BIR Convention Highlights Growing Trade Restrictions on Recycled Materials Over Strategic Supply Chain Concerns

Industry representatives warn that national security and economic priorities are increasingly shaping trade policies, creating challenges for global recycling markets and circular supply chains

Trade restrictions on secondary raw materials are increasingly being driven by political and strategic supply chain concerns rather than economic or environmental objectives, speakers at the Bureau of International Recycling (BIR) World Recycling Convention in Malaga, Spain, were told. During the International Environment Council session on October 26, participants discussed policy changes in the United States, Europe and other regions, and their implications for international recycling businesses.

Export Restrictions on Recycled Materials Increase

Alev Somer, BIR's Trade and Environment Director, highlighted OECD analysis indicating that export restrictions have increased fivefold over the past 15 years.

She said the trend was particularly concerning for raw materials, including recycled metals, which are increasingly classified as strategic or critical because of their limited availability in specific regions.

According to BIR, policymakers introducing trade barriers often fail to understand the business model of recycling companies, potentially undermining the development of the circular economy.

“We need global supply chains,” Somer said. “We need to reach out to where we can refine our material, where we can recycle them. Trade restrictions are doing the opposite: they kill our industry.”

Policy Priorities Shift Towards Strategic Supply Chains

In her presentation, Somer examined the changing policy narrative from securing sustainable supply chains to prioritising strategic supply chains, drawing on discussions with G7 countries and the OECD over the past three years.

She said policy discussions had gradually moved away from open trade towards greater emphasis on resilience, security and domestic production.

“The conversation is changing from open trade towards ‘We need to be more resilient’ and ‘Oh, we have a security issue’. Now they are looking more and more to economic security and onshoring. Then, it’s ‘Let's do things domestically’. Or they think of stockpiling and approaches that bring about the feeling of national security.

“We are shifting from resilient, sustainable and diversified supply chains towards a much stronger emphasis on economic security, national security and strategic dependencies. So we are raising our voice as much as we can.”

Opening the session, International Environment Council (IEC) Chairman and Recycling Europe President Olivier François recalled that discussions on the EU's updated Waste Shipment Regulation (WSR) began in 2019.

He noted that restrictions on recycled metal exports, initially considered under the EU's Steel and Metals Action Plan, were subsequently incorporated into the WSR.

“From a wide, open discussion on waste shipments, suddenly there is a very specific and very important consequence for us with regard to the export ban on metal to non-OECD countries,” he said.

US Policy Places Greater Emphasis on National Security

The United States is also seeing changes in its approach to exports of secondary raw materials, particularly critical raw materials, according to the country's national recycling association, ReMA.

Adam Shaffer, ReMA's Vice President of International Trade, highlighted what he described as a difference in how trade restrictions are justified in the US and Europe.

“What you're seeing [in Europe] in terms of trade restrictions disguised as environmentalism, in the US we're seeing trade restrictions disguised as national security concerns.”

Shaffer said national security had been cited by the first Trump administration to justify import controls during 2017–19, with the aim of supporting increased domestic production. The current policy direction, however, involves export restrictions.

“Over the last couple of months, we've seen the Trump administration's efforts to impose what's called a domestic purchasing requirement for recycled tungsten and black mass.”

He explained that the measures reflect an effort to secure domestic supply chains for minerals and materials considered scarce or critical.

Under a Defense Production Act requirement, traders must seek government authorisation to export certain materials, even when there is no domestic demand for them.

ReMA is preparing a report examining the extent to which recycled materials are used in defence supply chains.

Shaffer also highlighted a government proposal for a domestic purchasing requirement covering high-value copper scrap.

“The government has been considering, for example, a 25% domestic purchasing requirement for high value copper scrap,” he said. “That's a huge amount given the actual copper scrap usage in defence supply chains.”

ReMA Raises Concerns Over Licensing and Traceability

ReMA President Robin Wiener (USA), speaking from the floor, said domestic purchasing requirements represented a new development in US policy.

She recalled discussions with government officials following the introduction of export restrictions on tungsten and black mass.

“When we met with the government, we said, ‘Okay, you've just given us an export ban for tungsten and black mass’. They said: ‘What are you talking about? It's a domestic sales requirement and you can get an exemption’. Well, you get an exemption if you show your supply chain is with friends.”

Wiener also raised concerns about traceability requirements, arguing that the exemption process effectively amounted to a licensing regime.

She questioned how recycling businesses would be expected to map supply chains to demonstrate that materials remained within Western markets.

“There are ways of the government finding out what your supply chain looks like through a licensing regime. How do we map our supply chains to show [products] are staying in the West? The approach the US government is taking is that ‘Western’ supply chains are good for materials that are determined to be critical. That is a policy issue, not a technical issue.”

BIR Steps Up Advocacy Against EU Export Restrictions

BIR Trade and Environment Policy Officer Alexandra Vartan outlined the organisation's efforts to challenge a European Commission delegated act identifying which non-OECD countries could receive EU exports of recycled metals and other secondary material streams.

She said BIR's advocacy department had quickly informed members and issued a public statement outlining how the proposed restrictions on key non-OECD markets could disrupt recycling businesses and global supply chains.

BIR also submitted a consolidated response to the European Commission.

The organisation sent letters to the authorities of affected countries and subsequently held meetings in Brussels with representatives from Egypt, Hong Kong, India, Malaysia, Pakistan, Taiwan and Thailand.

Vartan said BIR would continue its engagement ahead of the EU's final list, expected on November 21, and the regulatory regime's implementation in May 2027. The list will be reviewed every two years.

Call for Greater Consultation Across the Value Chain

François urged the European Commission to provide detailed analysis explaining why specific metals had been selected and to increase consultation with industry stakeholders.

He said discussions involving different parts of the European value chain were difficult to organise, with policymakers currently hearing predominantly from one section of the industry.

“If we want to define a strategy it has to be for the entire value chain - from the raw material to the metal processing to, for example, the car manufacturers,” he said.

The session highlighted growing concerns that strategic supply chain policies and export controls could restrict international trade in secondary raw materials. BIR representatives called for broader stakeholder consultation and policies that consider the entire recycling and manufacturing value chain.