision on objection. Any decision to revoke the permit for KGF2 is a separate new decision. Tata Steel can submit a viewpoint against that decision, after which appeal and further appeal are again possible. 

Download of the letter to Provincial States about the decision on objection (pdf)