FEAD’s key messages on trade restrictions for secondary raw materials

The forthcoming Circular Economy Act offers an opportunity to strengthen the Single Market for secondary raw materials and place recycling at the heart of Europe’s industrial and competitiveness agenda.

FEAD considers that policies affecting trade in secondary raw materials should support this objective by improving market conditions for European recycled materials rather than relying primarily on trade restrictions. Measures applying only to secondary raw materials, while leaving primary raw materials unaffected, risk placing European recyclers at a competitive disadvantage and undermining the level playing field needed for a circular economy.

Concerns over exports of valuable secondary raw materials are understandable. However, the underlying challenge is often insufficient European demand for recycled materials. A demand-driven approach, supported by mandatory recycled content requirements, circular public procurement and harmonised rules promoting the uptake of secondary raw materials, would more effectively retain valuable resources in Europe, provide investment certainty for recyclers and contribute to the EU’s circularity, resilience and decarbonisation objectives.

Strengthening European demand for secondary raw materials

FEAD considers that the most effective way to reduce exports of secondary raw materials is to create a strong and predictable European market for recycled materials.

Policies such as ‘Made in Europe’ recycled content requirements, and circularity criteria in Public Procurement should therefore become central elements of EU industrial policy. Together, these measures would create stable demand for recycled materials produced in Europe, encouraging investment in advanced sorting and recycling capacity.

This approach addresses the root cause of exports. Where recycled materials are exported, this is often because European demand and price signals remain insufficient. Creating stronger domestic markets would naturally retain more valuable materials in Europe without introducing unnecessary distortive trade restrictions.

Creating the right investment signals

Future recycled content requirements should distinguish between post-consumer and pre-consumer material. Mandatory recycled content targets should focus on post-consumer waste, while pre-consumer material should remain subject to reporting requirements only.

A consistent approach across EU legislation would better recognise the environmental and economic value of post-consumer recycling and ensure that recycled-content targets generate genuinely additional demand for materials collected, sorted and recycled after use.

At the same time, producing high-quality secondary raw materials increasingly requires significant investment in sorting, treatment and recycling technologies. Such investments depend on predictable long-term market demand. Progressively increasing post-consumer recycled content targets would provide the regulatory certainty needed to stimulate investment, expand recycling capacity and improve the quality of secondary raw materials.

FEAD Recommendations

FEAD therefore calls on the European Commission to:

• prioritise demand-side and market-based measures over export restrictions on secondary raw materials;
• introduce “Made in Europe” provisions for recycled content, including through mandatory recycled-content requirements and public procurement;
• establish mandatory post-consumer recycled-content targets, while keeping pre-consumer material outside such targets;
• promote policies that preserve the quality and value of secondary raw materials while allowing efficient circulation across value chains;
• provide long-term regulatory certainty to support investment in advanced sorting and recycling technologies; and
• ensure that any trade-related measures are designed in a balanced way across primary and secondary raw materials, preserving a level playing field for European recyclers.

A competitive European market for secondary raw materials, rather than trade restrictions alone, is the most effective way to retain valuable resources within Europe, strengthen industrial resilience and deliver the objectives of the Circular Economy Act.

FEAD, the European Waste Management Association, represents the entire waste management value chain, from collection and sorting to recycling, energy recovery, and final disposal. It brings together the private waste and resource management industry across Europe through its 21 national member associations, which collectively represent over 3,000 companies. Together, the sector provides more than 500,000 local jobs and fuels €5 billion in investments into the economy every year. For more information, please contact: info@fead.be