On 24 September 2026 the Bureau of International Recycling told members that the European Commission's 18 September draft list of non-OECD countries authorised to receive EU non-hazardous waste would change recycled-metal trade flows from 21 May 2027. SteelOrbis reported the same day that BIR counted 24 of the 32 assessed countries and territories as applicants for ferrous or non-ferrous metal waste, of which only five are proposed for certain metal streams. The remaining 19 metal applicants would not be authorised on the current draft. BIR asked members to send destination, waste-code and disruption evidence by 9 October so it can file a consolidated response before the Directorate-General for Environment consultation closes on 16 October.
The legal rule is unchanged from the 18 September draft. Regulation (EU) 2024/1157 generally stops non-hazardous waste for recovery to non-OECD countries from 21 May 2027 unless the destination is authorised for that stream. What changed this week is the industry filing calendar and a fuller count of the metal column than the first trade notes recorded.
What BIR and SteelOrbis recorded on the metal column
SteelOrbis, writing from the draft assessment on 24 September, named Moldova, Montenegro, North Macedonia, Serbia and Ukraine as the five non-OECD destinations proposed for the metal waste covered by their applications. Authorisation is limited to the waste streams and codes listed for each country. Fastmarkets' 22 September reading, already summarised here, had recorded Ukraine, Moldova and North Macedonia; Serbia and Montenegro now sit on the same metal line.
The same SteelOrbis report said India was accepted in the draft for other waste streams in its application, but not for metal waste. Indonesia and Malaysia received the same metal finding. Metal waste would also stay unauthorised to Bangladesh, Bosnia and Herzegovina, Egypt, Georgia, Morocco, Oman, Pakistan, Saudi Arabia, Sri Lanka, Taiwan, Thailand, Tunisia and Vietnam. BIR's 24 September statement, as carried by Auto Recycling World, named India, Malaysia and Thailand among the Asian destinations excluded from ferrous and non-ferrous metal waste for recovery.
Recycling Europe had already objected to the Egypt, Morocco, Pakistan, Bangladesh and India ferrous books. BIR's count is the wider metal application book: 24 applicants, five proposed authorisations, 19 refusals.
Why BIR says closing those books does not fill EU furnaces
BIR said restricting exports would not by itself create the European demand or processing capacity needed to take the affected grades and volumes. The statement warned that the result could be lower recycled-material values, weaker collection incentives and less investment in the supply chain. Auto Recycling World recorded BIR's aluminium point from an earlier Commission consultation: Europe generates more recycled aluminium than its domestic facilities can technically absorb, and supply, demand and processing capability do not match every grade.
The German secondary-raw-materials association BVSE, also on 24 September via SteelOrbis, made the same commercial argument for ferrous scrap. The association said limited international outlets would leave tonnes in Europe that steelmakers would not automatically lift, with a risk of lower values for collection and processing. The Commission's consultation remains open until 16 October 2026.
SteelOrbis also recorded a Commission remark attached to the draft: the institution may later consider separate measures on exports of waste or of materials that have ceased to be waste, to address global imbalances and secure secondary-material supply. An end-of-waste statement keeps a lot outside the waste-shipment file. That route should still be treated as subject to a later instrument.
Who it affects among yards, traders, mills and processors
Export yards and traders that pack HMS, shredded or non-ferrous metal waste for India, Pakistan, Egypt, Morocco, Bangladesh, Indonesia, Malaysia, Thailand, Vietnam, Taiwan or the other unauthorised names need a 2027 book that does not assume those waste destinations stay open. OECD counterparts, including Turkey, sit outside this list. Who buys European scrap remains a Turkish-first map; the draft would tighten that concentration if the metal column is adopted as written.
Non-ferrous processors that sell aluminium scrap or copper-bearing lots into Malaysia, Thailand or India are inside BIR's statement, not only ferrous exporters. A paper, textile or glass line on the draft does not keep a metal cargo lawful. Check the metal codes on the lot, not whether the country appears somewhere else on the list.
European electric-arc mills and remelters are the intended domestic offtake if those non-OECD books close. BIR and BVSE both say that offtake is not automatic. Processors that already make a specification a Union or Turkish melt will charge have a clearer counterpart list than yards that only pack export mixes for the names now off the metal column.
Intra-EU sales and OECD shipments continue under existing procedures. CBAM still prices carbon on steel and aluminium entering the Union; it does not replace the waste-export list.
What to file before 9 October and 16 October
BIR asked members to check whether their main destination markets and the relevant waste codes are covered, and to supply evidence of disruption to recycling supply chains by 9 October. It also intends to speak with diplomatic missions of countries that applied for non-hazardous EU waste but were not authorised for metal. Companies that are not BIR members can still file on the Commission consultation, which closes on 16 October 2026. Comments that name the country and the metal stream are the ones the assessment can use.
SteelOrbis and BIR both put first adoption of the list at 21 November 2026, after which the delegated act goes to the European Parliament and the Council. Those institutions may object within two months, with a possible further two-month extension. The Commission's 18 September Environment note had said the first list would be established by the end of 2026. The list is due to be updated at least every two years, and later applications can be considered; there is no guarantee they will be decided before 21 May 2027.
Shipments that are lawful today remain lawful until the 2027 dates apply. For the 2027 book, split counterparts into OECD destinations, non-OECD countries the draft would authorise for metal, and destinations the draft would close. Name the recovery plant. Record whether the lot is waste or claimed as end-of-waste. The broader export-restriction debate does not replace a stream-specific filing.
Name the grade the buyer can melt — HMS 1&2 80/20, shredded, or the non-ferrous code the melt already uses — the tonnes, packing, city or load port, and whether the material is waste or claimed as end-of-waste. If the intended recovery is outside the OECD, name the country. Verified companies can place the parcel on live lots or post a wanted enquiry. Request access if you need a member account.