The European Commission's draft list would allow EU metal scrap exports to only five non-OECD countries from 21 May 2027, and recyclers have asked for a longer consultation before the list is adopted by 21 November. The excluded markets take a minority of EU exports, while Turkey, the dominant buyer, is unaffected. Executives should treat any domestic price relief as uncertain and map their exposure by grade and destination now.
What Brussels Actually Put on the Table
On 18 September the European Commission published a draft list of non-OECD countries that may keep receiving certain non-hazardous EU waste once the revised Waste Shipment Regulation bites on 21 May 2027. From that date, such exports to non-OECD destinations are prohibited unless the country is on the list. Thirty-two countries and territories asked to stay on it. For metal scrap, the draft is narrow. Only Moldova, Montenegro, North Macedonia, Serbia and Ukraine are proposed for metal waste. India, Pakistan, Bangladesh, Morocco, Egypt, Saudi Arabia, Vietnam and several others are not. India was cleared for other streams, such as paper, but not for metals. The consultation closed on 16 October with 161 responses. On 19 October the Bureau of International Recycling asked the Commission to reassess the proposal and extend the consultation to at least eight weeks, with a deadline no earlier than 13 November. The first list is due by 21 November 2026.
The Tonnage at Stake Is Smaller Than the Noise
The debate sounds existential, but the numbers point elsewhere. The EU exported 16.31 million tonnes of scrap to third countries in 2025. Turkey took 10.78 million tonnes of that, more than 65%, and Turkey does not appear among the destinations the draft excludes. Egypt, the fastest-growing major buyer, took 1.83 million tonnes. So the volume that loses its outlet is a minority of the export trade, concentrated in a few markets: Egypt, India, Pakistan, Morocco, Bangladesh and Saudi Arabia. That is meaningful for those buyers. It is not a flood that will reset the European scrap balance on its own. The structural surplus is the bigger figure. Galloo France estimates that EU steel scrap supply has exceeded European demand by about 15 million tonnes a year on average over the past decade. Closing a few non-OECD doors does not make that surplus disappear. It pushes more of it toward the doors that stay open.
Who Pays First
The first bill lands outside Europe. Morocco's industry ministry says its five scrap-based EAF steelworks, with about 4 million tonnes of liquid steel capacity a year, rely on secure scrap supply. ABM Recycling says Pakistan imported about 2.6 million tonnes of ferrous scrap in 2024 and that the EU supplied about 717,000 tonnes in 2025, worth €432 million. EU material accounts for roughly 20-25% of India's ferrous scrap imports. Inside Europe, the first bill lands on collectors, shredders and traders who built their business on those routes. They lose buyers for specific grades and gain one dominant customer, Turkey, with more pricing power. The BIR argues that restricting exports "will not, in itself, create additional capacity or demand" in the EU, and that weaker export margins can undermine collection itself. That is the core risk. Scrap is not mined; it is gathered. If the economics of gathering weaken, supply quality and volume can suffer exactly when European EAF projects need more of it.
Why EU Mills Should Not Bank on Cheaper Scrap
Eurofer welcomed the draft, saying the EU "must not export its waste problems to third countries". Arvedi called ferrous scrap "a strategic secondary raw material". The steelmakers' logic is clear: keep more scrap at home and feed the shift to electric arc furnaces. The arithmetic is less clear. With Turkey still open and absorbing two-thirds of exports, the marginal tonne will often be redirected rather than retained. Arvedi itself flagged the risk of circumvention through OECD countries, misuse of End-of-Waste status and weak border controls. Each of those is a leak in the policy. The list is also not permanent. It must be updated at least every two years, and authorisation is specific to each waste stream. India and others are pressing for a separate customs code for processed secondary raw materials. A procurement plan that assumes a lasting domestic discount is building on a regulation that is still moving.
What Executives Should Do Before 21 November
Buyers of scrap in the EU should model two cases: a modest discount on grades that used to go to South Asia and North Africa, and no change at all on grades that Turkey keeps buying. Budgets should sit on the second case until the final list and the first months of 2027 trade data are in. Sellers and traders should map their exposure by destination and grade now. Business that depends on India, Pakistan, Egypt or Morocco needs either an OECD outlet, a processing route that qualifies as End-of-Waste, or a plan to shrink. Steelmakers outside Europe that rely on EU scrap have about six months after the list is adopted to secure other origins. That timetable is short for long-term contracts. The final list, due within a month, is the date to watch.
Sources
Fastmarkets, 19 October 2026: BIR urges Commission to reassess steel scrap export ban list, extend consultation GMK Center, 21 October 2026: BIR calls on the EU to continue consultations on scrap metal exports SteelOrbis, 24 September 2026: EU publishes draft list of countries authorized to import EU waste GMK Center, 21 September 2026: The EU is proposing restrictions on scrap exports to a number of markets