EU proposes export restrictions as 19M tonnes of metal scrap leave Europe annually

The European Commission (EC) has unveiled its Steel and Metals Action Plan, setting out a framework to increase the use of recycled metals within the European Union (EU). The plan seeks to address a key contradiction: while recycling offers significant environmental and economic benefits, large quantities of metal scrap continue to be exported outside of Europe.

The Commission has outlined a two-pronged approach to resolve this issue – stimulating demand for recycled metals within the EU while exploring restrictions on scrap exports.

“Enhancing circularity is an important pathway for the decarbonisation of metal industries,” the Commission states, positioning increased recycling as a strategic necessity for reducing dependency on imported primary raw materials while cutting emissions.

Challenge of scrap metal exports

According to the plan, recycling can deliver substantial environmental benefits, with potential energy savings of up to 95 per cent for aluminium and 80 per cent for steel production compared to primary production methods.

However, the volume of scrap used for recycling in the EU is diminishing due to two key factors: a lack of demand from the EU-based metal industry and higher prices offered by buyers in external countries. In 2021, ferrous scrap exports reached 19.43 million tonnes, representing approximately 20 per cent of all scrap generated in the EU. The Commission notes that aluminium scrap exports continue to rise, with a new record expected in 2024 as exports exceed 1.3 million tonnes.

The Commission attributes this “scrap leakage” to trade distortions like subsidies and unfair market conditions in other countries, which allow them to pay higher prices for European scrap. This trend is undermining Europe’s circularity goals and reducing the availability of secondary raw materials for domestic industries.

The Transition Pathway for the European Metals Sector, a support document to the action plan, further identifies additional barriers to effective recycling. These include inadequate sorting and collection systems, increasing product complexity and improper treatment, and regulatory inconsistencies that hinder the movements of scrap within the EU.

The document also highlights the issue of ‘tramp elements’ – impurities that accumulate in recycled metals and cannot be easily removed. This challenge will become more significant as the proportion of scrap used in production increases relative to virgin materials.

Proposed measures to boost circularity

The action plan sets out a series of measures aimed at increasing the use of recycled metals in European industry. These include:

• A feasibility study, due by Q4 2026, on setting minimum recycled content requirements for steel and aluminium in vehicles
• Plans to introduce recycled content obligations for aluminium in construction products as part of the Circular Economy Act in Q4 2026
• An assessment of whether recyclability and recycled content requirements should be expanded to other product categories under EU sustainability regulations
• Prioritising product design and waste treatment facilities that separate copper components from steel and aluminium

To ensure that more scrap remains available within the EU, the Commission is considering potential trade measures. By Q3 2025, it will explore the introduction of a ‘reciprocity rule’ which could limit exports to countries that restrict scrap shipments to the EU. Additionally, the revised Waste Shipment Regulation will be used to monitor and regulate scrap exports more closely.

As part of the Circular Economy Act, the Commission will consider if additional measures such as export fees or duties are needed to increase the availability of scrap in the EU.

Industry pushback

Recycling industry representatives have voiced concerns over the proposed export restrictions. The European Recycling Industries’ Confederation (EuRIC) argues that the Commission’s framing of ‘scrap leakage’ is misleading.

According to EuRIC, 80 per cent of recycled steel already stays within the EU, with the remainder being surplus material that has no domestic buyers. The 20 per cent of exported scrap is not leakage—it is “excess material that would otherwise go to landfill”.

“The Commission’s Steel and Metals Action Plan is a chance to set the record straight and address the real causes behind the steel crisis. Any discussions on exports are a distraction. You cannot force recyclers to keep surplus recycled materials in Europe if there is no one to buy them,” said Julia Ettinger, Secretary General of EuRIC.

The real problem, says the confederation, is that Europe has failed to create enough demand for its own recycled materials. It warns that restricting exports before creating sufficient demand could mirror past failures in the plastics recycling sector, where limited market demand led to financial losses and facility closures.

“What will be the result of that?” Ettinger asked. “A collapse of the European recycling industry, more landfill, more value destruction, and fewer jobs.”