BIR and EuRIC Joint Statement on Steel and Metals Action Plan: Strengthening Circularity Amid Concerns on Export Restrictions
On March 19, 2025, the European Commission unveiled its Steel and Metals Action Plan, aiming to foster the competitiveness and sustainability of Europe’s metals sector. In response, BIR (Bureau of International Recycling) and EuRIC (European Recycling Industries' Confederation) have issued a joint statement welcoming much of the plan, particularly its recognition of circularity in decarbonizing the metals industry.
The statement applauds the Commission’s recognition that recycling can drastically reduce energy consumption, up to 95% for primary aluminium production and 80% for steel production. These figures underscore the environmental benefits of the recycling industry and the critical role it plays in climate action.
The two organizations also support the proposed targets for recycled content in key sectors such as automotive and construction, as well as the focus on improving recyclability and design for recycling. However, the statement raises serious concerns regarding potential trade-related measures, particularly the export restrictions and fees for recycled metals that could undermine global recycling markets.
Supporting Circularity and Tackling Domestic Challenges
Circularity in the Metals Industry
The BIR and EuRIC both strongly advocate for the vital role of circularity in driving the decarbonization of the metals industry. The action plan’s recognition that recycled metals save significant energy during production aligns with the global recycling industry’s goal to reduce emissions and resource consumption. By prioritizing design for recycling, particularly for copper and steel components, the Commission is promoting resource efficiency.
Additionally, the groups welcomed the proposal to stimulate demand for recycled metals through recycled content targets in key markets. This will help create more robust markets for recycled raw materials, enhancing the sustainability of the European metal sector.
Concerns Over Export Restrictions
However, BIR and EuRIC have serious reservations about the trade-related proposals in the plan. The Commission has suggested reciprocating export restrictions and export duties on recycled metals, which could disrupt global recycling markets.
Currently, 80% of the recycled materials processed in Europe are used domestically, with the remainder being exported due to a lack of sufficient domestic demand. The proposal to impose trade barriers risks harming the global recycling ecosystem, particularly for European metal recyclers who rely on the export market to maintain the economic viability of their operations.
The statement from BIR and EuRIC highlights that the current export of recycled metals is not due to “scrap leakage” or issues related to the availability of recycled materials in the EU. Instead, it stems from a shortage of domestic demand within Europe. The global recycling markets function optimally with open trade, and any restrictions could hinder the circular economy, affecting both local recyclers and international markets.
Economic Implications of Restrictions
If export barriers are introduced, it could lead to:
• Price pressures for EU recyclers, threatening the financial stability of recycling operations.
• Reduced collection rates for end-of-life products containing metals, due to the lack of domestic demand.
• Distorted global recycling markets and supply chains, which would undermine global efforts to promote circular material use.
The joint statement urges the Commission to disregard these trade restriction proposals, as they would create unnecessary hurdles for EU metal recyclers and undermine the global market for recycled materials.
Proposed Measures to Strengthen Recycling and Support Trade
In response to these concerns, BIR and EuRIC urge the European Commission to focus on several key actions:
• Disregard export restrictions: Ensuring that recycled metals can continue to be traded openly and globally is essential for a well-functioning recycling market.
• Introduce mandatory recycled content targets: These targets will support the creation of domestic demand for recycled materials in Europe, particularly in lead markets like automotive and construction.
• Harmonize waste classification: Accelerating efforts to create a harmonized classification system for recycled metals and clear EU-wide end-of-waste criteria will streamline the recycling process.
• Support domestic recycling infrastructure: Investment should be directed toward improving EU recycling facilities to process more recycled metals locally, ensuring recyclers have access to metallic waste.
• Build relationships with trade partners: Collaborating with global trade partners for recycled metals is vital to foster predictable markets and maximize circularity.
Finally, the statement emphasizes the importance of engaging stakeholders in the recycling industry. BIR and EuRIC urge the European Commission to ensure that the recycling industry is fully represented in discussions on the implementation of the action plan, especially regarding issues related to circularity and trade.
Key Takeaways:
• The European Commission’s Steel and Metals Action Plan highlights the importance of recycling and circularity in decarbonizing the metals industry.
• BIR and EuRIC support the Commission’s proposals for recycled content targets and improving recyclability but oppose potential export restrictions and fees on recycled metals.
• 80% of recycled materials processed in Europe are used domestically, while the remaining 20% is exported due to insufficient domestic demand.
• Export barriers could harm the global recycling market, create price pressures for EU recyclers, and distort global supply chains.
• The statement calls for mandatory recycled content targets, harmonized waste classifications, and support for domestic recycling infrastructure to strengthen the EU recycling industry.
• BIR and EuRIC urge the Commission to avoid trade restrictions and focus on fostering positive relationships with trade partners to maximize circularity.
