European recyclers to fight proposed EU metal waste export ban: CMA

The Circular Metal Association — which represents metal recyclers in Europe and Germany — said the European Commission was treating recycled metals differently from other waste streams and that it intended to fight proposed export restrictions, according to a statement emailed to Platts Sept. 24.

The draft delegated act under the Waste Shipment Regulation, published by the European Commission Sept. 18, will cut the majority of non-OECD countries off EU supplies of recycled steel and nonferrous metals from May 21, 2027.

The commission is looking to reduce EU annual exports of steel scrap by 4 million-4.1 million metric tons, or 25%-26%, and of aluminum scrap by 76% or 970,600 mt, with the volumes equivalent to shipments in 2025 to non-OECD countries that it does not want to authorize to receive European metal waste.

India, Egypt, Pakistan, China, Thailand and Morocco would be among the countries most affected by the respective restrictions.

The Waste Shipment Regulation states that non-hazardous waste may be exported for recovery to non-OECD countries that have demonstrated they treat such waste in an environmentally sound manner. But "the Commission applies a significantly stricter standard to recycled metals than to other types of waste," says CMA President Murat Bayram.

It assumes from the outset that recycled metals pose higher environmental and health risks than many other waste streams on the grounds that they may contain toxic heavy metals and are not biodegradable.

"Here, a single group of materials is being prejudged across the board, without any factual basis. The result is an export ban on the most important sales markets," Bayram said.

The association is calling on the commission to abandon the special criteria for metals and instead to apply the procedure set out in the Waste Shipment Regulation, under which treatment processes in the recipient country are assessed to determine whether exports there should continue.

"Closing off international markets creates neither additional demand nor greater competitiveness in Europe," Bayram said. "If European metal producers do not take up the available volumes, sales markets will disappear, material values will come under pressure and surpluses will grow."

Raw-material export restrictions reach record high

The association's view echoes that of broader German industries.

In its September recommendations to the EU and German governments, the German Chamber of Commerce and Industry, or DIHK, said that export restrictions on critical raw materials globally have reached a historic high, increasing fivefold since 2009. Governments increasingly use them as industrial policy tools, while shifting from duties and quotas toward more aggressive measures; as a result, bans accounted for 25% of all new export restrictions in 2024.

Waste and scrap have become the most restricted categories of critical raw materials, driven by environmental and circular economy goals, the DIHK notes.

However, the organization representing three million companies in Germany argues that export restrictions are not sustainable tools for securing raw materials: they distort business relationships, reduce sales opportunities for European scrap suppliers, and routinely trigger retaliatory trade measures.

"If the EU begins to withhold secondary raw materials, other states might restrict their exports ... even more heavily. This would further fragment global raw material markets and exacerbate trade conflicts," the DIHK says. It adds that mandatory recycled-content quotas, for example, in batteries, can only be achieved through free and global trade in secondary raw materials.

The majority of the German business community believes export barriers on waste and scrap should only ever be used as an absolute last resort, if strategic material streams are flowing out in significant volumes, posing a severe risk to domestic supply. If the EU implements restrictions for economic security, they must be highly targeted, time-limited and regularly evaluated, the DIHK said and recommended alternatives.

The EU should negotiate binding provisions against export barriers in its bilateral trade deals, dismantle discriminatory dual-pricing mechanisms used by some countries, including Chile and Mercosur, and proactively initiate WTO dispute proceedings against unfair trade barriers, mirroring successful cases against China and Indonesia.

Instead of turning protectionist, the EU government should focus on making Europe an attractive location for recycling and reprocessing, in which secondary raw materials are highly competitive with primary raw materials.

To achieve that, the EU needs to slash bureaucracy, fast-track permits for processing plants, clarify confusing legal definitions regarding waste versus product and by-product status, and invest in research to boost resource efficiency, the DIHK says.

The potential of industrial symbioses should also be given greater consideration, as inter-company utilization of by-products and residual materials can unlock additional sources of raw materials, according to the DIHK.