EU aluminium sector – trade measure to ensure sufficient availability of aluminium scrap on the EU market

>> Ultimately will lead to lower prices and negative consequences and down-cycling. As a matter of basic economics - there is an export of aluminium scrap at this time as sale prices are higher overseas. By blocking export or placing an export tariff on scrap exports then effective sale prices or sales proceeds to domestic EU scrap processors or sellers will fall.

FEAD, the European Waste Management Association, is deeply concerned about the EUs initiative to regulate the aluminium scrap market and calls upon the European Commission to focus on the competitiveness of the entire aluminium value chain. Market restrictions on recycled materials impact our sector as export restrictions would impact any other industry.

As an association representing a downstream sector, dependent on a stable supply of aluminium and recycled aluminium, FIM considers it important that the European Union intervenes to ensure, in the long term, the availability of sufficient volumes of aluminium scrap on its domestic market.

Measures to prevent scrap exports are essential to ensure European recycling capacity in the EU in the long term, reduce dependencies on aluminium imports and ensure the survival of industry and the many jobs it provides.

Filed in German · English published by the European Commission

Blanket export restrictions on aluminium scrap would weaken Europes circular economy without strengthening industrial competitiveness. There is no structural shortage of aluminium scrap in the European Union. Scrap exports are a market-balancing mechanism, occurring when domestic demand or processing capacity within the EU is temporarily insufficientnot a sign of market failure.

The EU must prevent material leakage from end-of-life products and all waste products, including scrap, relating to aluminium. This should preferably be achieved via export bans, more harmonised waste criteria, or levied export fees, which would make exporting to third countries more expensive and burdensome.

Hydro Aluminium Clervaux SA strongly supports introduction of trade measures on exports of aluminium scrap as set out in the Steel and Metals Action Plan adopted in March 2025. We are in favour of a flat export fee (an export duty) on aluminium scrap (customs code HS 7602) of around 30%. It needs to cover exports to all destinations except the European Economic Area countries.

EUROFER supports the Commissions intention to develop robust, forward-looking measures that retain more secondary materials. As with aluminium scrap, the trade flows of ferrous scrap generated within Europe should also be strictly controlled and regulated by suitable trade measures, appropriately designed to ensure that future policies deliver maximum environmental, economic, and strategic value for the European…

European Metals, the European non-ferrous metals association, calls for the introduction of a uniform export duty that applies universally towards all countries. As an alternative, and only as a fallback option, we see the possibility of introducing tariff rate quotas (TRQs), which should be based on historical export volumes (i.e. not reflecting the large surge in exports seen in recent years).

ESWET the European Suppliers of Waste-to-Energy Technology represents companies that have built and supplied over 95% of the Waste-to-Energy (WtE) plants in operation in Europe. It seeks to promote the technologies which recover both energy and materials from non-recyclable waste that would otherwise end up in landfills.

As a group representing a strategic downstream sector, heavily dependent on a stable supply of recycled aluminium, GIFAS considers it important that the European Union intervenes to ensure, in the long term, the availability of sufficient volumes of aluminium scrap on its domestic market.

Filed in French · English published by the European Commission

Too much valuable aluminium scrap is leaving Europe and being utilized elsewhere in countries with lower processing costs, subsidized overcapacity and/or less advanced collection and sorting infrastructure. Every tonne of scrap leaving Europe is a missed opportunity for investment, competitiveness, and decarbonization. Europe must actnow.

Hydro Extrusion Italy strongly supports introduction of trade measures on exports of aluminium scrap as set out in the Steel and Metals Action Plan adopted in March 2025. We are in favors of a flat export fee (an export duty) on aluminium scrap (customs code HS 7602) of around 30 %. It needs to cover exports to all destinations except the European Economic Area countries.

Filed in Italian · English published by the European Commission

economiesuisse welcomes the opportunity to provide feedback on the planned trade measures to ensure sufficient availability of aluminium scrap on the EU market. economiesuisse is the umbrella federation of Swiss business. Switzerland is a highly export-oriented country and economically strongly intertwined with the EU. We are convinced that these strong economic ties are mutually beneficial.

Galloo is a leading metal recycler who has invested in state-of-the-art aluminium recycling facilities. Galloo, in line with the metal recycling industry, is completely opposed to export restrictions on aluminum scrap imposed by the European Union.

