On 26 October 2026 the Bureau of International Recycling’s Non-Ferrous Metals Division met in Malaga. BIR published the session the next day. A study commissioned by Germany’s Circular Metal Association and written at the Fraunhofer Institute for Ceramic Technologies and Systems (IKTS) was presented there under the title Trade Barriers for Copper Scrap and their Effects. CMA and VDM released the same findings on 27 October. SteelOrbis, writing on the 26 October welcome briefing, put attendance at more than 1,400 delegates from 58 countries and recorded that the Commission’s final list of authorised non-OECD destinations is still expected on 21 November.
The study’s copper-flow numbers are the part that changes a yard book. Brass, meaning copper-zinc alloys, accounted for 41.7 percent of the EU’s recycled-copper exports in 2025 and only 14.1 percent of the corresponding imports. About 80 percent of that exported alloy went to China and India, where remelt and brass-using industry still take the grade. Those two destinations sit outside the OECD. Under the 18 September draft of the Waste Shipment Regulation list, non-OECD metal waste after 21 May 2027 would be authorised only for a handful of EU candidate countries. See the draft metal-waste list and CMA’s earlier reading of the metal column.
Fraunhofer IKTS treated the draft list and the duty to audit recovery plants outside the Union as raising cost for the foreign buyer. For some plants the extra paperwork would make an EU purchase uneconomic even if they could pass the check. The researchers described the combined effect as comparable to a partial export ban. The consultation on the draft closed on 16 October. The 21 November list, if adopted in that shape, is the instrument that would close those Asian waste books. OECD and non-OECD shipment rules still decide the file until May 2027.
What the study says happens if the alloy book closes
The authors do not treat recycled copper as one product. Pre-consumer copper that can go straight to the melt has a low processing cost and would still move at a weaker domestic bid. Complex streams from old equipment have to be collected, sorted and often refined. If overseas bids disappear, the study expects European scrap values to loosen from the refined-copper exchange, because fewer foreign buyers would be competing for the same tonnes. Existing European processing capacity is already described as running close to its limit, so the extra metal would not automatically find a home melt.
Collection of the harder grades is the first activity that stops paying. A yellow-brass or mixed-alloy pile that today clears to China or India would then sit. BIR recorded a Girona recycler, ACIN, telling the same session that clean copper is already easy to place inside the Union, that lower-quality grades are not, and that the firm has bought equipment to separate zinc from copper so that the copper fraction can be sold in Europe. The same speaker said there is already little EU offtake for brass and that a closed export book would leave brass stacked in the yard. BIR also recorded that much of the recent rise in European copper-recycling capacity has been built for wire-rod feed, not for a brass melt.
La Farga, a Spanish maker of semi-finished copper, told the session that in 2025 some 60 percent of its 200,000 tonnes of copper output came from recycled metal, and that this year more than 70 percent of that feed was collected inside Europe. That offtake is a rod and semis programme. The Indian and Chinese brass mills that took most of the exported alloy last year remain a different melt. Keep copper scrap and brass scrap on separate tickets.
CMA’s 27 October note adds that the EU has exported more recycled copper than it has imported since 2023. The researchers read that surplus as evidence that some grades are not being processed competitively inside Europe under present energy, capacity and regulatory costs, rather than as a loss of a strategic stockpile. The 21 November list would change the lawful destinations for waste alloy; it would not add a European brass mill. Who buys European scrap is still a destination map; for alloy that map is Asia unless the metal leaves as end-of-waste.
Who it affects among yards, traders, mills and processors
EU export yards that pack Honey, red brass, radiators or a refinery mix for India or China need a 2027 counterpart that does not assume those waste destinations stay open. India’s MRAI filing already set out the import book that the draft would close. A Honey parcel offered as waste after 21 May 2027 to a non-OECD plant that is not on the metal column would have no lawful recovery route under the draft. An end-of-waste claim, if the lot actually meets it, takes the shipment off that waste file. Do not write the claim unless the specification and the documents support it.
Traders who blend yellow metal into a copper stem to “help the copper” will be regraded. Brass is a copper-zinc alloy. Last week’s German wholesale cut already moved copper and brass on different increments. A mixed yellow-metal bag is priced as the weakest reading.
European copper remelters and rod mills that want Berry, Birch or clean solids are not the natural home for a zinc-bearing melt. A processor that can split zinc from copper, or that already sells a named Honey or Drink specification into a Union or Turkish melt, has a clearer book than a yard that only packs an Asian alloy mix. Turkey is an OECD member and is not decided by this list. Confirm the melt before you load.
SteelOrbis recorded BIR saying it is talking to delegates from the excluded countries and working with European national associations on what legal action could be envisaged. That is association work on the delegated act and does not authorise a shipment. The list is due to be updated at least every two years; later applications can be filed, with no promise they will be decided before 21 May 2027.
How to name the lot
Name the preparation the melt already uses. For unalloyed copper write Berry, Birch, or clean solids. For yellow brass write Honey; for a refinery mix write Drink or describe the copper content you have measured. See ISRI scrap codes. Add tonnes, packing, city or load port, and whether the sale is ex-works, delivered or FOB. State if the material is waste or claimed as end-of-waste. If the intended recovery is outside the OECD, name the country and the plant.
Do not write “brass/copper mix”, a 2027 policy line, or last week’s wholesale change on the offer. How to sell scrap metal still starts with a named grade and a named load point.
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