On 28 October 2026 Aperam published a Luxembourg release supporting the European Commission’s proposed delegated regulation under the Waste Shipment Regulation, Regulation (EU) 2024/1157. Recycling Today carried the statement on 2 November and updated it on 3 November. Shanghai Metals Market summarised the same release the same day.

The Luxembourg stainless and recycling group said it welcomes stronger controls on exports of recyclable materials to non-OECD countries. It called scrap a strategic raw material for the European industrial chain. European stainless production, it said, uses about 80 percent recycled metallic inputs. Recycling Today recorded that Aperam Recycling, the former ELG business, handles more than one million tonnes a year across more than 40 locations.

The Commission’s first list of non-OECD countries authorised to receive specified EU waste after 21 May 2027 is still due on 21 November 2026. Exports to a non-OECD destination that is not listed for that stream will then be prohibited. The 18 September draft left India, Malaysia and Vietnam off the metal column; Shanghai Metals Market also named Thailand among destinations left off. That draft is not the adopted list. OECD outlets, including Turkey and the United Kingdom, are not decided by it. See the draft waste-import list, OECD and non-OECD shipments and why the EU wants to limit scrap exports.

Aperam asked decision-makers to adopt the act by 21 November 2026 without extending the consultation or delaying implementation. BIR had asked the Commission in October for at least four more weeks. The mill also asked that countries unable to show EU-equivalent environmental standards stay off the list, and that the Commission not grant transitional export quotas. It asked customs to prevent circumvention through End-of-Waste classifications or indirect exports via OECD countries. It asked the Union to treat stainless scrap as a strategic secondary raw material for nickel and chromium under circular-economy and Critical Raw Materials Act work. That CRMA file already has a separate Parliament mandate on permanent-magnet scrap.

The intra-EU green-list act adopted on 26 October is a different instrument. C(2026) 7390 would ease recovery movements between Member States. It does not authorise a waste cargo to a non-OECD plant after 21 May 2027.

Who it affects among yards, traders, mills and processors

European yards that still pack waste-classified stainless, including 304 and Sabot 18-8 solids, for India, Malaysia, Vietnam or Thailand now have a mill-side record that a large European remelter wants the 21 November list adopted on time and without a quota window. Indian recyclers told BIR’s International Trade Council in Malaga that those destinations remain off the metal column and that the draft clashes with the EU–India FTA talks. See the Malaga India briefing.

Traders looking at an End-of-Waste wrapper to keep a May 2027 non-OECD book should read the Aperam ask against the law already on this site. Union-wide End-of-Waste criteria exist for iron, steel and aluminium under 333/2011 and for copper under 715/2013. Stainless does not have the same Union metal criteria; national decisions or waste classification apply. Calling a mixed 18-8 pile a product does not move it outside the waste-shipment file. See end-of-waste scrap.

A booking that leaves the Union as waste to an OECD port and then continues to a non-OECD recovery plant is the second route Aperam asked customs to watch. Turkey and the United Kingdom remain lawful OECD recovery destinations in their own right. A paper hop through an OECD port is the risk the mill named.

European stainless remelters that buy locally already face a selective fourth-quarter melt. A tighter extra-EU door from May 2027 would leave more 18-8 solids inside the Union only if those remelters lift them. Aperam did not publish a buying programme with the statement.

Processors that prepare 316, 400-series or mixed turnings should keep those fractions on their own tickets. The statement is about export law, not about a new melt specification.

How to name the lot

Write the alloy the melt already uses: 304 or Sabot for 18-8 solids, 316 if the molybdenum is known, or the mill’s own 18-8 language. See stainless steel scrap and ISRI scrap codes. Say whether the lot is solids, clips or turnings, magnetic 400-series or mixed, the city or works, the quantity, and whether the sale is ex-works or delivered. State whether the material is offered as waste or under a national End-of-Waste decision, and name the destination country if the cargo is booked. Do not invent a nickel or molybdenum figure you have not measured. Do not offer a mixed bag as Sabot.

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