Europe’s aluminium scrap fight: who gains when exports are restricted?

A discarded window frame, a drinks can and an automotive casting can all appear under the same customs heading: aluminium waste and scrap. To the business collecting them, they are products to sell. To a plant that wants to remelt them, they are an input to buy. Restricting exports changes the bargaining position on both sides.

On 4 September, Reuters reported that Stéphane Séjourné’s office was preparing a delegated act to ban waste exports, including aluminium scrap, to non-OECD countries, with exceptions for some EU accession candidates. 1

As of 6 September 2026, we have not found a public final text establishing the measure’s full scope. The announcement should not be read as a new ban already in force. That distinction matters because existing EU legislation already provides for tighter waste-export rules from 2027. 2

The economic question is more revealing than a choice between free trade and industrial sovereignty. Export restrictions could make some scrap cheaper for European manufacturers. They could also reduce the returns earned by the businesses that recover it. Whether the result is more recycling or mainly a redistribution of margins depends on what happens well before the material reaches a furnace.

There is already a legal timetable

The EU’s Waste Shipment Regulation was adopted on 11 April 2024. Articles 40 to 42 establish a prohibition, with a route to authorisation, for specified non-hazardous waste sent for recovery to countries where the relevant OECD decision does not apply. Eligibility rests on environmentally sound waste management. Under Article 86, the main provisions of this regime apply from 21 May 2027. 3

The Commission says an initial list of authorised destinations must be established by 21 November 2026. India, Malaysia and Thailand are among the countries that have applied. An application is not an authorisation, and the assessment concerns specified waste streams. 4

The forthcoming proposal will therefore have to answer a practical question: how does the new measure interact with that approval process? Its exact material coverage, exceptions and start date also remain important. The timetable in the existing regulation cannot simply be assigned to a new act that has yet to be published.

A separate Commission trade consultation, running from 19 December 2025 to 31 January 2026, framed the issue around sufficient scrap availability for European industry. 5 Preventing environmentally damaging treatment abroad and securing affordable feedstock at home may sometimes support each other. They are still different objectives, requiring different evidence and different tests of success.

What the trade figures do, and do not, show

For a directly verifiable breakdown by destination, we use the World Bank’s WITS presentation of UN Comtrade data for 2024. Under HS code 760200, the EU exported 1,257,620 metric tonnes of aluminium waste and scrap outside the bloc and imported 656,430 tonnes. Subtraction gives net exports of 601,190 tonnes. 6 7

Sources: WITS / UN Comtrade, exports and imports. Net = exports minus imports. Scrap quantities, not pure aluminium content.

Data and scope

Flow	Tonnes
Gross exports	1,257,620
Gross imports	656,430
Net exports	601,190

These are quantities of traded waste and scrap, not equivalent quantities of immediately recoverable pure aluminium. The balance is not a measure of metal shortage or spare industrial capacity. Nor does it tell us whether the material bought and sold has the same composition.

A more recent headline number is available: European Aluminium put 2025 exports at 1.27 million tonnes, as reported by Reuters on 25 June 2026. 19 The charts retain the directly accessible 2024 WITS breakdown rather than attach newer totals to older destinations. This is a historical trade snapshot, not an estimate of the flows that the future measure will capture.

Source: WITS / UN Comtrade, HS 760200, calendar 2024. Denominator: 1,257,620 t. Hong Kong is a separate statistical destination. This is not a measure of the proposal’s legal coverage.

Data and scope

Destination	Tonnes	%
India	345,424.0	27.47
Thailand	157,135.0	12.49
Malaysia	117,087.0	9.31
Pakistan	102,193.0	8.13
Türkiye	91,281.5	7.26
Hong Kong (China)	80,658.0	6.41
China	71,775.8	5.71
Other destinations	292,065.7	23.22

India is the largest individual destination in that snapshot. Some sales also go to OECD members, including Türkiye, Switzerland and the United Kingdom. 6 8 A measure directed at non-members would not close every market outside the EU.

Trade diversion is therefore a possibility, not a quantified forecast. A seller losing one customer may seek another authorised outlet. That buyer may demand a discount. The material could change route without all of it being processed inside the EU. Tracking final destinations and treatment facilities would be necessary before calling every new route an attempt to evade the rules.

A furnace cannot erase every difference between alloys

There is a substantial energy case for recycling. The International Aluminium Institute presents savings of around 95% relative to primary production. Its comparison combines a global primary-production estimate for 2019 with regional recycling datasets from 2015 and 2018. It is a useful technical benchmark, not a measurement of every plant’s performance in 2026. 9

The production routes are also distinct. Primary production extracts metal from alumina through electrolysis; recycling remelts metal that already exists. 9 Keeping more scrap can help feed a recycling operation. It does not automatically solve the electricity bill of a primary smelting line.

