Three German associations have addressed a joint letter to European regulators in protest of prospective export restrictions on steel and metal scrap, Kallanish reports.
Germany’s Association of Steel Recycling and Waste Management Companies (BDSV), the Association of German Metal Traders and Recyclers (VDM), and the Federal Association for Secondary Raw Materials and Waste Management (bvse) include a detailed legal opinion on economic and competition law. The recipient is Teresa Ribera, executive vice-president of the European Commission and Commissioner for Competition..
In the corresponence, the associations frame the export curbs under discussion in Brussels as a massive intervention in functioning recycling markets – with significant risks for climate protection, the circular economy and investments.
The criticism focuses, amongst other things, on the new Waste Shipment Regulation, the Critical Raw Materials Act, and the European Steel and Metals Action Plan. From the associations’ perspective, these initiatives amount to politically restricting or effectively preventing scrap exports to third countries.
“Here, they’re pretending that structural and cost problems in the primary steel industry can be solved by restricting the sales markets of the recycling industry, even though there’s no shortage of scrap metal at all. It’s simply an attempt to drive down market prices,” says BDSV managing director Guido Lipinski. “Anyone who over-regulates functioning scrap markets not only endangers thousands of medium-sized businesses but also risks destroying a functioning circular economy. That would do significantly more harm than good to the European steel industry.”
The German and European steel and metal recycling sector is a key industry for the decarbonisation of manufacturing: In the EU, around 59% of steel production already comes from recycled scrap
“Of all companies, those that have been practicing genuine circular economy principles for decades are now supposed to pay the price for short-sighted industrial policy,” bvse managing director Eric Rehbock contends. “Instead of expanding recycling capacities, Brussels is sending the signal that investments in modern processing and sorting technology are a risk because markets can be shut down politically at any time. That is the opposite of a secure future for the transformation.”
The associations warn against misusing export restrictions as a seemingly simple solution to the competitive problems of individual industries.
“What is needed are reliable and investment-friendly framework conditions to enable additional recycling capacities, higher quality products and innovative technologies – especially in light of the transformation towards ‘green steel’,” they claim.
The three associations appeal to the European Commission to give significantly greater consideration to the interests of the recycling industry in the ongoing proceedings and to refrain from market-shielding export bans or de facto export restrictions.


