On 25 September 2026 Recycling International recorded Germany's Circular Metal Association (CMA) and the secondary-raw-materials association BVSE among the trade groups objecting to the European Commission's 18 September draft list of non-OECD countries authorised to receive EU non-hazardous waste. The same report named Recycling Europe, the Bureau of International Recycling and India's Material Recycling Association of India. The 18 September draft already set the legal rule. CMA's statement, carried by Recyclingportal on 21 September and by Fastmarkets on 22 September, is the German recycler reading of that metal column.
Recyclingportal published the CMA text on 21 September. Fastmarkets carried the association in English the next day, as republished by EUROMETAL on 23 September. SteelOrbis reported BVSE on 24 September. The Commission consultation remains open until 16 October 2026.
What CMA says the draft does to metal waste
CMA said the draft delegated act would leave only a few EU candidate countries authorised to import recycled steel and non-ferrous metals from the Union. All other non-OECD destinations, including the main Asian books, would be closed from 21 May 2027. The association called that result an export ban for the most important markets.
Regulation (EU) 2024/1157 generally stops non-hazardous waste for recovery to non-OECD countries from 21 May 2027 unless the destination has shown environmentally sound treatment and is authorised for that stream. CMA's complaint is how metal is assessed. Recyclingportal recorded the Commission's stated reason as a higher starting risk than for other wastes: recycled metals may contain toxic heavy metals, they are not degradable, and shredding, melting and refining can create environmental harm. CMA said that treats one material group as prejudged, and that a country-by-country check of treatment standards is what the regulation already provides.
SteelOrbis, writing on 24 September, named Moldova, Montenegro, North Macedonia, Serbia and Ukraine as the five non-OECD destinations proposed for certain metal waste. BIR's 24 September count was 24 metal applicants and five proposed authorisations. Recycling International named India, Malaysia and Thailand among the Asian destinations excluded from ferrous and non-ferrous metal scrap for recovery.
CMA also tied the draft to the withdrawn aluminium export duty. Fastmarkets recorded the association saying export restrictions on recycled metals are the wrong path, including when they are introduced through waste law. The EGA briefing already covered the duty withdrawal. CMA's point is that the waste list is now the instrument.
The association put European recycler output mostly into Union plants, with about 20 percent exported. Recycling Europe used the same 20 percent figure. CMA said those export tonnes are the outlet for metal European demand does not take. Closing international markets, it argued, does not create extra demand or competitiveness inside the Union. If European metal producers do not buy the available quantities, outlets disappear, values come under pressure and surplus grows.
What BVSE added on surplus and investment
BVSE told SteelOrbis that limiting international outlets for ferrous scrap could leave volumes in Europe that steelmakers would not automatically lift. Restricted access to overseas markets does not by itself create additional European demand. Without sales opportunities, the association warned of lower values for recycled raw materials, weaker investment and, over time, weaker European recycling capacity. If that path holds, more available supply would put downward pressure on ferrous values and on collection and processing revenue.
The association also said that closing markets by political decision makes investment in modern processing and sorting plant a risk. It asked for better investment conditions and said competitiveness problems in European industry should be treated at source rather than by restricting recycler outlets. Fastmarkets recorded BVSE calling for open markets and real demand instead of new export barriers.
German yards are already in a September rollover, with October still tied to the Turkish export bid. The CMA and BVSE statements are about the 2027 book, not the current monthly contract.
Who it affects among yards, traders, mills and processors
German and other EU export yards that pack HMS, shredded or non-ferrous metal waste for India, Pakistan, Egypt, Morocco, Bangladesh, Malaysia, Thailand or the other unauthorised names need a 2027 counterpart list that does not assume those waste destinations stay open. Who buys European scrap remains a Turkish-first map. Turkey is an OECD member and is not decided by this list. Fastmarkets has already mapped the likely reroute toward Turkey and UK exporters.
Non-ferrous processors that sell aluminium scrap or copper-bearing lots into Malaysia, Thailand or India sit inside CMA's metal argument, not only ferrous exporters. A paper or textile line on the draft does not keep a metal cargo lawful. MRAI has already set out the Indian import book that would close.
European electric-arc mills and remelters are the intended domestic offtake if those non-OECD books close. CMA 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 book 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. 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.
What to file before 16 October
CMA said it will take part in the Commission consultation, which closes on 16 October 2026, and will press for a revision of the draft. It also asked the Council and the European Parliament to object once the delegated act is adopted. BIR has already asked members for destination, waste-code and disruption evidence by 9 October. Companies that are not association members can still file on the Commission consultation. Comments that name the country and the metal stream are the ones the assessment can use.
First adoption is still put at 21 November 2026 by BIR and SteelOrbis, after which the act goes to the European Parliament and the Council. Those institutions may object within two months, with a possible further two-month extension. The list is due to be updated at least every two years. 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 status check.
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.