On 25 September 2026 Recycling International reported that the Material Recycling Association of India (MRAI) had written to India's Ministry of Commerce and Industry after the European Commission's 18 September draft left India off the metal-waste column of the non-OECD authorised list. KNN, citing a letter reviewed by Reuters, published the same filing on 24 September and dated it to Wednesday 23 September. MRAI said that if the draft stands, exports of ferrous and non-ferrous metal scrap from the EU to India could end from 21 May 2027. The ministry told KNN that it remains engaged with the EU on the matter.
The legal rule is the one already set out from the 18 September draft. What changed this week is the buyer-side filing: an Indian industry association treating the metal-waste finding as a bilateral trade and raw-material issue, not only a waste-environment assessment.
What MRAI asked the ministry to do
Recycling International said the eight-page letter asked for urgent intervention before the list is finalised in November. MRAI asked the ministry to take the file through India-EU bilateral trade mechanisms, including the proposed free-trade agreement, and to treat it as a question of India's trade and raw-material security. KNN recorded a further ask: zero-duty treatment for scrap imports under that proposed agreement.
MRAI called the proposal resource protectionism. Recycling International quoted the association as saying the restrictions are not only an environmental measure and are aimed at keeping metal scrap in Europe for domestic industry. The same report linked that claim to the Carbon Border Adjustment Mechanism, which MRAI treats as a further reason for European steel and aluminium producers to use scrap.
MRAI also objected to the Commission's extra scrutiny of metal waste. Recycling International recorded the association's point that paper, rubber, textile and other streams were proposed for authorisation to India, while ferrous and non-ferrous metal scrap was excluded, even though those other treatments also produce emissions, residues and wastewater. The Commission, in the 18 September draft as reported by SteelOrbis and by KNN, has said metal waste needs particular scrutiny because of persistent and toxic heavy metals.
MRAI said India has an extensive regulatory framework for metal recycling and processing plants. The letter, as Recycling International summarised it, argued that blocking recyclable metal from countries with established recycling capacity and industrial demand would leave scrap in the country of generation, cut its value and weaken collection.
The Indian import book the letter puts at risk
Recycling International recorded MRAI's last-year import totals: about 2.03 million tonnes of aluminium, 0.47 million tonnes of copper and copper alloy, 0.21 million tonnes of lead and 0.11 million tonnes of zinc. The EU share in that year, according to the same figures, was about 20 percent of India's aluminium scrap imports, 22 percent of copper and copper alloy, 20 percent of lead and 40 percent of zinc. KNN, using MRAI data for 2025/26, published the same percentage shares. Industry estimates cited by KNN put the EU at around a quarter of India's metal-scrap imports overall.
On ferrous, Recycling International said India imported about 8.45 million tonnes of ferrous and stainless steel scrap last year, of which about 0.79 million tonnes originated from the EU. That is a smaller EU share than on zinc or aluminium, but it is still a book European HMS and stainless exporters pack. Who buys European scrap already records India as a secondary seaborne outlet behind Turkey.
MRAI represents more than 2,000 members and said its network supports employment for more than 2.5 million people. The letter, as quoted by KNN, said disruption would hit Indian recyclers, particularly micro, small and medium enterprises, and could raise raw-material costs and increase dependence on virgin metal.
Those figures describe the Indian melt's dependence on EU units. They do not set a European price, and they leave the draft metal column unchanged: India remains proposed for other waste streams and not for metal.
Who it affects among yards, traders, mills and processors
European yards and traders that sell waste-classified aluminium scrap, copper, zinc, lead or ferrous lots to Indian recyclers now have a counterpart that is lobbying its own government. A Delhi intervention, if it comes, would sit in the consultation that closes on 16 October and in the India-EU trade talks. It does not keep a May 2027 cargo lawful if the adopted list still omits India for metal.
Non-ferrous processors that pack extrusion, used beverage cans, mixed aluminium or copper-bearing lots for Indian remelters are more exposed on the MRAI percentages than ferrous exporters. Zinc is the highest EU share MRAI published. Ferrous sellers into India remain inside the same metal-waste finding; OECD destinations, including Turkey, do not.
Indian recyclers and MSME remelters are the buyers MRAI is writing for. If the EU book closes, they will need other origins. That does not automatically raise the bid those buyers can show for remaining lawful cargoes from the UK or other OECD loaders. European electric-arc mills and remelters are still the intended domestic offtake if those Indian books close. BIR and Recycling Europe have already said that offtake is not automatic.
Intra-EU sales and OECD shipments continue under existing procedures. An end-of-waste statement keeps a lot outside the waste-shipment file only where the criteria are actually met. Fastmarkets' 22 September reading of a ferrous reroute toward Turkey and UK exporters is the market map if the metal column is adopted as written.
What to check before 16 October and May 2027
The Commission consultation remains open until 16 October 2026. BIR has asked members for destination and waste-code evidence by 9 October. Comments that name India and the metal stream are the ones the assessment can use.
First adoption of the list is still put at 21 November 2026 by BIR and SteelOrbis, after which the delegated act goes to the European Parliament and the Council. MRAI's November deadline matches that calendar. 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, treat Indian waste recovery as unauthorised on the current draft, and do not stem a May 2027 cargo to an Indian port on the hope that the FTA talks will rewrite the waste list. 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 in India or another non-OECD country, 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.