H2 Energy Systems is a Cyprus-based clean-tech company developing a continuous reactor that uses aluminium scrap to generate hydrogen on-demand for industrial energy applications. Our process co-produces alumina (AlO), a valuable industrial feedstock for European value chains, so that, with proper capture and compliant valorisation of all outputs, the pathway can operate as a closed-loop, near-zero-waste system.

Constellium is a leader in the recycling and transformation of aluminium for the packaging, automotive and aerospace markets with a large presence in Europe. Recycling is a critical element of our decarbonization trajectory as it emits up to 95% less CO2 than primary production, and affordable scrap is crucial for us as well as for the European aluminium value chain.

Recycling Europe welcomes the opportunity to provide feedback on the Call for Evidence on trade measures aimed at ensuring sufficient availability of aluminium scrap on the EU market. However, the underlying assumption that the EU is facing a structural shortage or leakage of aluminium scrap is not supported by market evidence.

Galloo is a leading metal recycler who has invested in state-of-the-art aluminium recycling facilities. Galloo, in line with the metal recycling industry, is completely opposed to export restrictions on aluminum scrap imposed by the European Union.

The company AUVERGNE ALU strongly supports an urgent EU trade measure on aluminium waste exports to address the severe shortages caused by the sharp increase in exports and distortions in third countries (export bans, subsidies, low standards in India, China, etc.), as well as by rising aluminium waste prices.

Filed in French · English published by the European Commission

Aluminium France, which represents the entire aluminium value chain in France, actively supports the European Commission’s targeted consultation on trade measures to ensure sufficient availability of aluminium waste on the European Union (EU) market.

Filed in French · English published by the European Commission

Federacciai welcomes the opportunity to contribute to this consultation on trade measures to tackle the issue of insufficient availability and affordability of strategic secondary raw materials, such as metallic scrap.

"EXCOFFIER RECYCLAGE is a Member of FEDERREC, the French Federation of Recycling, Reuse and Circular Economy Companies. As a recycler of aluminium, we are completely opposed to export restrictions on aluminum scrap imposed by the European Union.

SUEZ, as a company involved in the recycling of aluminum in Europe, welcomes the opportunity to provide feedback on the call for evidence on trade measures aimed at ensuring sufficient availability of aluminium scrap on the EU market. While sharing the objective of strengthening the European aluminium value chain, SUEZ is firmly opposed to the adoption of any restrictive measures on aluminium scrap exports.

Grupa Bobrek as secondary aluminium smelter producing alloys meeting requirements of primary alloys strongly support implementation of export duties at level of 30%. Scrap is a key element of green transformation and without improved availability of this strategic raw material there is not chance to reach ambitious targets in the coming years.

We strongly disagree with this proposal. The Spanish Federation of Recovery and Recycling (FER) is the leading association in which represents companies involved in the collection, trade, processing and recycling of different waste streams such as metals, plastics, pallets, ELV, tires, textiles. FER represents, between member companies and member associations, over 537 facilities.

Galloo is a leading metal recycler who has invested in state-of-the-art aluminium recycling facilities. Galloo, in line with the metal recycling industry, is completely opposed to export restrictions on aluminum scrap imposed by the European Union.

We welcome the Commissions call for evidence on a trade measure to ensure sufficient availability of aluminium scrap on the EU market. FACE represents independent downstream transformers consumers and end users of aluminium. The downstream constitutes 70% of the industrys turnover and 90% of its workforce.

UNESDA Soft Drinks Europe welcomes the European Commissions initiative to address the growing leakage of aluminium scrap outside the EU. Ensuring that valuable secondary raw materials remain available for European industry is essential to strengthening strategic autonomy, supporting circularity, and reducing dependence on primary aluminium.

European Aluminium welcomes and supports the European Commissions Call for Evidence on trade measures to ensure sufficient availability of aluminium scrap on the EU market. Representing the entire aluminium value chain, the association recognizes aluminium scrap as a strategic secondary raw material essential for the EUs decarbonisation objectives, circular economy, and industrial resilience, as acknowledged in the…

Metal Packaging Europe (MPE) represents the producers of rigid steel and aluminium packaging across Europe. This particular contribution relates to rigid aluminium beverage packaging. MPE supports the introduction of a differentiated export duty for scrap products classified under subheading 7602 00 90 of the EU Combined Nomenclature.

