The Bureau of International Recycling (BIR) has warned that the EU’s new economic and raw materials strategies risk undermining Europe’s industrial competitiveness and supply security. While the EU’s Economic Security Doctrine and the RESourceEU Action Plan emphasize the strategic importance of recycling and secondary raw materials, BIR argued that several proposed export restrictions could have the opposite effect by destabilizing global recycling markets and restricting access to high-quality secondary inputs.
The RESourceEU Action Plan outlines multiple interventions designed to strengthen the EU’s access to critical raw materials (CRMs). Among them are new export restrictions on scrap and waste from permanent magnets, which are expected by early 2026, and specific aluminum scrap streams, depending on ongoing market monitoring.
BIR stressed that such restrictions must be based on transparent datasets, proportionality, and clear analysis of their global impacts.
Measures adding pressure to international recycling markets
Beyond export controls, several incoming requirements will directly affect international recycling markets:
- Expanded EU product requirements and labelling rules for permanent magnets, including mandatory declarations of recycled content.
- Stronger incentives for recovering pre-consumer waste.
- Improved facilitation of CRM-rich waste shipments within the EU under the revised Waste Shipment Regulation.
- Creation of a European Critical Raw Materials Centre.
- Launch of an EU-coordinated CRM stockpiling scheme by early 2026.
- Enhanced collection targets through changes to the Waste from Electrical and Electronic Equipment (WEEE) Directive, aimed at securing access to end-of-life materials containing high CRM concentrations.
Complementing the Action Plan, the EU’s Economic Security Doctrine opens the door to adjustments in trade policy, industrial strategy and investment-screening tools. A comprehensive review in 2026 will determine whether additional instruments are needed to counter what the EU describes as “unfair trade practices and global market distortions”.
Export controls could distort markets and disrupt circular trade flows
BIR emphasized that circular trade flows are essential for efficient resource use and global emissions reductions. Export restrictions implemented without rigorous global impact assessments risk distorting competition, discouraging private investment, disrupting international recycling flows and weakening access to high-quality secondary raw materials
Maintaining open, competitive global markets, BIR argued, is crucial for supporting Europe’s own industrial decarbonisation and CRM security objectives.
“To secure Europe’s industrial future and resilience, the continent needs competitive, well-functioning international markets for recycled materials. We fully support the EU’s ambition to expand recycling capacity, but this success depends entirely on evidence-based policies and predictable trade frameworks,” BIR trade and environment director Alev Somer stated. Somer warned that measures designed without robust global analysis risk becoming “entirely counterproductive”.