Composition becomes critical at the next step. Manufacturing offcuts with a known specification, dismantled profiles and a shredded mixture need not be interchangeable inputs. European Aluminium acknowledges this in its own work on end-of-life vehicles: mixed alloys can be poorly suited to higher-grade sheet, extrusions and castings. The association advocates separating fractions into composition-based families. 10

Melting more material is therefore not the same as being able to manufacture any required product. Experimental research on recycled aluminium illustrates how iron can impair desired properties and how a different solidification process can improve iron tolerance. 18 That points to a technical constraint and a route for innovation. It does not establish a ready-made solution for every European scrap stream.

The economic implication is straightforward: a plant can be short of a particular grade while other grades struggle to find a buyer. Those conditions can exist at the same time. Adding all the tonnes together hides the distinction.

Recycling Europe, which represents recycling businesses, argues that some mixtures find outlets abroad that are inadequate or uneconomic within the EU. Its submission challenges the idea of a general shortage. 11 This is an interested trade association’s position, not independent verification that every exported tonne is unusable in Europe. It nevertheless identifies a question that policy has to answer grade by grade.

Cheaper feedstock is someone else’s lower selling price

Consider a lot of scrap whose best overseas outlet becomes unavailable. Holding quality, transport and demand constant, the seller has lost an option. A European buyer may be able to negotiate a lower price. The size of the discount would depend on alternative customers, storage and the cost of reaching a different destination. None of the documents reviewed provides a reliable rule for translating a restriction into a specific price change.

A hypothetical example makes the transfer visible. A €100-per-tonne reduction on 100,000 tonnes purchased during a year cuts the buyer’s purchasing bill by €10 million. On those same transactions, it also reduces sellers’ revenue by €10 million, before their own changes in costs and volumes. Neither figure represents a measured change in any company’s net profit.

A collector may respond by paying less for incoming material, or by cutting back on operations that no longer earn an adequate return. A remelter might increase production, pass some savings to customers, invest, or retain a higher margin. The outcome depends on competition at each stage and on contracts already in place.

This is why a measure described as support for recycling can help a business that remelts aluminium while hurting one that prepares it. The word “recycler” does not identify a single economic interest. Some companies combine several activities. Others earn their living from only one part of the chain.

Adjustment is unlikely to be simultaneous. A business that bought its stock before resale prices fell may face an inventory loss before the cost of new purchases catches up. A hoped-for long-term manufacturing benefit can coexist with an immediate cash-flow problem at a supplier.

That does not establish that collection would collapse. It explains why the financing of collection belongs in the assessment. Recovered metal is a resource, but recovering it remains a service that somebody has to pay for.

The strongest case for intervention deserves a hearing

It would be equally simplistic to dismiss manufacturers as buyers lobbying for a discount. In its January 2026 submission, European Aluminium called for an export duty of at least 30% across all third-country destinations, arguing that secure feedstock would protect recycling investment. 12 That percentage is a lobbying request, not an adopted EU tax or an established feature of the September proposal.

There is a serious industrial argument underneath it. A plant expected to operate for years needs access to suitable inputs at a cost its customers can support. An inability to secure that supply makes investment riskier. Lost processing capacity might also take time to rebuild if trading conditions later deteriorate. A plant’s strategic value can exceed its current quarterly margin.

Under that scenario, a temporary, well-targeted measure could give a supply chain time to strengthen. But the problem needs to be identified first. Is it a shortage of a particular grade, a documented trade distortion, financing, or processing costs? An export barrier changes the seller’s available outlets. It cannot be assumed to fix every one of those problems.

The best argument against restrictions is not that international trade always allocates materials perfectly. The OECD does, however, note that cross-border trade can provide the scale needed to make recycling viable, and that restrictions may prevent more efficient processing abroad. 13 That is a material consideration, not permission to ignore environmental standards wherever waste is sent.

Keep 100,000 tonnes. How much becomes usable metal?

Take a deliberately fictional annual scenario. An additional 100,000 tonnes need an outlet inside the EU. After sorting, 70% is compatible with the processing route being examined. Plants can handle an extra 60,000 tonnes, while commercial outlets could support 80,000 tonnes of equivalent incoming scrap. Processing capacity is therefore the binding constraint: 60,000 tonnes are treated.

At an assumed recovery yield of 90%, the route produces 54,000 tonnes of metal, leaves 6,000 tonnes of residues or fractions not recovered within that route, and leaves 40,000 tonnes needing a different outlet or a later treatment date. The last figure is neither a permanent loss nor an observed stockpile. Every input is illustrative.

l0g calculations. Metal: solid fill; residues: hatching; unassigned material: outline. The 100,000 t refers to incoming scrap, not pure metal. Assumptions are listed below.

Data and scope

Scenario	Compatible	Capacity (kt)	Outlets (kt)
Capacity constraint	70 %	60	80
Quality constraint	40 %	80	80
Aligned chain	90 %	90	90

The l0g scrap-outlet simulator lets readers change compatibility, additional capacity, commercial absorption and recovery yield. All constraints use equivalent tonnes of incoming scrap over the same period. The calculation identifies the limiting factor. It does not estimate the impact of the future regulation.