Position of the French Federation of Forges and Foundries, January 2026 Position in favour of introducing export taxes on aluminium waste at EU borders, destined for third countries. Aluminium recycling is no longer just an ecological option; it is a matter of sovereignty.

HJHansen Group welcomes the opportunity to provide feedback on the call for evidence on trade measures aimed at ensuring sufficient availability of aluminum scrap on the EU market. HJHansen Recycling Group is one of Northern Europes leading companies for the recycling of iron and metal scrap.

BIR Position on Proposed EU Trade Measures on Aluminium Scrap The Bureau of International Recycling (BIR), the global federation representing more than 1000 companies and 37 national federations across over 70 countries, welcomes the opportunity to provide feedback on the European Commissions initiative concerning trade measures to ensure sufficient availability of aluminium scrap on the EU market.

Austria’s secondary raw materials trade commented on the European Commission’s consultation on the EU aluminium sector initiative, a trade measure to ensure sufficient availability of aluminium scrap on the EU market, emphasising its central role as a key component of the European circular economy.

Filed in German · English published by the European Commission

We are against the proposal of an export tariff on aluminium scrap. The solution to the survival of the European Aluminium industry cannot be tariffs. Since USA started to threaten to/or started to impose tariffs EU has closed two large free trade deals, how does this fit with the idea of starting to impose export tariffs?

Gebrüder Gratz is definitely opposed to export bans and restrictions on aluminium scrap. Such measures would massively interfere with functioning markets and weaken the sector’s core function without actually ensuring the initiative’s stated aim.

Filed in German · English published by the European Commission

The Commissions initiative to ensure sufficient availability of aluminium scrap within the EU is fully consistent with the Unions renewed approach to economic security, industrial resilience and the effective implementation of the circular economy, in line with the objectives of the Steel and Metals Action Plan and the EU agenda to safeguard strategic inputs for the green and digital transitions.

Nicrometal S.A. (Poland) has been active in the metal recycling industry since 2000, focusing mainly on the extraction of post-production metal waste from Poland. Its history has been able to build an extensive network of trade contacts around the world, which, in various macro-economic situations, has allowed for a rapid adaptation to the current situation.

Filed in Polish · English published by the European Commission

PASSENAUD RECYCLAGE is a Member of FEDERREC, the French Federation of Recycling, Reuse and Circular Economy Companies. As a recycler of aluminium, we are completely opposed to export restrictions on aluminum scrap imposed by the European Union.

The Swedish Recycling Industries stand by the answers provided by the Confederation of Swedish Enterprise and Recycling Europe. Enclosed you may also find our position paper. The underlying assumption that the EU is facing a structural shortage or leakage of aluminium scrap is not supported by market evidence.

The Hungarian Waste Management Federation (HOSZ) is principally the industry federation of recycling companies in Hungary, with its more than 60 members representing a significant proportion of the Hungarian recycling industry (https://hosz.org/en/). HOSZ is opposed to any export duty on aluminum scrap imposed by the European Union.

The current volume of aluminium scrap exports outside the European Union is creating growing tension in the internal market. For the European secondary aluminium industry built on circular models, significant investments in recycling, and strict environmental commitments this situation results in reduced availability of material, increased volatility, and a sustained rise in prices that undermines our operational…

FACE ALU, a French company based in Perigny on Yerres (94), produces and develops aluminium solutions for the building. French and European regulations require us to reduce the carbon footprint of our products. We need to offer aluminium products with increasingly high recycled content.

Filed in French · English published by the European Commission

We would like to point out that export bans or measures having an equivalent effect on exports of aluminium scrap would be neither proportionate nor appropriate to achieve the objective stated in the consultation document.

Filed in German · English published by the European Commission

Hydro Extrusion Nenzing GmbH strongly supports introduction of trade measures on exports of aluminium scrap as set out in the Steel and Metals Action Plan adopted in March 2025. We are in favour of a flat export fee (an export duty) on aluminium scrap (customs code HS 7602) of around 30%. It needs to cover exports to all destinations except the European Economic Area countries.

Derichebourg Environnement is a member of Recycling Europe, and of several national associations representing the recycling industry accross the EU Members States, such as FEDERREC (French association), FER (Spanish association), Denuo (Belgium association) and VDM (German association).

