On 22 September 2026 Fastmarkets reported that the European Commission's 18 September draft list of non-OECD countries authorised to import EU non-hazardous waste is already being treated as a 2027 rerouting of ferrous scrap. Exporters told the publication that, if the draft is adopted without a material change, European steel scrap classified as waste would lose several of its largest seaborne outlets after 21 May 2027. The Directorate-General for Environment's consultation on that draft list remains open until 16 October, with the first adopted list due by the end of 2026.

The legal rule has not moved since 18 September. 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. The commercial change this week is that yards and traders have started to map which 2027 books still have a lawful EU origin.

What exporters told Fastmarkets

Sources speaking to Fastmarkets on 22 September said the draft had raised alarm in importer markets because European steel scrap would be locked out of India, Pakistan and Egypt if the text stands. One major exporter expected a realignment rather than a simple removal of tonnes from the international market. Turkey is an OECD member, so EU sellers can continue to ship there, and more European scrap would then be offered into Turkey and the EU domestic melt. India, Pakistan and Bangladesh would have to replace EU supply from the United Kingdom, the United States, Japan, Australia and other origins that remain outside the Waste Shipment Regulation. A second exporter said Egypt and Morocco would be the destinations most affected in European steel-scrap volume, and that loading today is not the issue because comments can still be filed.

Fastmarkets also recorded that applications from Ukraine, Moldova and North Macedonia were accepted for metal scrap on the draft, while the large Asian and North African buyers were not. That reading matches the Circular Metal Association statement carried by Recyclingportal on 21 September: the metal column of the list is limited to a few EU accession candidates.

The books that sit outside the draft

Eurostat figures cited by Fastmarkets put the EU as the world's largest ferrous scrap exporting bloc in the first half of 2026, at 13.76 million tonnes under the relevant HS heading, up 10.3 percent year on year. Turkey remains the largest single buyer and is not touched by the non-OECD list. The next books are the ones that would lose an EU waste origin.

Egypt took 2.12 million tonnes of steel scrap from the EU in January–June 2026, up 59.7 percent year on year. Morocco took 1.08 million tonnes, up 44.9 percent. Pakistan was the largest South Asian buyer of European steel scrap in that half-year, at 952,110 tonnes, up 18.5 percent. India purchased 832,375 tonnes, down 26.2 percent. Those four destinations are the same markets named in Recycling Europe's 18 September reaction.

Kallanish, writing on 23 September from the Commission's staff working document, recorded the reasons given for keeping ferrous waste off those authorisations. India had not shown comprehensive air-emission and wastewater controls for treatment. Pakistan had not shown key metallurgical-treatment requirements, including a stable shredder feed and controls on diffuse emissions. Egypt had not supplied data on the share of metal waste that is recycled. Bangladesh was judged incomplete on residual-waste management and pollution controls. Saudi Arabia was also left off ferrous for gaps on mixing bans, laboratory testing and shredder-feed rules.

GMK Center, reporting Argus, said the Materials Recycling Association of India intends to file comments before the 16 October close and has discussed a separate customs treatment for processed secondary raw materials that have reached end-of-waste. That is an industry proposal, not a Commission decision.

Turkey stays open; the UK is outside the rule

Turkey's OECD status is the main commercial fact for an EU export yard. Fastmarkets' exporter sources expected more European HMS and shredded to be offered into Iskenderun and Aliaga if Egypt, Morocco, Pakistan and India close. That sits on top of the September German rollover, where recyclers already named a recovery of the Turkish export book as the driver for any October markup. Who buys European scrap has been a Turkish-first map for several years; the draft would make that concentration tighter.

The United Kingdom is not bound by the EU Waste Shipment Regulation. Fastmarkets' sources did not expect London to copy the EU list in the near term. UK customs data cited in the same report put British steel-scrap exports at 4.92 million tonnes in January–July 2026, up 7.5 percent. Those cargoes already go to Egypt, Morocco, Pakistan and India as well as Turkey. If EU-origin waste is later barred from those non-OECD melts, UK container and bulk exporters become a substitute origin. That is additional demand for UK yards and a lost bid for EU yards that today pack the same 80/20 or shredded mix for Karachi, Alexandria or Nhava Sheva.

South Asian importers that lose EU supply would also compete for Japanese, Australian and other East Asian cargoes that today go to Bangladesh. Fastmarkets recorded that Bangladesh took only 40,154 tonnes from the EU in the first half of 2026, while customs data in that report showed much larger receipts from Japan, Australia and Singapore. The risk those buyers described is a shortage of alternative origin, not only a shortage of EU tonnes.

German recyclers and end-of-waste

The Circular Metal Association, quoted by Fastmarkets on 22 September and earlier by Recyclingportal, said export restrictions on recycled metals are the wrong instrument and that using waste law does not improve them. CMA said European recyclers already deliver about 80 percent of the metals they produce to EU manufacturers; the remaining export is the outlet for volumes the European melt does not take. Closing that outlet, the association said, does not create additional European demand and leaves collection and preparation businesses with fewer sales and growing surplus. CMA will comment on the consultation and has asked the Council and the European Parliament to object to the act. BVSE, also quoted by Fastmarkets, called for open markets and real demand rather than new export barriers.

Fastmarkets noted that high-purity scrap which has obtained end-of-waste status from an EU-accredited auditor is not a waste shipment. How many EU recyclers hold that status, and for what share of output, is not published. Council Regulation (EU) No 333/2011 and Commission Regulation (EU) No 715/2013 already set Union criteria for iron, steel, aluminium and copper. A mixed demolition pile does not become a product by being labelled as one. Until the adopted list and any later guidance exist, a yard should record whether a lot is waste or claimed as end-of-waste. An end-of-waste statement should not be treated as a guaranteed route into a country that is off the metal column. The OECD and non-OECD split still decides the shipment file.

What to record before 16 October

Shipments that are lawful today remain lawful until May 2027. The commercial work is the 2027 book. Split counterparts into OECD destinations, including Turkey; non-OECD countries that the draft would authorise for metal; and destinations that the draft would close. Name the recovery plant. Keep that file with the lot.

Trade associations and companies that ship metal waste can still file comments on the 18 September consultation before 16 October 2026. Comments that name the country and the metal stream are the ones the assessment can use. The broader export-restriction debate is not a substitute for that 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.