We welcome many of the proposals in the action plan, particularly those recognising the vital role of circularity in decarbonising the metals industry. The acknowledgment that recycling can save up to 95% of the energy required for primary aluminium production and up to 80% for steel production accurately reflects the environmental benefits of our industry.
The proposed measures to stimulate demand for recycled materials through recycled content targets for key sectors are a positive step toward creating markets for recycled raw materials. We also support the intention to improve recyclability and recycled content requirements for additional product groups, as well as prioritising design for recycling that facilitate the separation of copper components from steel and aluminium fractions.
However, we must express serious concerns regarding certain trade-related proposals: The plan considers reciprocating export restrictions and potentially introducing “export fees or duties” for recycled metals. Such measures risk creating new trade barriers that would harm the functioning of global recycling markets and especially European metal recyclers.
European recyclers have repeatedly emphasised that currently 80% of the recycled materials processed in Europe are utilised by the internal market, whereas the remainder is exported due to lack of domestic demand. For this reason, it is essential to put in place measures to stimulate the uptake of recycled materials in Europe instead of contemplating new measures that could undermine the open trade of recycled metals.
The premise that these exports in some way relate to the availability of recycled material in the EU misrepresents the reality of global recycling markets. Recycled metals are exported because domestic demand in the EU is insufficient to absorb the available material. There is no “scrap leakage”.
As the voice of European and global recyclers, we strongly warn against introducing additional restrictions on recycled metals exports, beyond those already established in the revised Waste Shipments Regulation. Metals recyclers around the world have worked tirelessly in the past months, alongside their governments, to prepare for the stringent requirements introduced by the new rules which will ensure that receiving countries for EU recycled metals abide by high standards of environmental resource management. Further limitations to open trade would seriously injure the European and global recycling industry and goodwill of the EU’s trade partners.
Contrary to the assertion that recycled metal exports lead to lower sustainable treatment practices, these materials are valuable resources that are utilised efficiently in receiving countries. Restricting their movement would potentially lead to:
- Price pressures for recyclers in the EU, threatening the economic viability of collection and processing operations.
- Reduced collection rates for end-of-life products containing metals, due to the lack of sufficient demand for recycled metals.
- Distortion of global recycling markets and supply chains, leading to lower circular material use rates around the world.
We urge the Commission to:
- Disregard possible trade restriction proposals on recycled metals: To support the development of a well-functioning market for cycled metals it crucial to ensure open trade. Currently, recycled metals are exported because domestic demand in the EU is insufficient to absorb the available material.
- Introduce mandatory recycled content targets for metals products: To support the creation of such demand, we welcome the introduction of mandatory recycled content targets for metal products, including those that represent lead markets, such as the automotive and construction industry.
- Harmonise waste classification: Accelerate efforts to create a harmonised classification system for recycled metals and establish clear EU-wide end-of-waste criteria.
- Support domestic recycling infrastructure: Direct investment toward upgrading and expanding EU recycling facilities to process more recycled metals domestically. This should also include measures to grant European recyclers access to metallic waste to process.
- Build positive relationships with trade partners to maximise circularity: The EU’s climate and circular economy ambitions would be best served by working closely with trade partners for recycled metals to build predictable and supportive markets.
- Engage recycling industry stakeholders: Ensure the recycling industry is fully represented in discussions on implementing measures, particularly those related to circularity and trade.
