Recent political interventions, including the parliamentary question on Europe’s dependence on third countries for paper recycling and production, reflect a broader narrative that portrays exports of recovered paper as a threat to European industrial sovereignty. This concern is particularly striking in the case of paper, long regarded as a European circular economy success story.

Structural surplus requires access to global markets

As highlighted in Recycling Europe’s Manifesto for Paper Recycling, Europe’s recycling system consistently generates more recovered fibre than its domestic paper manufacturing capacity can absorb, creating a structural surplus confirmed by industry data, including preliminary Cepi analysis.[1] Exports are therefore not a weakness but a stabilising mechanism that keeps surplus material in productive use.

Without access to global outlets, recyclers would face price collapses, stockpiling risks, and reduced incentives for collection. Because recycling markets are demand-driven, restricting trade does not create new domestic capacity; it risks distortions, discourages investment, and weakens the competitiveness of European recyclers. Maintaining access to international markets where EU demand is insufficient is therefore essential for both circularity and industrial competitiveness, in line with priorities identified for the forthcoming Circular Economy Act.  

Exports are already tightly regulated under EU law

Exports of recovered paper operate already under a robust and increasingly stringent regulatory framework. The revised Waste Shipment Regulation (WSR) has significantly strengthened monitoring, traceability, and compliance requirements, particularly for exports to third countries. European recyclers already face strict environmental standards and administrative controls.

As these new rules are only beginning to be implemented, their practical impact on trade flows and market conditions remains uncertain. Introducing additional export restrictions at this stage would duplicate existing safeguards, increase administrative burdens, and create further uncertainty across the value chain without delivering clear environmental benefits. Policymaking should first assess the effects of the WSR before considering any further measures.

Internal market barriers – not exports – limit Europe’s circularity

Last but not least, if the objective is to retain more recycled material within Europe, the priority should be strengthening the EU’s internal market for waste and recycled materials rather than restricting trade.

Today, paper recyclers face persistent fragmentation across Member States. The absence of harmonised EU-wide end-of-waste (EoW) criteria for paper, combined with divergent national interpretations of waste rules, creates legal uncertainty, shipment delays, and additional costs. This patchwork of rules hampers the efficient circulation of recovered paper both within and beyond the EU and weakens the competitiveness of European recyclers.

Developing and implementing EU-wide EoW criteria for paper based on existing national criteria or the EN 643 standard would significantly improve legal certainty, facilitate cross-border shipments, and strengthen the Single Market for recycled materials. Addressing these structural barriers would be far more effective for enhancing Europe’s circular economy and industrial resilience than limiting exports.

A coherent, market-based approach is needed

Europe’s paper recycling sector is a cornerstone of the circular economy and industrial competitiveness. Export restrictions would risk weakening collection systems and investment without addressing the underlying challenges. The priority should instead be to remove internal barriers, assess the impact of the Waste Shipment Regulation, and maintain access to global markets where EU demand is insufficient.

[1] Cepi, Preliminary Statistics 2025 [https://www.cepi.org/cepi-preliminary-statistics-2025/]; Cepi, Key Statistics 2024 European pulp & paper industry [https://www.cepi.org/wp-content/uploads/2025/07/Cepi-2024-Key-Statistics.pdf]