BIR Warns EU of Market Risks in New Security and CRM Plans

Industry Raises Red Flag Over Trade Restrictions

BIR cautions that the EU’s new Economic Security Doctrine and RESourceEU Action Plan, while prioritising recycling, could unintentionally distort global markets without data-driven policy design.

The Bureau of International Recycling (BIR) has urged the European Union to ensure that its newly unveiled Economic Security Doctrine and RESourceEU Action Plan do not unintentionally destabilise global recycling markets, despite their strong emphasis on the importance of secondary raw materials in strengthening Europe’s industrial security.

The RESourceEU Action Plan lays out a wide-ranging set of measures aimed at safeguarding the European Union’s access to critical raw materials (CRMs). Central to the strategy are new export restrictions on scrap and waste streams involving permanent magnets, aluminium and—pending market assessment—copper. BIR notes that these steps, unless grounded in robust evidence and proportionality, could backfire by weakening the very supply-chain resilience the EU seeks to reinforce.

The plan details several actions with direct implications for international recyclers:

• Export restrictions by early 2026 covering scrap and waste of permanent magnets, along with targeted controls on aluminium scrap and potential similar provisions for copper.
• Expanded EU product rules and labelling obligations for permanent magnets, including recycled-content declarations and mechanisms to encourage recovery of pre-consumer waste.
• A stronger emphasis on facilitating CRM waste shipments within the EU under the Waste Shipment Regulation.
• Establishment of a European Critical Raw Materials Centre and the rollout of a coordinated EU stockpiling system beginning in 2026.
• Enhanced collection and access measures via the upcoming revision of the WEEE Directive, particularly for CRM-containing end-of-life products.

Complementing the Action Plan, the Economic Security Doctrine signals further changes to the EU’s trade, industrial and investment-screening tools. A 2026 review will determine whether new policy instruments are required to respond to “unfair trade practices and global market distortions”.

BIR stresses that policy decisions of this scale must be anchored in transparent global data and careful economic impact assessments. It warns that restrictive trade measures, if implemented without a full understanding of international market dynamics, may disrupt circular-economy flows, weaken competition and undermine global resource-efficiency goals.

“To secure Europe's industrial future and resilience, the continent needs competitive, well-functioning international markets for recycled materials,” says Alev Somer, BIR Trade and Environment Director. “We fully support the EU’s ambition to expand recycling capacity, but this success depends entirely on evidence-based policies and predictable trade frameworks. Measures that hinder open trade, particularly those designed without rigorous global impact assessments, risk being entirely counterproductive.”

BIR, representing recyclers worldwide, reiterates its commitment to working with the European Commission and Member States to ensure that Europe’s economic-security agenda strengthens global circularity instead of creating new barriers.