From 21 May 2027 the EU will treat scrap export differently according to whether the destination is covered by the OECD Decision on waste. That split is already the question yards ask after the Waste Shipment Regulation and after Brussels dropped a planned aluminium export duty in September 2026. This note is a loading checklist, not a substitute for the regulation or for counsel on a given cargo.
The OECD line is about waste classification and destination. It is not a quality grade. HMS 80/20 to Aliaga and the same mix to a non-OECD mill may be the same furnace recipe and two different legal routes.
OECD and non-OECD in this trade
OECD members relevant to European scrap include Turkey, the United Kingdom, the United States, South Korea, Japan, Mexico and others. Turkey is the main seaborne buyer of EU ferrous scrap. The United Kingdom remains a large origin and a possible destination after Brexit, under the OECD track rather than as an EU Member State.
Non-OECD destinations that have historically taken EU or UK scrap include India, Pakistan, Bangladesh, China, Vietnam and Egypt. India is the world’s second-largest scrap importer and a major buyer of EU aluminium scrap. Those countries can only receive non-hazardous EU waste for recovery from 21 May 2027 if they appear on the Commission’s authorised list for the relevant stream, unless a later act says otherwise.
Egypt is not an OECD member. It was the second EU ferrous destination in 2025 after Turkey. Its place on the 2027 list is therefore a live commercial question, not a detail.
What already applies, and what starts in 2027
Until the new export chapter applies, Regulation (EC) No 1013/2006 still governs many shipments. Exports of waste for disposal, and of hazardous waste for recovery, to non-OECD countries remain banned. Green-listed metal scrap for recovery currently moves under the information procedure or, where required, notification.
From 21 May 2027, export of non-hazardous waste for recovery to non-OECD countries is generally prohibited. Exceptions exist only for countries listed by the Commission after they show environmentally sound management. The first list is due by 21 November 2026. A Reuters report of a draft in September 2026 said India, Thailand and Malaysia had not met the tests for metal waste; that draft is not the adopted list.
Exports to OECD countries for recovery continue under a regime closer to intra-EU shipments. The Commission will monitor volumes. If it finds that exports are rising and the waste is not managed soundly, it can engage the destination country and suspend those flows.
A delegated act announced by Stéphane Séjourné’s cabinet on 4 September 2026 would go further: a ban on waste exports, including aluminium scrap, to non-OECD countries, with exceptions for some EU candidate countries. Consultation and adoption were described as due by the end of 2026. The act has not been published. Grades, end-of-waste treatment and the link to the November list are not yet fixed.
What to check before the truck or vessel is booked
Confirm whether the lot is waste or has met EU end-of-waste criteria (333/2011 for iron, steel and aluminium; 715/2013 for copper). Product-status metal is not shipped as waste; the claim needs the statement of conformity and a lot that matches it.
Confirm the destination country’s OECD status and, for non-OECD from May 2027, whether it is on the authorised list for that waste code. Turkey as OECD is not in the non-OECD ban as the regulation is written. India, Bangladesh, Pakistan, China and Egypt are.
Confirm the waste code, green-list versus notification, and whether the shipment is intra-EU, to an OECD third country, or extra-OECD. Intra-EU movements have their own procedures; they are not “export” in the 2027 sense.
Confirm who is the notifier or exporter, the recovery facility, and that Annex VII or notification documents will travel with the load. The Digital Waste Shipment System (DIWASS) is part of the 2026 implementation of the new regulation for intra-EU and related flows. Ask the broker which procedure they are using.
Do not treat a commercial ISRI name as a customs or waste classification. 211, Berry and Taldon describe the melt. The movement follows the waste or product status and the CN code.
How this affects a European offer
Who buys European scrap in bulk is still, first, Turkish EAFs. That OECD route remains the least legally constrained seaborne outlet under the 2027 text. Non-OECD programmes (India, South Asia, Egypt) depend on the list and on any delegated act. CBAM does not replace those checks; it applies to many steel and aluminium products, not to scrap codes 7204 and 7602.
On the lot, write grade, tonnes, packing, load place, company, destination if known, and waste versus end-of-waste. Verified companies can list on live lots or wanted; request access if you have metal or a recovery operation.
OECD status decides which 2027 export door is open for waste-classified scrap. Check destination, legal status of the metal, and the documents before loading. The November 2026 list and the unpublished delegated act will narrow or confirm the non-OECD names.