The exercise prevents a tempting shortcut: treating every tonne prevented from leaving as a tonne of finished metal immediately gained. It also does not measure additional global production. The resulting metal might replace another source, while a foreign buyer deprived of scrap could seek a substitute.

The outcome will be decided between sorting and sales

Better information comes first. The Commission activated customs surveillance of metal-scrap trade on 23 July 2025 and said it was working with stakeholders on more detailed classification. 14 A grade-specific policy needs that granularity. Aggregate tonnage does not identify preparation requirements, compatible capacity or missing orders.

Investment in handling difficult material matters too. SortCAS, a research project documented by the Commission, addresses automated aluminium-scrap sorting using sensors and separation technologies. 17 The project’s existence is not evidence of market-wide deployment. It does show that feedstock quality is a variable that engineering can work on, rather than an immutable feature of the waste pile.

Industrial financing also extends beyond border measures. On 23 February 2026, the European Investment Bank announced a €75 million loan to AMAG, contributing to a €168 million research, innovation and digitalisation programme for 2025–2028. 15 The project record dates the financing signature to 19 December 2025. 16 It is a loan, not a €75 million grant, and the programme is broader than a straightforward addition of recycling capacity.

Contracts between businesses deserve similar attention. A multi-year outlet with explicit quality requirements can give a scrap processor a reason to invest. A lower purchasing price without any volume commitment could send the opposite signal. These are mechanisms to compare, not outcomes already established in this case.

A useful assessment would track actual collection, the grades processed, preparation costs and lead times, material still seeking an outlet, and margins along the chain. It would also compare European processing with what would actually have happened abroad. The energy advantage of recycling over primary production does not, by itself, show that moving recycling from one country to another reduces global emissions.

Europe may have sound reasons to keep more used aluminium. It still needs a workable route from retained scrap to material that customers will buy. Better sorting, durable purchases and saleable output would signal success. A fall in exports alone cannot distinguish a stronger recycling industry from a growing difficulty in finding a home for its material.

Sources and methodology

Documentary research closed on 6 September 2026. Trade data cover calendar year 2024, apart from the separately identified industry total for 2025. Calculations and scenarios are by l0g; no simulation is a forecast. Trade associations’ positions are attributed. No interviews or plant audits were conducted.

[1] Reuters / Julia Payne. EU to propose ban on waste exports, including aluminium scrap, to non-OECD countries. 2026-09-04.

[2] European Commission, DG ENV. Waste shipments. Institutional page; publication date not displayed.

[3] European Union. Regulation (EU) 2024/1157 on shipments of waste. Adopted 11 April 2024; published 30 April; Articles 40–42 and 86.

[4] European Commission, DG ENV. Implementation of the Waste Shipment Regulation. Institutional page; publication date not displayed.

[5] European Commission, DG TRADE. Targeted consultation: EU measure for aluminium scrap. 2025-12-19.

[6] WITS / World Bank / UN Comtrade. European Union aluminium waste and scrap exports by country, 2024. Period: 2024. EUN, HS 760200, H0, quantities in kg.

[7] WITS / World Bank / UN Comtrade. European Union aluminium waste and scrap imports by country, 2024. Period: 2024. EUN, HS 760200, H0, quantities in kg.

[8] OECD. Members and partners. Institutional page; publication date not displayed.

[9] International Aluminium Institute. Aluminium recycling saves 95% of the energy needed for primary aluminium production. Industry source. Publication date not displayed.

[10] European Aluminium. Improve the Quality of Aluminium Scrap From End-of-Life Vehicles. Industry source; publication date not displayed.

[11] Recycling Europe. Feedback: EU aluminium sector trade measures. Industry source. 2026-02-16.

[12] European Aluminium. Call for evidence: aluminium scrap. Industry source. 2026-01.

[13] OECD. OECD Inventory of Export Restrictions on Industrial Raw Materials 2024, chapter 2. 2024-09-16.

[14] European Commission, DG TAXUD. Commission introduces surveillance of imports and exports of metal scrap. 2025-07-23.

[15] European Investment Bank. Austria: aluminium maker AMAG receives €75 million EIB loan for cutting-edge research and development. 2026-02-23.

[16] European Investment Bank. TECHEU AMAG ALUMINIUM RDI, project 20240905. Institutional page; publication date not displayed.

[17] European Commission, CORDIS. SortCAS: Innovative sorting facility for the circularity of aluminium scraps. Institutional page; publication date not displayed.

[18] Lu Jiang, Ross K. W. Marceau, Thomas Dorin. Improved iron-tolerance in recycled aluminum alloys via direct strip casting process. 10 October 2023; original research preprint.

[19] Reuters / European Aluminium. EU aluminium scrap export curbs delayed until September, group and sources say. 25 June 2026; the 2025 total is attributed to European Aluminium.