The European Union is trying to keep more steel and aluminium scrap inside the single market. The stated reasons are industrial and environmental: electric-arc steel and recycled aluminium need feedstock for decarbonisation, and Brussels does not want to ship untreated waste to countries that cannot show environmentally sound recovery. How it intends to do that has shifted in the last two weeks. A planned export duty on aluminium scrap was withdrawn in September 2026. The Commission is now pointing to waste-shipment law, including a delegated act still to be published, rather than to a customs tariff.

The volume at stake is large. The Steel and Metals Action Plan of 19 March 2025 (COM(2025) 125) recorded ferrous scrap exports peaking at 19.43 million tonnes in 2021, about a fifth of EU generation. In 2025 the Union was still the world’s largest exporter of recycled steel, as set out in who buys European scrap. Aluminium scrap exports reached a record of about 1.26 million tonnes in 2025, according to figures cited in Commission draft material reported by Reuters, some 51 percent above 2019.

Why the Commission wants to limit exports

EU steel and aluminium producers argue that overseas mills and remelters pay more for European scrap than the domestic melt can, in part because of energy costs, subsidies and trade distortions abroad. The March 2025 Action Plan said scrap use in the Union was falling for two reasons: weak demand from EU industry, especially steel, and higher prices paid in third countries. Eurofer adds that a share of exported ferrous scrap is untreated and still contains copper, aluminium and nickel that European works would rather recover at home.

Climate policy points the same way. Recycled steel in an electric-arc furnace and remelted aluminium use less energy than primary metal. The Carbon Border Adjustment Mechanism, applying to steel in 2026, is designed to price carbon on metal entering the EU. It does not tax scrap leaving the EU. If European furnaces are to run on scrap, the Commission’s industrial logic is that the scrap should be available here, not only in Iskenderun or Gujarat.

The Circular Economy Action Plan and the Green Deal also frame scrap as a secondary raw material, not as a residual to be sold wherever the bid is highest. Recyclers, for their part, warn that if export is closed and EU mills do not lift the metal, collection and processing lose their margin. The Action Plan itself notes that acting on supply only works if there is still a business case for yards.

The Waste Shipment Regulation already adopted

The legal instrument already on the books is Regulation (EU) 2024/1157, the revised Waste Shipment Regulation. It entered into force on 20 May 2024. Most internal provisions apply from 21 May 2026. The new export rules for recovery apply from 21 May 2027. Until then, Regulation (EC) No 1013/2006 still governs many shipments.

From 21 May 2027, export of non-hazardous (“green-listed”) waste for recovery to countries outside the OECD Decision is generally prohibited. A non-OECD country may receive specified streams only if it is on a Commission list, after showing that it can manage the waste in an environmentally sound manner, including labour-related criteria in the regulation. The first list is due by 21 November 2026. Twenty-four countries had applied by the original February 2025 deadline; later reporting has referred to a larger number of applications still under assessment.

Exports for disposal, and hazardous waste for recovery, to non-OECD countries remain banned, as they largely already were. Shipments of e-waste to non-OECD countries are prohibited.

OECD destinations and what “waste” means

The OECD split is the practical line for the trade. Turkey, the United Kingdom, the United States, South Korea and other OECD members are not in the non-OECD ban. Exports to OECD countries for recovery continue under a regime closer to intra-EU shipments. The Commission is to monitor volumes; if it finds that exports are rising and the destination is not managing the waste soundly, it can open a dialogue and, ultimately, suspend those flows.

That is why a ferrous cargo of HMS to Turkey is not, under the 2027 rules as written, in the same legal box as the same grade to a non-OECD mill in India, Pakistan or Bangladesh. India has asked the EU for continued access. A draft of secondary legislation seen by Reuters in September 2026 indicated that India, Thailand and Malaysia had not met the environmental tests for an exemption on metal waste. That draft is not the adopted list.

A second distinction is end-of-waste. Council Regulation (EU) No 333/2011 sets criteria under which iron, steel and aluminium scrap can cease to be waste. Material that has legally become a product is not shipped as waste. Whether a lot is still waste or has met those criteria is a compliance question for the holder, not a marketing line on an offer.

The aluminium duty withdrawn in September 2026

On 4 September 2026 the cabinet of Executive Vice-President Stéphane Séjourné said a trade instrument on aluminium scrap would be withdrawn. Internal discussion had left a draft covering only about half of aluminium scrap exports. Reuters later reported that a prepared text would have set a 15 percent export duty for three years; European Aluminium had asked for 30 percent. An annex in that draft exempted a long list of countries, including India, the EU’s largest aluminium-scrap buyer (about a third of EU aluminium scrap exports). Sources told Reuters the duty was dropped in part because of the forthcoming EU–India trade agreement, expected to be signed in December 2026.

The Commission’s public line was that the same objective could be pursued under the Waste Shipment Regulation. Séjourné’s cabinet said work was under way on a delegated act that would ban exports of waste, including aluminium scrap, to non-OECD countries, with an exception for some EU candidate countries. A public consultation is to precede adoption, targeted by the end of 2026. As of mid-September 2026 the act has not been published. Grades (including CN 7602), end-of-waste treatment, and the relationship with the November 2026 authorised-country list are therefore not yet settled.

The Action Plan had also left open export fees or duties more generally, and a Circular Economy Act in the fourth quarter of 2026, to make a single market for waste and secondary materials inside the Union. Those files have not replaced the waste-shipment calendar.

What a European seller should watch

Until May 2027, existing shipment rules apply. From that date, the destination’s OECD status and, for non-OECD, presence on the authorised list will decide whether a waste-classified lot can leave. A delegated act adopted in late 2026 could tighten that further. Turkey and other OECD melts remain the path of least legal friction for ferrous export under the regulation as it stands. Aluminium and other non-ferrous streams to India and China are the flows most exposed if the list and the delegated act bite.

None of this changes how a lot is specified. Name the grade, tonnes, load port or city, and the company. State whether the material is still waste or claimed as end-of-waste. Prices will move with the bid that can still take the cargo. Verified companies can list on live lots or wanted; request access if you have metal to place or a melt to cover.

The EU’s aim is to retain scrap for its own steel and aluminium industry and to stop non-OECD recovery that it does not trust. The method now in force is waste-shipment law from May 2027, not a published export tax. The September 2026 aluminium duty is off the table; the delegated act and the November 2026 country list are the next documents that will tell yards where a parcel can still go.