
While the newly published Economic Security Doctrine and the RESourceEU Action Plan confirm the central role of recycling and secondary raw materials in securing Europe’s industrial future, BIR cautions that several measures risk undermining the very resilience and competitiveness the EU seeks to protect.
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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.
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The Action Plan includes a number of initiatives directly affecting international recyclers:
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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.
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Note: This article has been issued by BIR and has been published by AL Circle with its original information without any modifications or edits to the core subject/data.
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