Position papers

Revision of the Waste Shipment Regulation

The steel industry welcomes the release of the Waste Shipment Regulation revision by the European Commission. However, significant improvements are necessary to ensure effectiveness of the revised rules in contributing to the objectives of the EU Circular Economy Action Plan and the EU Green Deal.

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Facilitating shipments of waste for reuse and recycling in the EU, not exporting waste challenges outside the EU and addressing illegal shipments of waste, are crucial for the European Union to adequately manage waste shipments in a clean and more circular economy and to avoid losses of valuable resources that can be recycled in the EU. This is consistent with the objectives of the EU Circular Economy Action Plan and the EU Green Deal.

The European Commission recognises the steel industry as a priority sector for transitioning to a circular and climate-neutral European economy: recycling of ferrous scrap in the EU plays a fundamental role in decarbonisation, and this will become more and more relevant in the near future. Therefore, it is essential that the potential of EU recycling is fully unlocked, the waste domestic market functions smoothly and at the same time export of waste does occur only when comparable environmental, health and social conditions exist between the EU and third countries, and only when those conditions are verified with certainty.

Significant improvements are necessary to ensure that the proposed measures are implementable, effective, and that no risks of fraud or circumvention arise. The fundamental principle of environmentally sound management should apply effectively to all waste exports and to all destination countries. The different treatment between OECD and non-OECD countries, and the subsequent fact that certain destination countries may be exempted from having to demonstrate the extent to which they meet these essential conditions, is contrary to the spirit of the reform and could undermine the whole system.

Moreover, a careful evaluation is necessary to ensure that additional administrative burden will not hinder intra-EU shipment, while a three-year transition period before the entry into force of the new requirements is excessively long as far as ferrous scrap is concerned.

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Published: 10 December 2021

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The European Steel Association (EUROFER)
172 Avenue de Cortenbergh
1000 Brussels


Email: mail@eurofer.eu
Phone: +32 (0) 2 738 79 20