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The Bureau of International Recycling (BIR) has urged the European Commission to extend its consultation on the proposed list of non-OECD countries that will be authorized to import certain non-hazardous waste from the European Union from May 2027.
In a statement sent to Fastmarkets on Monday October 19, the association requested a four-week extension to the consultation period to “at least eight weeks, with a deadline no earlier than November 13, 2026.”
The consultation, which opened on September 18 and closed on October 16, received 161 responses both in favor and against the proposed draft list, which excludes countries such as India, Pakistan, Bangladesh, Morocco and Egypt as destinations for both ferrous and non-ferrous recycled metals from the EU. A final list must be published by November 21.
“BIR is calling for a reassessment of the proposed restrictions and of the evidence and legal reasoning underpinning them,” a spokesperson said. “The additional time would allow affected countries and territories to coordinate with ministries, regulators and facilities, respond to the Commission’s findings and submit supplementary evidence before the final list of authorized destinations is established.”
As part of its feedback to the consultation, submitted on September 23, BIR told Commission officials that it was “deeply concerned” that the proposed restrictions could significantly disrupt global trade flows, distort markets and limit access to steel scrap while also undermining the future availability of recycled metals within the EU.
It is unclear whether officials would consider the renewed requests. The Commission did not immediately respond to Fastmarkets’ request for comment.
Feedback received to date
The proposed restrictions have drawn mixed responses from companies, industry groups and authorities, with several recyclers and scrap consumers questioning the environmental and economic justification for excluding non-OECD destinations, while European steelmaking interests have argued in favor of retaining more scrap within the bloc.
European recyclers question proposed restrictions
French recycler Galloo France said it “seriously questions” the Commission’s proposal to impose what it described as an “ex ante ban” on scrap exports to non-OECD countries, arguing that European supply already exceeds domestic demand for some metals.
For steel, Galloo estimated that this surplus has averaged around 15 million tonnes compared with European demand over the past decade, per its feedback seen by Fastmarkets.
Finland-based Kuusakoski Recycling similarly argued that the proposal was inconsistent with the objectives of the Waste Shipment Regulation and could distort global recycling markets. The company said the proposed rules risked having an adverse impact on global emissions, European recycling rates and recycling businesses.
Cronimet also questioned the “consistency, proportionality and legal basis” for the near-total exclusion of non-OECD destinations for non-hazardous metal waste, particularly when some of the affected countries would remain authorized to receive other waste streams.
Danish recycler HJHansen Recycling Group also opposed the proposed restrictions, saying it did not see evidence that they were based on an environmental assessment.
Non-OECD countries raise scrap supply concerns
Concerns have also emerged from companies and authorities in countries that could lose access to EU scrap under the proposed list.
Morocco’s Ministry of Industry and Trade highlighted the country’s scrap-based electric-arc furnace (EAF) steel sector, which it said comprises five modern EAF steelworks with combined liquid-steel capacity of around 4 million tonnes per year.
The ministry said imported scrap was used as a raw material for melting and argued that excluding metal waste from EU exports would destabilize the industry and threaten its supply security.
Pakistan-based ABM Recycling, meanwhile, described Pakistan as a scrap-deficit market, citing imports of around 2.6 million tonnes of ferrous scrap in 2024. It said the EU supplied about 717,000 tonnes of ferrous, aluminium and copper scrap to Pakistan in 2025, worth €432 million ($484.2 million), and argued that specification-grade material was purchased as furnace feed rather than being shipped for disposal.
European steelmakers back EU scrap export controls
However, the Commission’s approach has also received support from European steelmaking interests.
European steel industry association Eurofer welcomed the draft proposal, saying that when the revised Waste Shipment Regulation was adopted, “co-legislators made a clear commitment: the EU must not export its waste problems to third countries. This must also be consistent with the Basel Convention, which the EU ratified long ago.”
Italian steelmaker Finarvedi, part of the Arvedi Group, echoed the statement, arguing that countries unable to provide adequate guarantees of environmentally sound waste management should not be authorized to receive EU ferrous scrap.
It described ferrous scrap as “a strategic secondary raw material” and said keeping the material within the EU would support environmental protection and European strategic autonomy.
Steel groups flag implementation and circumvention risks
Arvedi nevertheless highlighted potential implementation challenges, including the misuse of End-of-Waste status, possible circumvention through OECD countries and insufficient border controls.
Italian steel association Federacciai, its Spanish counterpart Unesid and Polish steel association HIPH, raised similar concerns, warning that such issues could undermine the effectiveness of the measures if left unaddressed.
The European Commission has yet to fully disclose the content of all feedback received during the consultation ended on Friday October 16.
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