Derichebourg Environnement is a member of Recycling Europe, and of several national associations representing the recycling industry accross the EU Members States, such as FEDERREC (French association), FER (Spanish association), Denuo (Belgium association) and VDM (German association).

Derichebourg Environnement is a member of Recycling Europe, and of several national associations representing the recycling industry accross the EU Members States, such as FEDERREC (French association), FER (Spanish association), Denuo (Belgium association) and VDM (German association).

Norsk Hydro Holland B.V strongly supports introduction of trade measures on exports of aluminium scrap as set out in the Steel and Metals Action Plan adopted in March 2025. We are in favour of a flat export fee (an export duty) on aluminium scrap (customs code HS 7602) of around 30%. It needs to cover exports to all destinations except the European Economic Area countries.

Derichebourg Environnement is a member of Recycling Europe, and of several national associations representing the recycling industry accross the EU Members States, such as FEDERREC (French association), FER (Spanish association), Denuo (Belgium association) and VDM (German association).

Arge-Shredder’s comments on the European Commission’s consultation on the initiative ‘EU aluminium sector, trade measure to ensure sufficient availability of aluminium scrap on the EU market’ are as follows: The member companies of the Arge-Shredder have an excellent knowledge of the market and the industry and are unable to identify any threat to sufficient security of supply, either now or in the future, as shown…

Filed in German · English published by the European Commission

As the legal representative of ROUMANET SAS, a European contractor in the field of joinery and aluminium facade, I would like to express my support for the introduction of fiscal and regulatory measures to regulate or even tax the import of aluminium waste outside the European Union.

Filed in French · English published by the European Commission

as per letter in pj: As the legal representative of LUC ESCHARAVIL SA, a European contractor in the field of joinery and aluminium facade, I would like to express my support for the introduction of fiscal and regulatory measures to regulate, or even tax, the import of aluminium waste outside the European Union.

Filed in French · English published by the European Commission

From our experience, sustained exports of aluminium scrap outside the EU are directly affecting our ability to operate and plan with stability. Our industrial model is recycling intensive: we produce with a clearly circular approach, supported by an eco-label certifying that our coils contain 99.5 % scrap, and we have invested significantly to expand capacities in recycling and rolling (35 M between 2022 and 2025).

Filed in Spanish · English published by the European Commission

Zeme Eco Fuels and Alloys Ltd (Cyprus) is Cyprus first specialised aluminium recycling and secondary production facility of its kind, delivering high-efficiency, low-emission recovery of secondary aluminium. Cyprus is an island Member State with a structural disadvantage: it has no domestic aluminium recycling chain at all.

Myne Circular Metals supports building a strong European circular aluminium industry through innovation and fair competition, and believes that well-designed trade measures, alongside investment incentives, are needed to restore a level playing field and support European upgrading capacity, innovative recyclers and long-term resource resilience. Please find attached more details.

PRAXY CENTRE is a Member of FEDERREC, the French Federation of Recycling, Reuse and Circular Economy Companies. As a recycler of aluminium, we are completely opposed to export restrictions on aluminum scrap imposed by the European Union.

Hydro Extrusion Spain S.A.U strongly supports introduction of trade measures on exports of aluminium scrap as set out in the Steel and Metals Action Plan adopted in March 2025. We are in favour of a flat export fee (an export duty) on aluminium scrap (customs code HS 7602) of around 30%. It needs to cover exports to all destinations except the European Economic Area countries.

CORNEC SAS is a Member of FEDERREC, the French Federation of Recycling, Reuse and Circular Economy Companies. As a recycler of aluminium, we are completely opposed to export restrictions on aluminum scrap imposed by the European Union.

ELECTRO RECYCLING is a Member of FEDERREC, the French Federation of Recycling, Reuse and Circular Economy Companies. As a recycler of aluminium, we are completely opposed to export restrictions on aluminum scrap imposed by the European Union.

Celsa Group welcomes the European Commissions initiative to address the availability of scrap within the European Union. Although this consultation specifically focuses on aluminium scrap, the challenges and opportunities it addresses are highly relevant across all scrap categories, including ferrous scrap.

Norsk Hydro ASA strongly supports introduction of trade measures on exports of aluminium scrap as set out in the Steel and Metals Action Plan adopted in March 2025. For a detailed position, please see the document attached. In summary, we are in favour of a flat export fee (an export duty) on aluminium scrap (customs code HS 7602) of around 30%.

