FEAD response to possible trade measures to ensure sufficient availability of aluminium scrap on the EU market
FEAD, the European Waste Management Association, is deeply concerned about the EU’s initiative to regulate the aluminium scrap market and calls upon the European Commission to focus on the competitiveness of the entire aluminium value chain. Market restrictions on recycled materials impact our sector as export restrictions would impact any other industry. However, such restrictions are not imposed on the same materials when produced from primary sources, putting our industry at an unfair disadvantage and hampering the circular economy in the EU and globally. FEAD therefore, strongly rejects one-sided export restrictions for aluminium scrap.
FEAD supports open markets and free trade. If the Commission’s objective is supporting European aluminium production, this must be done by looking at the entire value chain and not only at the final step as this initiative reveals. In fact, with this initiative, the European Commission is not actually considering the sufficient availability of aluminium scrap on the EU market but the sufficient (financial) affordability of this material according to the views of the aluminium industry. This approach only focuses on one step of a value chain and fully undermines European recyclers and waste management operators, who are collecting, treating and providing the aluminium scrap.
In order to flourish and contribute to the EU’s environmental objectives, competitiveness and economic security, the European waste management industry requires strong and stable domestic demand of recycled materials. This is what FEAD has asked the European Commission to prioritise with the upcoming Circular Economy Act with concrete proposals.[1] Without strong and stable domestic demand of recycled materials, the only consequence of restricting exports of those will be limiting market outlets, loosing competitiveness and investment and innovation capacity. This, moreover, adds high risk of reciprocate trade restrictions, where the EU stands to lose due to its scarcity of (critical) raw materials. FEAD is opposed to exports of untreated waste and supports maximum collection, sorting and recycling within the EU, but stresses that a level playing field for the waste management industry vis-à-vis virgin producers requires comparable export rules. FEAD therefore urges the European Commission to reconsider its strategy with a holistic approach to ensure the competitiveness and sustainability of the entire European value chains, instead of solely focusing on one production step.
FEAD is furthermore concerned that the call for evidence focuses exclusively on the amount of aluminium scrap exported outside of the EU (1.2 Mio tons in 2024). Indeed, the background paper does not look into how much scrap is actually produced in the EU to understand what the level of exports is. It does not assess either how much aluminium scrap the EU can absorb (compared to total EU scrap production), and it equally fails to assess imports data (amounts of imports), as well as what are the price differences between EU scrap and imported scrap. Such information is essential.
As pointed out, FEAD strongly opposes one-sided export restrictions for aluminium scrap. If any such measures would nevertheless be imposed, they must be accompanied by the right measures to ensure the competitiveness of the entire value chain. This means recycled content targets for European aluminium scrap to a degree that they ensure both the necessary and complete uptake from European recyclers as well as a market price, which can be negotiated indexed to the LME price. Moreover, additional measures, such as Green Public Procurement to ensure the uptake of European scrap but also rules that recognise the overall sustainable benefits of scrap – no sliding scale system for GHG savings – must be implemented. This is necessary to guarantee a level playing field between recyclers and aluminium producers, as well as to incentivise investments in advanced treatment technologies for aluminium recycling facilities.
Finally, FEAD wants to point out at the lack of nuance in the call for evidence. In the context of the aluminium recyclates market, it is important to differentiate between aluminium cast and aluminium wrought alloys. For aluminium cast alloys, export will become essential for the upkeep of the value chain, since the European demand for aluminium castings is projected to shrink over the next years due to the electrification of motor vehicles. Thus, there will probably be an insufficient demand for aluminium cast alloys to utilise the quantity of aluminium cast scrap in Europe within the foreseeable future.
[1] https://fead.be/wp-content/uploads/2025/11/CEA-FEAD-position-paper-10-policy-reommendations.pdf
FEAD is the European Waste Management Association, representing the private waste and resource management industry across Europe, including 21 national waste management federations and 3,000 waste management companies. Private waste management companies operate in 60% of municipal waste markets in Europe and in 75% of industrial and commercial waste. This means more than 500,000 local jobs, fuelling €5 billion of investments into the economy every year. For more information, please contact: info@fead.be