Executive summary
- From 21 May 2027, the EU will only allow exports of non-hazardous waste, including steel scrap, to non-OECD countries that are on a list drawn up by the European Commission.
- The Commission’s draft list, published on 18 September 2026, authorises metal waste for only five destinations: Moldova, Montenegro, North Macedonia, Serbia and Ukraine. India, Pakistan, Egypt, Bangladesh, Vietnam and eleven other applicants would be approved for other waste, but not for metal.
- The recycling federation BIR said on 19 October that the Commission should reassess the exclusions and give affected countries at least four more weeks. The Commission must adopt the first list by 21 November 2026.
- Türkiye, which took about two-thirds of EU scrap exports in 2025 according to industry analysis of Eurostat data, is an OECD member and is not covered by this list. Egypt, India and Pakistan together took about 3.4 Mt. If the draft stands, more EU scrap is likely to stay in Europe or go to Türkiye, which could ease scrap costs for EU electric arc furnace (EAF) mills over time.
Key numbers
21 May 2027 Date from which EU exports of non-hazardous waste to non-OECD countries need the destination and waste stream to be on the Commission’s list FactDraft delegated regulation
32 Non-OECD countries and territories that asked to keep receiving EU waste FactEuropean Commission, 18 Sep 2026
5 Destinations the draft list approves for metal waste (Moldova, Montenegro, North Macedonia, Serbia, Ukraine) FactDraft delegated regulation
16 Applicants approved for other waste streams but refused for metal waste, including India, Pakistan and Egypt FactDraft delegated regulation
≈ 3.4 Mt EU steel scrap exported to Egypt, India and Pakistan in 2025, three outlets the draft would close to EU metal waste Calc.Loharo calculation from GMK Center figures based on Eurostat
161 Feedback responses on the draft, which closed on 16 October 2026 FactHave Your Say portal
Fact = supported by the cited primary source or clearly attributed reporting/market assessment · Calc. = Loharo calculation from cited figures · Uncertain = an attributed claim not independently confirmed · Analysis = interpretation or forecast with sourced premises.
What happened
The EU’s Waste Shipment Regulation, Regulation (EU) 2024/1157, closes most routes for exporting non-hazardous waste to countries outside the OECD. From 21 May 2027, such exports are allowed only to countries that asked to stay open, showed they can treat the waste in an environmentally sound way, and are named on a Commission list for that specific waste stream. On 18 September 2026 the Commission published its draft list, together with an assessment of each request. It says 32 countries and territories applied.
For metal, the draft delegated regulation is strict. Only Moldova, Montenegro, North Macedonia, Serbia and Ukraine would be cleared to receive EU metal waste. Sixteen other applicants that asked for metal would be approved only for other materials such as paper, rubber or glass: Bangladesh, Bosnia and Herzegovina, Egypt, Georgia, India, Indonesia, Malaysia, Morocco, Oman, Pakistan, Saudi Arabia, Sri Lanka, Taiwan, Thailand, Tunisia and Vietnam. In each case the draft says the country has not shown that it has the measures in place to manage metal waste in an environmentally sound manner. The Commission explains that it gave metal waste particular scrutiny because scrap can carry heavy metals such as lead, mercury and cadmium, and because shredding and smelting can release dust, fumes and contaminated residues.
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Advertise with LoharoThe feedback period on the Have Your Say portal ran from 18 September to 16 October 2026 and drew 161 responses. On 19 October, the Bureau of International Recycling (BIR) said it had asked the Commission to reassess the exclusion of major non-OECD markets for ferrous and non-ferrous scrap, and to extend the consultation to at least eight weeks, with a deadline no earlier than 13 November 2026. BIR argued that most recycled metal collected in Europe is already used by European industry, and that exports are needed for material that Europe has neither the demand nor the right plants to take.
Under the regulation the first list is due by 21 November 2026. According to BIR’s guide for members, the European Parliament and the Council will then have two months to object, which can be extended by two more months, before the act can enter into force. We could not open the regulation text on EUR-Lex during this check, so that timing rests on BIR’s summary.
Why it matters for steel buyers
According to GMK Center, which bases its figures on Eurostat data, the EU exported 16.31 Mt of steel scrap to non-EU countries in 2025. Türkiye took 10.78 Mt, more than 65% of the total, Egypt 1.83 Mt, India 1.02 Mt and Pakistan 585,000 t. EUWID, citing preliminary Eurostat figures, puts total exports at 16.6 Mt. We did not open the Eurostat database itself, so these volumes are marked as reported.
