The European recycling industry is a €100 billion success story, with recycling facilities, from small collection and sorting sites to large-scale recycling plants, creating over 310 000 green local, non-outsourceable jobs across all Member States. For decades, European metal recyclers have continuously invested in industrialising their recycling processes to increase both the quantity and quality of waste reprocessed into recycled materials.

Using as a pretext the upcoming Steel and Metals Action Plan, announced in the EU Clean Industrial Deal COM(2025), the steel and aluminium industries are pushing for additional export restrictions on steel and aluminium “scrap” . These calls completely disregard the fact that the new EU Waste Shipment Regulation (EU) 2024/1157 (WSR), published less than a year ago and currently undergoing implementation, already limits recycled steel & metal scrap exports to both OECD and, even more significantly, non-OECD countries. The WSR already imposes additional bureaucratic burdens on EU recyclers, reinforces control of environmental standards and already places significant limitations to access international markets.

While there is no doubt that Europe’s energy-intensive industries are facing an existential threat and should receive support, it is crucial to recognise that this crisis stems from record-high energy prices, which are affecting the recycling industry as well. However, it is crucial to underline that the economic difficulties faced by European steel and aluminium manufacturers are not caused by a shortage of recycled materials, which simply does not exist. The numbers speak for themselves, and they do not lie:

The EU’s net consumption (=demand) of recycled steel scrap has dropped over the last decade, from 87.5 million tonnes (MT) in 2014 to 75.2 MT in 2023. During the same period, exports increased from 12.3 MT to 18.9 MT, while imports fell from 5.1 MT to 3.9 MT.

Why? Because Europe’s own industry isn’t using enough recycled materials.

There has been no shortage of recycled steel scrap over the past decade. On the contrary, exports have compensated for structurally low EU demand, which, is not likely to improve, in the medium run.

If further export restrictions, beyond those already enacted in the WSR, are implemented, collection and recycling rates will drop, jobs will disappear, and facilities will close. If access to international markets is restricted, as the steel and aluminium industries want to artificially lower the price of materials they use as feedstock, the EU will kill its recycling industry. The socio-economic and environmental consequences of such a decision would be devastating. We have already seen what happens when bad policies strangle recycling. This is precisely what is happening in plastic recycling, where a combination of low oil prices and anticipated export bans, without any restrictions on cheap plastic imports, have triggered multiple bankruptcies for EU plastics recyclers.  Argentina recently lifted a 16-year long ban on the export of recycled metals, which had crippled the domestic recycling industry, decreasing the collection and processing rates of ferrous waste and leaving many unemployed. Europe must learn from these mistakes.

In the short to medium term, such restrictions would be a lose-lose scenario for the entire European metal value chain – from recycling to production – ultimately making the EU even more dependent on imports of primary ore, semi-finished and finished products. Instead of strengthening Europe’s recycling industry, a key pillar of a circular and low-carbon economy, these measures would undermine it for years to come.

By all means, such a scenario must be prevented.

Europe’s deindustrialisation problem cannot be addressed with protectionism and with harming recyclers. Therefore, EuRIC calls for evidence-based measures to tackle the root causes of Europe’s deindustrialisation, rather than worsening its consequences:

• Adhere to the brand new EU WSR framework and refrain from enacting any additional  export restrictions on recycled steel and metal scrap.
• Boost demand for European recycled materials by introducing targeted recycled content obligations, reducing VAT, creating circular lead markets and promoting green public procurement to reward circularity.
• Address competitiveness issues caused by high energy prices, as identified in the Clean Industrial Deal, which affect all industries including the EU recycling sector.

It would be both counterproductive and disastrous if one of the first consequences of implementing the Clean Industrial Deal in the steel and metals sector were to destroy industrial local green jobs and value creation, the very foundation of Europe’s circular economy.