The concerns raised by the Material Recycling Association of India (MRAI) over the European Union’s proposed restriction on exports of ferrous and non-ferrous metal scrap to India are increasingly finding resonance across the global recycling industry, with international recycling forums and industry bodies pressing for policies that preserve the free and predictable movement of recyclable materials across borders.
The issue has assumed wider significance as recycling organisations across geographies highlight the implications of restricting established scrap markets at a time when recycled metals are increasingly being recognised as strategic secondary raw materials. The Bureau of International Recycling (BIR), among the global industry bodies representing recyclers, has been raising concerns over the impact of changing EU trade and waste-shipment policies on international material flows and has emphasised the importance of open, well-functioning markets for recycling investment and global circularity.
The international recycling community’s concerns broadly mirror the position taken by MRAI: that recyclable material should be allowed to move from regions where it is generated in surplus to markets where adequate recycling capacity and industrial demand exist. Industry discussions globally have also focused on the possibility that tighter restrictions could disrupt established markets, reduce outlets for recyclables and affect the economics of collection and recycling.
The European Commission, on September 18, published its draft list of non-OECD countries authorised to receive certain non-hazardous waste from the EU under the Waste Shipment Regulation (EU) 2024/1157. While India has been proposed for several waste streams, ferrous and non-ferrous metal scrap have not been authorised in the draft. If the exclusion is retained in the final list, EU exports of these materials to India could effectively be discontinued from May 21, 2027.
Sanjay Mehta, President, Material Recycling Association of India (MRAI), said, “The fact that recycling organisations and industry forums across the world are raising similar concerns demonstrates that this is not merely an India-specific issue. The movement of recyclable materials is an integral part of the global circular economy. When a material is generated in one geography and there is established, environmentally compliant recycling capacity in another, restricting its movement can undermine the very objectives of resource efficiency and circularity. India has invested substantially in modern recycling infrastructure and has a regulatory framework governing environmental compliance. We therefore believe that policies governing scrap trade should facilitate responsible recycling rather than fragment established global supply chains. MRAI’s concerns are being echoed by the international recycling community because the implications extend well beyond one country or one commodity.”
India’s concerns stem from the country’s structural dependence on imported scrap. MRAI’s representation to the Ministry of Environment, Forest and Climate Change notes that India’s domestic generation of end-of-life metal scrap is insufficient to meet the requirements of its recycling industry because of historically lower per-capita consumption of metals compared with mature economies. Europe, by contrast, has accumulated significantly larger stocks of end-of-life products following decades of industrialisation and consumption.
The EU is a significant source of this secondary raw material. During FY 2025-26, India imported approximately 2.03 million tonnes of aluminium scrap, 0.47 million tonnes of copper and copper-alloy scrap, 0.21 million tonnes of lead scrap and 0.11 million tonnes of zinc scrap. The EU accounted for around 20% of aluminium scrap imports, 22% of copper and copper-alloy scrap imports, 20% of lead scrap imports and 40% of zinc scrap imports. India also imported approximately 8.45 million tonnes of ferrous and stainless-steel scrap, including around 0.79 million tonnes from the EU.
Dhawal Shah, Senior Vice President, MRAI, said, “India imports about 23% of its end-of-life metallic scrap requirements from EU countries, while our domestic generation is still insufficient to meet the requirements of the recycling industry. This is fundamentally different from mature economies such as those in Europe, where the availability of end-of-life scrap is substantially higher. Metal scrap is not merely waste being sent to India for disposal. It is an essential secondary raw material that is recycled and subsequently used by major sectors such as automobiles, construction, power, batteries and HVAC.”
Shah added that the proposed restrictions could affect an already scrap-deficit Indian recycling industry. “Free movement of recyclable materials is fundamental to an efficient global circular economy. If established flows are restricted, recyclers may have to turn increasingly towards virgin resources, which would be contrary to the environmental objectives that recycling policies are intended to achieve,” he said.
MRAI’s representation points out that recycling metal provides significant environmental benefits by reducing dependence on virgin ore extraction, conserving natural resources, lowering energy consumption and reducing greenhouse-gas emissions. It cites International Aluminium Institute data that recycled aluminium requires approximately 95% less energy than primary aluminium production. It also cites World Steel Association data showing substantially lower CO₂ intensity for scrap-based electric-arc-furnace steelmaking compared with the BF-BOF route.
The association has also maintained that India already has an established regulatory framework for environmentally sound metal recycling. Recycling facilities are required to obtain applicable environmental approvals and comply with requirements covering emissions, effluent treatment, storage, hazardous waste, handling and disposal of process residues. MRAI has pointed out that India also has organised recycling facilities equipped with modern sorting, shredding, melting, refining, pollution-control and material-recovery technologies.
The issue has meanwhile received growing attention in global and Indian business media, with coverage focusing on the possible disruption to India’s scrap-dependent manufacturing and recycling ecosystem, the implications for MSMEs and the broader impact on international secondary-raw-material supply chains. The international debate has also increasingly centred on whether restrictions on scrap movements could inadvertently weaken the global circular economy rather than strengthen it.
MRAI has already taken up the matter with the Ministries of Environment, Forest and Climate Change, Mines and Steel and is seeking intervention through the Commerce Ministry. The association has urged the Government of India to engage with the European Commission and seek inclusion of ferrous and non-ferrous metal scrap in the final list of materials authorised for export to India.
MRAI has also sought that the matter be examined in the context of the India-EU Free Trade Agreement, arguing that recyclable metallic raw materials should have stable and predictable market access. It has pointed out that broader trade liberalisation would be difficult to reconcile with regulatory restrictions that effectively prevent the movement of essential secondary raw materials.
The association said it will continue engaging with Indian policymakers as well as international recycling forums to press for a globally coordinated approach that combines environmental safeguards with uninterrupted access to legitimate secondary raw materials.
“India is not seeking unrestricted movement of waste. We are seeking a fair and environmentally responsible system for the movement of recyclable materials to authorised recycling facilities. That principle is increasingly being discussed across the global recycling community, and India must ensure that its interests as a major recycling and manufacturing economy are adequately represented,” Mr Shah said.