Analysis Türkiye is an OECD member. The list applies only to countries that are not covered by the OECD waste decision, so EU scrap can still be shipped to Turkish mills after May 2027. The change hits the other big deep-sea outlets in South Asia, North Africa and South-East Asia, such as India, Pakistan, Bangladesh, Egypt and Vietnam, which the draft would close to EU metal waste.
Analysis If those outlets close, EU scrap sellers will have fewer buyers bidding against European mills. That would tend to push EU scrap prices down relative to world prices and give Turkish buyers more pricing power, at least until trade flows settle. For EU buyers of EAF-made steel, mainly rebar, wire rod, merchant bar and a growing share of flat products, cheaper scrap would lower one of the main costs of their suppliers. Scrap is the main raw material in an EAF, as our raw materials primer and our EAF versus blast furnace guide explain.
Analysis The effect should not be overstated yet. The list is a draft, the Commission can change it after the consultation, Parliament and the Council can still object, and excluded countries can apply again later. Scrap exporters and some importing countries will push hard for changes. Scrap markets may also price in the change well before May 2027, so buyers who negotiate long-term contracts with scrap-based price formulas should watch it now.
Who is affected
- EU buyers of long products and EAF flat steel: a larger scrap supply at home could lower mill costs over time, which may show up in negotiations from 2027.
- EU EAF mills: potentially cheaper and more plentiful scrap, which helps the cost case for new EAF capacity.
- Scrap recyclers and traders: fewer export outlets for ferrous and non-ferrous scrap outside the OECD, and more dependence on EU and Turkish buyers.
- Mills in India, Pakistan, Bangladesh, Egypt and Vietnam: loss of EU scrap as a raw material if the draft stands, so they will need more scrap from elsewhere or more iron ore-based input.
- Turkish mills: they stay open to EU scrap and could face less competition for it.
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What to watch next
- The final list, due by 21 November 2026: whether the Commission adds any big metal importers after the consultation, or extends the feedback period as BIR asked.
- The Parliament and Council objection period: whether either institution objects to the list before it can enter into force.
- Scrap price spreads: how EU domestic scrap prices move against Turkish import prices as the May 2027 date approaches (see our latest scrap and iron ore market signals).
- New requests: countries left off the list can apply again, and the list must be reviewed at least every two years.
Verification status: Verified
- Material factual claims are supported by appropriate primary sources or clearly attributed reporting and market assessments; Loharo analysis is labelled separately. Last fact-check: 24 October 2026.
- Key: Verified = material factual claims are supported by an appropriate primary source or clearly attributed reporting/market assessments; Partially verified = a specific material claim remains unsupported, contradicted or materially overstated; Analysis = interpretation or forecast with sourced premises; Developing = material facts are checked but the situation is still changing.
Ask the Analyst
“2,000 t HRC from India into Genoa in Q1 2027 at €610/t CFR”: landed cost with duty, quota and CBAM in one answer.Ask the AnalystSources
Primary sources
- Draft Commission Delegated Regulation establishing the list of non-OECD countries to which exports of certain non-hazardous wastes are authorised — European Commission, published 18 September 2026 (draft, not adopted)
- Commission publishes draft list of countries authorised to import EU waste — European Commission, DG Environment, 18 September 2026
- List of non-OECD countries authorised to import certain non-hazardous waste from the EU — European Commission, Have Your Say
- BIR urges EU to reconsider recycled metal export restrictions and extend consultation deadline — Bureau of International Recycling, October 2026
- Members and partners — OECD
Supporting sources
- European Commission publishes draft list of non-OECD countries authorised to receive certain non-hazardous waste from the EU — BIR member update, September 2026
- The EU scrap market balance in 2025 — GMK Center, 5 May 2026, citing Eurostat
- Rebound in EU’s ferrous scrap exports and imports in 2025 — EUWID, 23 March 2026, citing Eurostat
- BIR urges EU to review recycled metal export restrictions and extend consultation — SteelOrbis, 20 October 2026
Related on Loharo
- Iron ore, coking coal and scrap: how raw material costs feed through to finished steel prices
- EAF versus blast furnace: what the two routes mean for emissions, costs and the green steel premium
- Scrap and iron ore send soft signals: Turkish HMS stalls near $400/t as seaborne ore slips below $90
Last fact-check: 21 October 2026 (Europe/Amsterdam).




