The European Commission has kicked off customs surveillance on recycled steel, aluminium, and copper. EuRIC supports smarter oversight, but warns that rushed trade measures could backfire, hurting recyclers without fixing raw material access. Any next steps must be proportionate, fact-based, and circular economy-proof.

 “The assessment must consider both the quantities and qualities of recycled metals being exported and imported. However, to have a full picture the EU will also need to monitor the imports of primary materials competing with recycled materials, such as iron sponge or Direct Reduced Iron (DRI), which have exponentially surged since the beginning of the year, as well as the EU’s forecasted production capacity” Olivier François President of EuRIC stated. “This is essential to avoid introducing measures that could unintentionally harm the competitiveness of the European recycling industry without improving circular materials’ availability for EU manufacturers.”

EuRIC has on numerus occasions reiterated that the exports of recycled metals have been keeping recycling businesses alive by offsetting a structurally low and declining EU demand. While the unfair competition faced by European aluminium and steel producers, needs to be addressed, EuRIC highlights that this should not be done at the expense of European recyclers. Furthermore, while 12 CN codes have been listed to assess steel, only 3 each have been used so far to track the imports and exports of recycled aluminium and copper. Recyclers urges the Commission to take into account the differences in quality between exported and domestically demanded materials, as well as forecasted demand at European level as a fundamental pre-requisite to any decisions.

EuRIC would also raise concerns regarding the Commission’s recent statement that the EU is experiencing a decline in metal scrap availability for recycling due to “scrap leakage” to third countries. It is necessary to recall that EU metal recyclers are reprocessing metallic waste into recycled metals which replace or complement extracted raw materials utilized by steel, aluminium or copper mills. The high recycling rates achieved for metallic waste are a reflection of the investments made by European recyclers over the past decades to become the backbone of a more circular economy. Since 1975, over 9,3 billion € were invested across Europe by steel recyclers alone to fund 267 shredding plants. Hence, the allegations that recycling occurs within mills, risks discarding broader role of the recycling sector in the circular economy.

In light of the ongoing geopolitical tensions, Europe should strengthen its credibility as a reliable trade partner and avoid introducing measures that could hamper well established partnerships while not increasing the recycled metals use rate locally. The surveillance system will collect trade data throughout the coming months, with the Commission expected to assess by the end of Q3 2025 whether targeted trade measures are needed to safeguard the EU’s supply of recycled metals and prevent perceived scarcity.

As the monitoring process unfolds, EuRIC and its members will continue to engage with the Commission to ensure that any future measures are proportionate, informed, and supportive of Europe’s green and industrial ambitions.