EXTRUSIÓN DE SAX S.L., strongly supports an urgent EU trade measure on aluminium scrap exports to address severe shortages driven by surging exports and third-country distortions (export bans, subsidies, low standards in India, China, etc.), together with rising prices of aluminium scrap.

BEFESA Salzschlacke GmbH, a leading company in the recycling of aluminium waste for almost 40 years, supports possible actions by the European Commission to increase the availability of scrap in the European market. Aluminium is an essential raw material for decarbonisation.

Filed in Spanish · English published by the European Commission

ZEME Eco Fuels & Alloys Ltd strongly supports the EUs rapid introduction of effective trade measures to curb aluminium scrap leakage, in line with the direction set by the European Steel and Metals Action Plan and the Commissions ongoing preparatory work on an EU instrument for aluminium scrap.

BEFESA Aluminio, S.L., a leading company in the recycling of aluminium waste and production of secondary aluminium alloys for 70 years, supports the actions that the European Commission may take to increase the availability of scrap in the European market. Aluminium is an essential raw material for decarbonisation.

Filed in Spanish · English published by the European Commission

Hydro Extrusion Hungary Kft strongly supports introduction of trade measures on exports of aluminium scrap as set out in the Steel and Metals Action Plan adopted in March 2025. We are in favor of a flat export fee (an export duty) on aluminium scrap (customs code HS 7602) of around 30%. It needs to cover exports to all destinations except the European Economic Area countries.

Hydro Aluminium Extrusion Portugal, HAEP; Strongly supports introduction of trade measures on exports of aluminium scrap as set out in the Steel and Metals Action Plan adopted in March 2025. We are in favour of a flat export fee (an export duty) on aluminium scrap (customs code HS 7602) of around 30%. It needs to cover exports to all destinations except the European Economic Area countries.

Hydro Building Systems Spain SLU; strongly supports introduction of trade measures on exports of aluminium scrap as set out in the Steel and Metals Action Plan adopted in March 2025. We are in favour of a flat export fee (an export duty) on aluminium scrap (customs code HS 7602) of around 30%. It needs to cover exports to all destinations except the European Economic Area countries.

The SNFA is the organisation representing the aluminium construction industry in France. The ambitious regulatory environment for buildings in France calls for more and more recycled content to be incorporated into products and for an ever lower carbon footprint.

Filed in French · English published by the European Commission

The Confederation of Swedish Enterprise is sceptical of export restrictions as a trade policy tool and emphasises that open markets and free trade are essential for Europes competitiveness, resilience and long-term industrial strength. The proposed restrictions on aluminium scrap represent a significant departure from established EU trade principles and risk undermining integrated global value chains.

Hydro Extrusion Sweden AB strongly supports introduction of trade measures on exports of aluminium scrap as set out in the Steel and Metals Action Plan adopted in March 2025. We are in favour of a flat export fee (an export duty) on aluminium scrap (customs code HS 7602) of around 30%. It needs to cover exports to all destinations except the European Economic Area countries.

The Assiral Association of Italian Refiners has, for many years, strongly called for the introduction of an export duty on scrap to non-EU countries. This measure has now become absolutely imperative, as export volumes are increasing at a rapid pace. The most effective solution would be the adoption of an erga omnes export duty of 30% or higher.

To Whom It May Concern, Turkish aluminium industry is highly integrated with Europe. Being under the same Customs Union, as well as other bilateral and multilateral agreements, Türkiye and the European Union have largely harmonized regulations governing aluminium industry.

Eurometal S.A. supports the implementation of restrictions on the export of aluminium scrap outside the European Union. As a vertically integrated European aluminium manufacturer, we emphasize that aluminium scrap constitutes a critical raw material for achieving our decarbonization objectives and for the production of low-carbon aluminium products.

The Swedish Federation of Wood and Furniture Industry (TMF) expresses concerns regarding the use of export restrictions on aluminium scrap as a trade policy instrument. The wood, furniture and building component industries are downstream users of aluminium, while at the same time supplying significant volumes of high-quality production scrap back into recycling and remelting value chains.

Raffmetal, Europes leading producer of recycled aluminium alloys, urgently supports the initiative of the European Commission (Ares(2025)11437867) aimed at addressing the crisis in the availability of aluminium scrap.

