As the European and global voices of the recycling industry, our organisations collectively represent the interests of thousands of recycling companies. EuRIC, through its Member Federations across 23 EU & EFTA countries, significantly contributes to the European economy with a turnover of over 95 billion euros, providing over 300,000 local green jobs across Europe. BIR represents over 30,000 global companies through 36 national member associations and over 1,000 direct corporate members across 71 countries.
Our organisations are particularly concerned about the intention expressed by representatives of Belgium, Italy, France, Luxembourg, Romania, Slovakia, and Spain to “secure access to raw materials while retaining steel scrap within the EU” and the proposal to “restrict or ban exports to third countries that do not adopt environmental and production legislation similar to that of Europe.”
These proposals are based on demonstrably incorrect premises that require immediate correction:
The European recycling industry processes over 100 million tonnes of steel annually, with approximately 80% of the total output utilised domestically. The remaining 20% is exported, precisely because the EU lacks the capacity to utilise all available recycled steel. This is not a “leakage” but rather an efficient allocation of resources in a functioning market.
Recycled steel — which we prefer to call by this name rather than “scrap” to reflect its true value — is exported because it is a commodity whose value is recognised by global markets. Decades of experience through established recycling supply chains and stable international trade have enabled European recycling companies to become world-leading facilities that set global standards for efficiency and environmental performance.
Following the adoption of the Waste Shipments Regulation (WSR), metal recyclers will already face increased challenges when exporting recycled steel. Bureaucratic and stringent control measures on valuable recycled steel represent an obstacle towards increased circularity. Implementing additional export restrictions, when no material shortage exists, would artificially suppress prices of recycled steel. Introducing such barriers will predictably lead to counterproductive results:
- Reduced collection and processing rates of metal “waste” as economic incentives diminish
- Decreased investment in recycling infrastructure
- Market exit of numerous recycling companies as their business models become unsustainable
- Reduction in material availability as the recycling ecosystem shrinks
The suggestion that exported recycled steel somehow contributes to environmental degradation in receiving countries fundamentally misrepresents the nature of the material. Rather than fitting the definition of what is commonly refined as waste, recycled steel is a valuable commodity, used as feedstock for steel manufacturing worldwide.
Cutting off access to European recycled steel would force many global producers to revert to more carbon-intensive Basic Oxygen Furnace (BOF) production, dramatically increasing global emissions and openly contradicting Europe’s climate leadership ambitions.
Constructive alternatives exist
Rather than pursuing counterproductive trade restrictions, we propose genuine solutions to promote circular steel economies:
- Create lead markets for circular steel through mandatory recycled content targets in key sectors
- Implement public procurement policies that prioritise recycled materials
- Support investment and R&D for the recycling industry
- Ensure recyclers are meaningfully included in policy discussions and decision-making processes
The European Recycling Industries’ Confederation and the Bureau of International Recycling remain steadfast in their commitment to advancing a truly sustainable and circular economy for metals. We believe that well-functioning markets, not artificial barriers, are the foundation of environmental progress.
As the recycling industry continues to innovate and invest in technologies that maximise resource efficiency, we invite all stakeholders—producers, consumers, and policymakers alike—to engage in evidence-based dialogue that recognises the essential role recyclers play in building a more sustainable future. Together, we can develop approaches that harness rather than hinder the power of international markets to drive genuine circularity.
