Maria Vera Duran, policy director at Recycling Europe, talked to SteelOrbis giving her review of 2025 and expectations for 2026.
Review of 2025
For European metal recyclers, 2025 unfolded against a backdrop of growing uncertainty and a strengthened trade-protectionist narrative. The year began with two key policy announcements: the Clean Industrial Deal in February 2025 and the Steel and Metals Action Plan in March. While the European Commission reiterated its ambition to increase the circular material use rate, policy developments over the course of the year did little to translate this objective into concrete progress. On the contrary, additional layers of regulatory and market uncertainty for metal recyclers were introduced.
The prospect of export restrictions on recycled metals, particularly aluminium, copper and steel, for which trade monitoring assessments were conducted, raised serious concerns about the viability of investments aimed at expanding and upgrading recycling capacity across Europe. This situation was further compounded by the entry into force of the new Waste Shipment Regulation, which is already expected to affect established trade flows.
The year concluded with a political agreement on new End-of-Life Vehicles (ELV) rules. While these rules will introduce recycled content targets for steel, aluminium, magnesium and certain critical raw materials, they will also impose quality requirements on output fractions, adding another layer of compliance for recyclers. Another key development in 2025 was the increasing focus on “green steel” definitions and the role of ‘scrap’ in emissions accounting. Discussions around benchmark methodologies, lifecycle emissions, and access to low-carbon feedstock intensified, with Recycling Europe actively advocating for fair, science-based approaches, and opposing biased methodologies - such as the proposed sliding scale models - that risk penalising the use of recycled metal rather than recognising its carbon-reduction benefits. The lack of clarity on how ‘scrap’ would be treated under future green steel frameworks continued to complicate long-term investment planning and contract structures for recyclers.
Expectations for 2026
Throughout 2025, Recycling Europe consistently highlighted the need for ambitious demand-side measures to stimulate the uptake of recycled metals within the EU. Ensuring sufficient local demand from European producers, while preserving recyclers’ access to open markets to allocate their output, remains essential in 2026. However, the translation of these principles into concrete policy tools, such as mandatory recycled content requirements, has yet to materialise. These measures are expected to be further developed through upcoming legislative initiatives, including the Circular Economy Act, the Ecodesign for Sustainable Products Regulation, the revision of the WEEE Directive, and secondary legislation supporting the End-of-Life Vehicles Regulation (ELVR). Therefore, for metal recyclers, 2026 is expected to be a decisive year from a policy perspective rather than a market-driven turning point, as several key legislative initiatives will enter critical phases, and their implementation will directly influence investment decisions, trade flows and access to markets for recycled metals.
A central issue will be the European Commission’s forthcoming definition of “green steel”, expected by the end of January 2026. Recycling Europe expects this debate to set a precedent for how recycled materials are valued across industrial policy. The continued reliance on sliding scale methodologies could undermine demand for recycled steel, weaken circularity incentives and send contradictory signals to investors in recycling capacity, if adopted without corrections. More broadly, 2026 will test whether demand-side measures for recycled metals can move from political intent to concrete instruments.
Trade policy will remain another critical area. The risk of export restrictions on recycled metals is expected to remain high, particularly for aluminium, copper and steel. Recycling Europe expects continued engagement with policymakers to ensure access to open markets, allowing recyclers to balance domestic demand with global trade realities.
Overall, Recycling Europe views 2026 as a year in which policy coherence will determine whether Europe can strengthen its recycling base. Clear recognition of the emissions benefits of recycled materials, avoidance of protectionist distortions, and credible demand-side measures will be essential to prevent further investment hesitation and support the role of recycling in Europe’s industrial and climate strategies.