To whom it may concern, Türkiyes aluminium sector is highly integrated with Europe. Under the Customs Union, as well as other bilateral and multilateral agreements, Türkiye and the European Union have largely harmonized regulations governing aluminium recycling.

Hydro Holding Offenburg GmbH strongly supports introduction of trade measures on exports of aluminium scrap as set out in the Steel and Metals Action Plan adopted in March 2025. We are in favour of a flat export fee (an export duty) on aluminium scrap (customs code HS 7602) of around 30%. It needs to cover exports to all destinations except the European Economic Area countries.

Strongly supports introduction of trade measures on exports of aluminium scrap as set out in the Steel and Metals Action Plan adopted in March 2025. We are in favour of a flat export fee (an export duty) on aluminium scrap (customs code HS 7602) of around 30%. It needs to cover exports to all destinations except the European Economic Area countries.

Turkish Steel Producers Association_EU Aluminum Scrap Measure - Evaluation of the Public Consultation Process and Steel Scrap Opinion Statement This submission assesses the European Commissions public consultation on potential trade measures concerning aluminium scrap and examines the broader implications for scrap-dependent sectors, particularly steel.

Aluminium Denmark wishes to thank the European Commission for the opportunity to provide input regarding the consultation on possible EU trade measures for exports of aluminium scrap, with the aim of ensuring adequate availability on the EU internal market.

ISR Recycling GmbH & Co.KG is explicitly committed to free and open international trade. Additional export restrictions do not protect economies – they weaken them in a sustainable way. In the aluminium sector, such measures lead to significant price increases for aluminium products and endanger jobs along the entire value chain.

Filed in German · English published by the European Commission

Forest Metal GmbH is a circular metal economy company operating in Germany. We support the European Commission’s objective to strengthen the security of supply and competitiveness of the European aluminium industry. From a technical and market-economic point of view, blanket export restrictions on aluminium scrap are not an appropriate policy instrument.

Filed in German · English published by the European Commission

Curef GmbH is a medium-sized recycling company with two sites in Germany and specialising in the processing of aluminium scrap. As part of the European circular economy, we strongly support the objective of strengthening aluminium production and security of supply in Europe. At the same time, we consider blanket export restrictions on aluminium scrap to be politically and economically flawed.

Filed in German · English published by the European Commission

Our company is of the oppinion that keeping scrap in Europe is vital for our industry to remain competitive. We have over the recent years seen a significant outflow of scrap at very high prices to comapnies in Asia. This effectively eliminate european companies to deliver sustainble offerings to clients as our clients is preferring alumnium products from recycled material.

I strongly supports the introduction of trade measures on exports of aluminium scrap as set out in the Steel and Metals Action Plan adopted in March 2025. We are in favour of a flat export fee (an export duty) on aluminium scrap (customs code HS 7602) of around 30%. It needs to cover exports to all destinations except the European Economic Area countries.

Hydro Aluminium Iberia SAU, strongly supports introduction of trade measures on exports of aluminium scrap as set out in the Steel and Metals Action Plan adopted in March 2025. We are in favour of a flat export fee (an export duty) on aluminium scrap (customs code HS 7602) of around 30%. It needs to cover exports to all destinations except the European Economic Area countries.

We strongly support introduction of trade measures on exports of aluminium scrap as set out in the Steel and Metals Action Plan adopted in March 2025. The level of exported scrap volumes are so high, and prices so detached to the European market- that without any action green deal may not really happen in aluminium industry in Europe.

Export restrictions on aluminium weaken free trade, make products more expensive and threaten jobs along the entire value chain. They distort the market, reduce industrial competitiveness and lead to long-term supply shortages rather than stability. Sustainable and resilient supply chains are created by cooperation and open markets, not by foreclosure.

Filed in German · English published by the European Commission

AEA strongly supports an urgent EU trade measure on aluminium scrap exports to address severe shortages driven by surging exports and third-country distortions (export bans, subsidies, low standards in India, China, etc.), together with rising prices of aluminium scrap.

