According to the Commission, the measure aims to “address the issue of aluminium scrap leakage” and secure access for European industry to this strategically important material at competitive prices. However, data from the Commission’s own monitoring mechanism on imports and exports of recycled materials shows no evidence supporting claims of “scrap leakage.” Available figures do not support this narrative, which may create a misleading basis for future policy decisions.
BIR welcomes the clear recognition of recycled aluminium as a strategic material essential to Europe’s circular economy and decarbonisation goals. At the same time, we stress that the global recycling industry is a vital contributor to the availability of this key raw material, and that its functioning relies on open, predictable and fair access to international markets.
BIR strongly recommends that any new trade measure should be:
- Evidence-based, reflecting actual market conditions rather than assumptions;
- Proportionate, avoiding unintended consequences for downstream users and recycling operators;
- Balanced, taking into account the interests of all actors in the value chain;
- Globally coherent, ensuring that the EU does not undermine international recycling flows that depend on Europe’s surplus of high-quality recycled materials.
BIR calls on the European Commission to uphold its stated commitment to “take into account the interests of all actors” as this initiative unfolds. We will continue to actively advocate on behalf of the recycling industry, support our members throughout this process, and participate fully in the forthcoming public consultation and call for evidence scheduled for later this year.
BIR stands ready to offer its expertise, data and global perspective to ensure that any future measure strengthens – not weakens – the circular economy and the global recycling ecosystem.
