The RESourceEU Action Plan sets out measures to secure the EU’s supply of critical raw materials (CRM), in particular new export restrictions on scrap and waste of permanent magnets, aluminium and potentially copper. As stated in previous BIR positions on the EU’s aluminium export framework and steel-sector support measures, trade-restrictive approaches must be grounded in transparent data, proportionality, and a clear assessment of global market impacts.
The Action Plan includes a number of initiatives directly affecting international recyclers:
- Export restrictions by early 2026 on scrap and waste of permanent magnets, targeted measures on aluminium scrap, and potential similar steps for copper depending on market monitoring.
- Expansion of EU product requirements and labelling rules for permanent magnets, including declarations of recycled content and measures encouraging recovery of pre-consumer waste.
- A strengthened focus on CRM waste shipment facilitation within the EU, aligned with the Waste Shipment Regulation.
- Creation of a European Critical Raw Materials Centre and the launch of a coordinated EU stockpiling scheme in early 2026.
- Measures to boost collection under the revision of the WEEE Directive, improving access to CRM-containing end-of-life products.
The Economic Security Doctrine complements this by signalling future adjustments to the EU’s trade, industrial, and investment-screening toolkit, with a 2026 assessment of whether new instruments are needed to respond to “unfair trade practices and global market distortions”.
BIR calls for transparent, proportional, data-driven policy design based on real-world trade flows and a balanced understanding of the international recycling market. Export-restrictive measures designed without rigorous global impact assessments can distort markets, reduce competition, and disrupt international circular-trade flows. For efficient resource use and emissions reductions worldwide, it is key to preserve the openness of global circular-economy trade and promote investments in positive incentives while avoiding counterproductive effects of restrictive trade measures.
“To secure Europe’s industrial future and resilience, the continent needs competitive, well-functioning international markets for recycled materials,” says Alev Somer, BIR Trade and Environment Director. “We fully support the EU’s ambition to expand recycling capacity, but this success depends entirely on evidence-based policies and predictable trade frameworks. Measures that hinder open trade, particularly those designed without rigorous global impact assessments, risk being entirely counterproductive.”
As the world’s leading voice of the recycling industry, BIR remains committed to collaborating with the European Commission and Member States to ensure that Europe’s pursuit of economic security and raw-materials resilience strengthens, rather than undermines, global circularity.