Arctial is a Finnish company currently conducting a feasibility study for a low carbon aluminium manufacturing facility in Kokkola, Finland. The initiative is financed by ABB, Fortum, Mitsubishi Corporation, Rio Tinto, Siemens Financial Services, Tesi, and Vargas. The planned primary aluminium production capacity exceeds 600,000 tpa, with an additional maximum of 10% processed as secondary aluminium.

metal.suisse recognises the problems associated with a shortage of aluminium scrap and the resulting increase in its price. Swiss aluminium producers are facing similar challenges. metal.suisse therefore understands the need for action on the part of the European Union.

Export restrictions on aluminum scrap would not strengthen the European aluminum sector but rather undermine well-functioning recycling and raw material markets. There is no structural shortage of aluminum scrap in the EU; current surpluses are primarily the result of weak downstream demand and insufficient processing capacity.

JBM Recycling AB strongly opposes any trade measures that restrict exports of aluminium scrap. Export is a vital safety valve when European Smelters cannot absorb available volumes. Limiting exports would Distor the market, reduce competition, accelerate consolidation and weaken price transparency and may even reduce recycling.

Filed in Swedish · English published by the European Commission

In the current VUCA environment of the aluminium market, scrap that can, in theory, replace primary aluminium ingots remains the best alternative. However, in today's European market, it is becoming increasingly difficult to source scrap, especially at competitive prices. Non-European manufacturing groups are taking advantage of European producers' access to this material, that adds further pressure on supply.

It goes without saying that, as a privately run metal recycling company mainly based in Europe with more than 5 branches, our ambition is primarily to support the European aluminium industry, if market conditions allow.

Filed in German · English published by the European Commission

Branchehuset is and will remain strong advocates for global free trade, but we recognise that there may be good arguments in favor of introducing an export duty on aluminium scrap to support the green transition of European companies and contribute to self-sufficient, independent European value chains of critical raw materials in light of the current global situation.

Recycling associations estimate that there is sufficient aluminium scrap available on the European market. The current economic situation of aluminium producers cannot therefore be primarily explained by a shortage of scrap or by excessive scrap prices. Rather, the root causes lie in the structural locational disadvantages of the EU.

Filed in German · English published by the European Commission

We are a scrap processing company and oppose the planned measure for tariffs or quotas for the export of aluminum scrap. There are many low quality grades that can not be processed in Europe and will end up dumped somewhere to damage the environment. Other aluminum grades, which are painted / lacquered are also not in high demand by European secondary smelters due to their higher pollution and processing cost.

Open markets are a prerequisite for securing raw materials and ensuring the functioning of aluminium recycling in Europe. The European recycling industry continuously supplies high-quality secondary raw materials. At the same time, many aluminium plants are already subject to capacity limits.

Filed in German · English published by the European Commission

Cannot see that the European aluminium industry has the capacity to handle the volume and some of the waste grades generated within Europe. Making exports more difficult will only reduce recycling and thus the green transition. The green transition is not a European unique concern globally. The EU must look at the whole, not just at an industry that restricts competition to their advantage.

Filed in Swedish · English published by the European Commission

This is an idiotic and Communistic proposal that damage the open market and flow of recycling material. Anybody with the slightest knowledge of the recycling market knows that higher prices equal more recycling. Taking away export means less demand and lower prices and less material availiable for recycling. This will hurt the industry and investment into recyling facilities and processes.

Chilanga AB strongly opposes any trade measures that restrict exports of aluminium scrap. Export restrictions would seriously distort the market and undermine the recycling industrys ability to operate efficiently. When European smelters cannot absorb available volumes, export is not an option it is a necessity.

Svenska Järn strongly opposes any trade measures that restrict exports of aluminium scrap. Export is a vital safety valve when European smelters cannot absorb available volumes. Limiting exports would distort the market, reduce competition, accelerate consolidation and weaken price transparency and may even reduce recycling.

As the legal representative of SOREMO, a European industrial player in the second smelting of aluminium from waste and used engine blocks, I would like to express my support for the introduction of fiscal and regulatory measures to regulate, or even tax, the import of aluminium waste outside the European Union. The European sector of the second merger is currently in a structurally unbalanced situation.

Filed in French · English published by the European Commission

In our view, a fundamental shortcoming of the current consultation is that one-size-fits-all regulatory approaches are discussed without sufficiently differentiating the different qualities, origins and market mechanisms of aluminium scrap. Such undifferentiated regulation poses significant risks to a functioning market economy. 1. It is essential to differentiate between aluminium scrap and aluminium scrap.

