23 September 2026 – EU Waste Shipment Regulation: the Commission is now planning its export ban on metal scrap through the regulatory back door and under a green disguise. One year without new obligations: 13 EU Member States are calling for an end to Brussels’ bureaucratic madness.
Metal Scrap: Export Restrictions in Green Disguise
At the beginning of September, the Commission withdrew its planned trade measure against aluminium scrap exports. Now it is back, this time through waste legislation.
Scrap Exports Only to a Few Countries
On 18 September, Brussels published the draft country list under Waste Shipment Regulation (EU) 2024/1157. Thirty two non OECD countries had applied to continue receiving EU waste. For recycled steel and non ferrous metals, only a number of EU accession candidates are to remain eligible. All others would be cut off from 21 May 2027.
“In effect, this amounts to an export ban for the most important sales markets,” is the message from the recycling industry.
Where It Hurts
For steel scrap, OECD member Türkiye remains open. In 2025, it took almost two thirds of the EU’s 16.6 million tonnes of exports. Egypt, India and Pakistan are set to be excluded. Another 12 major buyer countries are also to be left entirely outside the system under the Commission’s plans because they allegedly fail to meet the required high standards.
Brussels justifies this tough approach under the usual green cover and applies a special standard specifically to recycled metals, even though the Waste Shipment Regulation itself does not provide for such a criterion.
The End of Europe’s Recycling Industry?
Europe’s recycling industry is dominated by small and medium sized enterprises, highly specialised companies whose loss the circular economy cannot afford.
Without export opportunities, however, these companies would lose important sources of revenue. Many types of metal scrap are particularly unpopular with steel producers because of their high copper content. For many smaller recycling companies, this could mean the end. The only beneficiaries would be the large and heavily protected EU steel and aluminium smelters. One could almost think there is a recurring pattern here.
The consultation runs until 16 October, after which the Council and Parliament can raise objections. They urgently should. Anyone who makes scrap cheaper by regulation is conducting industrial policy at the expense of SMEs. That is not environmental protection. It is Brussels style central planning.
13 EU Member States Call for an End to Brussels’ Bureaucratic Madness
One year without new obligations. CBAM shows why.
“Anyone who fights bureaucracy with legislation is trying to put out a fire with paper.” With these words, Austria’s Europe Minister Claudia Bauer presented a paper in Brussels on Tuesday backed by 13 Member States, including Germany.
The demand: spend one year implementing, simplifying and deleting rules instead of inventing new Regulations. Ursula von der Leyen had announced more than 20 new legislative initiatives just one week earlier.
Every steel importer knows the consequences. CBAM now comprises more than 3,500 pages of legal texts and guidance, more than 600 pages of them from August alone. To this day, the CBAM Registry cannot produce a single declaration. Yet Parliament and Council still want to expand the carbon border mechanism to another 457 product codes.
Bureaucracy Is Far Too Expensive
As early as 2021, Brussels estimated CBAM administrative costs of up to €45,300 per SME importer per year. Adjusted for inflation, that is now more than €55,000, calculated for a system that was planned to be considerably leaner at the time.
Did the Last Warning Letter to Brussels Achieve Nothing?
The complaint is not new. In October 2025, 19 heads of state and government sent a warning letter to Brussels, including Merz, Meloni and Macron. Why Macron, of all people, was part of it remains difficult to understand, given that his government pushed CBAM, the EU’s biggest bureaucratic monster, more aggressively than almost any other.
The fact that the initiative is coming from Vienna this time rather than Berlin illustrates Germany’s dilemma. Its governing parties are so preoccupied with themselves that Germany has squandered any claim to leadership in Europe. Entrepreneurs can send as many offers of dialogue and proposed solutions to Berlin as they like. The grandees of the Union are not listening. Others are.
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