BIR Warns EU Waste Export Restrictions Could Disrupt Global Recycling Markets

Draft EU list excluding India, Malaysia and Thailand could affect recycled metal flows and global circular supply chains

The Bureau of International Recycling (BIR) has raised concerns over a European Commission draft delegated act under the EU Waste Shipment Regulation, warning that proposed restrictions on exports of certain non-hazardous waste could disrupt international recycling markets. The draft list, published on 18 September, excludes major Asian destinations including India, Malaysia and Thailand from authorisations to receive certain ferrous and non-ferrous metal waste from the EU for recovery.

According to BIR, restricting exports would not necessarily create sufficient European demand or processing capacity to absorb the affected grades and volumes. The organisation says this could place downward pressure on recycled material prices, reduce incentives for collection and affect investment required to maintain future supplies.

Concerns Over European Processing Capacity

BIR noted that metals retain their intrinsic properties through repeated recycling cycles and that international trade allows different grades of these materials to reach facilities and markets equipped to process them.

The organisation highlighted aluminium in particular, stating that European supply, demand and processing capabilities do not always match every available grade.

Earlier this year, BIR responded to the European Commission's consultation on EU aluminium scrap availability and stressed that Europe generates more recycled aluminium than its domestic facilities can technically absorb. BIR said this concern is also relevant to the Commission's current proposal.

BIR acknowledged the European Commission's objective of ensuring environmentally sound waste management. However, it said any restrictions should be proportionate, supported by robust evidence and developed through meaningful engagement with affected recycling industries, industry associations and governments, particularly those in non-OECD countries.

Consultation Deadline Set for 16 October

The European Commission's public consultation on the draft remains open until 16 October 2026.

BIR is urging its members, industry associations, businesses and relevant governments to submit factual corrections, evidence and practical case studies concerning whether the proposed country and waste-stream authorisations are appropriate.

The organisation is preparing a consolidated industry response and said it remains available to work with the European Commission, diplomatic missions and relevant authorities. BIR's stated objective is a legislative framework that supports environmental protection while maintaining responsible recycling, resilient supply chains and free and fair trade in recycled materials.