Filed in German · English published by the European Commission

The Gremi de Recuperació de Catalunya represents 345 member companies operating across the recycling and recovery sector in Catalonia. A significant majority of our members are small and micro-sized enterprises, deeply rooted in local economies and highly exposed to market distortions. This position gives us both the responsibility and the legitimacy to express serious concerns about the proposed measures.

At first sight, export restrictions on aluminium scrap sound like more raw materials for Europe in terms of industrial policy. In practice, however, they would damage functioning recycling markets, slow down investments and ultimately jeopardise climate and location objectives. First, according to the recycling associations, there is no structural shortage of scrap in the EU.

Filed in German · English published by the European Commission

As a long-standing market player in the European non-ferrous metal and aluminium recycling sector, I warmly welcome the European Commission’s aim to strengthen the circular economy, improve security of supply and sustainably safeguard the competitiveness of the EU aluminium sector. Aluminium is undoubtedly a key raw material for Europe’s green and digital transformation.

Filed in German · English published by the European Commission

The European Commission’s current reflections on trade policy measures, including possible export restrictions, export fees or additional regulatory requirements for aluminium scrap, have far-reaching implications for companies at all levels of the industry.

Filed in German · English published by the European Commission

Current market developments demonstrate the need for targeted Union action to ensure that aluminium scrap remains available at competitive prices for the European industry. To this end, the Commission should be encouraged to prioritise an export duty on scrap as the most effective response.

Filed in Italian · English published by the European Commission

There is a functioning world market for aluminium scrap. There is no shortage of raw material scrap for the aluminium smelters in Europe. The problem of aluminium smelters is mainly the excessive cost of electricity, which drives up the cost of production when smelting.

Filed in German · English published by the European Commission

Open markets are a prerequisite for the functioning of the European circular economy. On the contrary, export restrictions or tariffs on secondary raw materials such as aluminium scrap would not contribute to security of supply: They would hamper recycling processes, create significant difficulties for companies in the circular economy and ultimately weaken climate protection.

Filed in German · English published by the European Commission

Aluminium recycling is a strategic part of European industry and the energy transition. Security of supply for European works is a legitimate objective. However, this objective is not achieved through export restrictions, but through functioning markets along the entire value chain.

Filed in German · English published by the European Commission

These days we are talking about a systemic transformation from a linear economy to a circular economy. On the other hand, applications such as digital twins, artificial intelligence, and machine learning provide significant support for this transformation. Because within this change, both recycling processes need to play a greater role and the recycling processes themselves need to transform.

Scrap is the first factor in reducing CO2, and a key factor in reducing consumption and energy costs in refining melting processes. It is one of the few resources/inputs available to Europe, among other things, in ever smaller quantities, given the reduction in industrial production.

Filed in Italian · English published by the European Commission

Scrap is a raw material that has multiple advantages: — its use results in low CO2 emissions; — its use reduces the depletion of the planet’s resources by extracting less; — its use reduces energy consumption (specifically aluminium only serves 5 % of energy compared to the production of new mineral aluminium); — its use is a key link in the circular economy; In addition, Europe has few raw materials (concentrated…

Filed in Italian · English published by the European Commission

We are not mistaken: here we are talking about protectionism and creating captive markets to favour companies that are not competitive. Rising energy costs and labour costs are also borne by waste managers and we have the right to have access to global markets to sell our products.

Filed in Spanish · English published by the European Commission

To understand if it’s important to have scraps metals in Europe, do we need to consult anyone? The answer is obvious! Scraps metals are strategic, environmentally friendly and economical source of raw materials. If we want to safeguard European industry, we must allow it to supply itself reliably, in abundant quantities and at competitive prices.

Filed in Italian · English published by the European Commission

We shall not expose scrap for the following reasons: - aluminum scrap is a source of infinite recycled aluminium - Europe is not rich in bauxite mining sites - import through CBAM will be a double wham - most important: aluminium is the result of an energy intensive process, exporting scrap is the same as exporting energy

Aluminium scrap is the strategic and critical material of a whole supply chain that is currently severely attacked by countries outside Europe that have very low energy costs and no control over CO2 emissions. If we want the aluminium component production chain for both the automotive sector and other sectors such as defence to succeed and be competitive and decarbonised, we need to support the recycling of scrap on…

Filed in Italian · English published by the European Commission