On 18 September 2026 Recycling Europe condemned the European Commission’s proposed treatment of ferrous and non-ferrous metal waste under the draft list of non-OECD countries that may import EU non-hazardous waste after 21 May 2027. The association, formerly EuRIC, said the draft would shut EU recycled metals out of major non-OECD Asian markets. The next day Argus reported that the same draft would exclude major ferrous destinations including Egypt, Morocco, Bangladesh, India and Pakistan from receiving the relevant material.
The Commission’s Environment department published the draft on 18 September, with an online consultation open until 16 October and the first adopted list due by the end of 2026. Thirty-two countries applied. Authorisation is by country and by waste stream. A name on a paper or textile line does not keep a metal cargo lawful. Shipments that are lawful today remain lawful until the 2027 dates apply.
The site’s 18 September note recorded India’s metal-waste finding, including aluminium scrap. This briefing is the recycler response and the ferrous destinations that sit behind Turkey on the EU export book.
What Recycling Europe objected to
Recycling Europe said the Commission is subjecting metal waste to particular scrutiny because of possible toxic heavy metals, the “non-degradable” nature of metals, and environmental risks tied to shredding, smelting and refining. The association called that characterisation technically incorrect. EU waste law already splits hazardous from non-hazardous metal on composition and properties. Secretary general Julia Ettinger said the environmental assessment must lead to the decision, not justify one already taken, and that an entire category of non-hazardous recycled materials cannot be treated as an environmental problem by default.
The association put European output at around 100 million tonnes of recycled steel and 6.2 million tonnes of recycled aluminium a year. It said recyclers already supply most of that metal to EU manufacturers, with only around 20 percent exported, and that those export tonnes are the outlet for surplus that European demand does not take. Closing overseas markets, it argued, will not create mill demand at home. If EU furnaces do not lift the metal, yards are left with fewer outlets, weaker values and growing stock.
Ettinger also pointed to what Recycling Europe called a contradiction on India: the draft would exclude the country as a destination for EU ferrous and non-ferrous metal waste, while the Commission is, in the association’s account, considering two Indian ship-recycling yards that use beaching for the European List of approved ship recycling facilities. That claim is Recycling Europe’s. It is not independently confirmed here. Recyclingportal republished the statement on 21 September.
Recycling Europe asked the Commission to reassess ferrous and non-ferrous metal waste so the final list rests on the actual risks of specific streams and on demonstrated conditions in receiving countries and plants.
What Argus recorded on ferrous destinations
Argus, writing on 19 September, said the draft would keep Egypt, Morocco, Bangladesh, India and Pakistan off the relevant material. Those names matter for HMS and shredded programmes, not only for aluminium scrap into India.
Citing Global Trade Tracker, Argus put Egyptian intake at 1.86 million tonnes in 2025 and 947,000 tonnes in January–July 2026, 34 percent higher than a year earlier. The same report said Moroccan and Pakistani volumes had risen sharply and that Indian volumes had fallen. BIR figures already used on the site put the EU’s 2025 ferrous export book at about 16.7 million tonnes, with around 10.8 million tonnes to Turkey and Egypt next among EU destinations at about 1.9 million tonnes. That Egypt figure matches the Argus 2025 number closely enough to treat Egypt as the second seaborne outlet, not a side market.
Turkey is an OECD member. It is not decided by this list. Who buys European scrap still starts with Turkish electric-arc mills. Egypt, Morocco, Pakistan, Bangladesh and India are the non-OECD names now in dispute. CIJ.World, also on 19 September, recorded the same split inside the European industry: recyclers need overseas offtake for surplus; EU mills want more scrap retained as feedstock.
The consultation documents are stream-specific. Egypt can appear as authorised for paper, textiles or glass and still be closed for metal waste. Check the metal line, not whether the country is mentioned somewhere on the draft.
Who it affects among yards, traders, mills and processors
Export yards and traders that stem ferrous cargoes to Alexandria, Casablanca, Karachi, Chattogram or Indian west-coast ports need a 2027 plan. If the adopted list follows Argus’s reading, those waste-classified lots cannot leave the EU for those destinations from 21 May 2027. The metal can still move to OECD destinations such as Turkey and the United Kingdom, to any non-OECD country that is actually authorised for metal waste, or as end-of-waste product where the criteria are met. A mixed parcel labelled as product without a statement of conformity does not change its legal status.
European electric-arc mills and remelters are the intended beneficiaries. If Egyptian, Moroccan and South Asian demand is cut off and domestic furnaces lift the metal, more HMS, shredded and prepared specification stays inside the Union. Recycling Europe’s warning remains the commercial risk: if EU demand does not take the surplus, collection and processing lose margin. Processors that already produce a specification a Brescia, Duisburg or Iskenderun melt will charge have a clearer book than yards that only pack export mixes for North Africa and South Asia.
Intra-EU sales and OECD exports continue under existing shipment procedures. CBAM still prices carbon on steel and aluminium entering the Union; it does not replace the waste-export list. The withdrawn aluminium export duty is not the instrument in force.
What to do before 16 October
Trade associations and companies that ship metal waste can file comments on the Commission’s 18 September consultation before 16 October 2026. The comments that matter name the country and the metal stream. Do not argue from a paper or textile authorisation.
For the 2027 book, split counterparts into OECD, authorised non-OECD for metal, and unauthorised. Record whether each lot is waste or end-of-waste, and which recovery plant is named. Do not stem a May 2027 cargo to Egypt, Morocco, Pakistan, Bangladesh or India on the hope that metal waste will be added later. Later applications can be considered; the Commission has already said there is no guarantee they will be decided before the first list.
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 and keep a copy of its status on the authorised list once that list is adopted. Verified companies can place the parcel on live lots or post a wanted enquiry. Request access if you need a member account.