EU Drops Aluminium Scrap Duty, Leaving €130M Plant Without Feedstock

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The European Commission has dropped a proposed 15% export duty on aluminium scrap and replaced it with a waste regulation that Europe’s own recyclers say will not do the job. The consequence is not theoretical: investment capital at one of the continent’s largest aluminium producers is now sitting in limbo while the policy architecture gets rewritten.

Over 1.25 million tonnes of aluminium scrap left Europe in 2024, a 51% rise since 2019, and the window to redirect that feedstock into domestic recycling infrastructure is closing as the November 2026 finalisation of the revised Waste Shipment Regulation approaches. Constellium’s Neuf-Brisach recycling centre, a €130 million facility opened in September 2024, shows exactly what domestic capacity looks like, and exactly what stalls if scrap cannot be secured.

Here is what the policy shift actually changes, why the replacement mechanism is contested by the industry it is meant to protect, and which capital decisions now hang on the outcome. The distinction between a price signal and an administrative ban sits at the centre of it.

What the Commission abandoned, and what it put in its place

In September 2026, the European Commission formally withdrew its proposed 15% export duty on aluminium scrap. The stated reason was trade diplomacy: the duty risked complicating the signing of a free trade agreement with India.

The Commission’s September 2026 reversal did not emerge in isolation: EU aluminium scrap export policy has been contested terrain since 2023, with multiple draft instruments proposed, assessed, and modified as the Commission weighed trade diplomacy against recycling industry objectives.

The Commission did not walk away from the objective. It put the trade measure “on hold” on the grounds that the same goals could be met through the revised Waste Shipment Regulation (WSR) instead.

The revised Waste Shipment Regulation, Regulation (EU) 2024/1157, establishes the legal framework governing cross-border waste movements including the non-OECD export ban and the country-level exemptions process that will determine scrap availability inside Europe from May 2027.

Here is the mechanism that replaces the duty. From 21 May 2027, the WSR will ban exports of non-hazardous waste, including aluminium scrap, to non-OECD countries. Destinations can escape the ban if they demonstrate they manage the material to standards equivalent to EU environmental rules, granted through a case-by-case exemptions process.

That structural difference matters more than it first appears. A duty changes export economics directly for every shipment, everywhere. A shipment ban works through administrative classification and country-level exemptions, and 32 non-OECD countries have already applied for those exemptions, according to Reuters.

For anyone tracking EU green metals policy, that is the pivot to understand before weighing the industry’s reaction. One instrument raises the cost of exporting scrap. The other decides, country by country, whether the door stays open. The question of which mechanism keeps scrap in Europe sits directly upstream of where recycling investment capital flows next.

Why industry says the new approach will not work

The Federation of Aluminium Consumers in Europe (FACE) and Recycling Europe have laid out four objections to relying on the WSR alone. Read in sequence, they build from a simple gap to a much harder enforcement problem.

Recycling Europe’s position, set out in its February 2026 submission to the Commission, frames the problem plainly: this is a matter that requires a trade measure to ensure sufficient domestic scrap availability, not a waste regulation retrofitted to do the work of one.

The FACE position on aluminium scrap export restrictions, published in September 2026, frames the Commission’s pivot from a trade instrument to a waste regulation as a category error: the problem of feedstock retention requires a price signal that only a trade measure can provide, not an administrative classification process.

The critique is not lobbying noise. It identifies specific legal and economic gaps that, if they hold, mean scrap keeps leaving Europe after May 2027. That is precisely the scenario a major producer is now pricing into its capital decisions.

That producer is Constellium, and its chief executive has said so publicly.

When named industry bodies and the CEO of one of Europe’s largest aluminium producers reach the same conclusion, the signal is that the replacement framework is genuinely contested, not merely unpopular. For anyone assessing the durability of Europe’s green metals policy, that distinction is material.

Constellium’s investment calculus and what scrap access means for EU recycling capacity

To understand what is at stake, start with what already exists. Constellium’s Neuf-Brisach recycling centre is the concrete benchmark for what domestic capacity costs and delivers.

That is the baseline. It proves the model works and puts a hard number on it: €130 million buys 130,000 tonnes of recycling capacity. The forward question is whether the next round of similar spending happens at all.

What comes next: the projects at risk

Constellium is currently evaluating multiple further recycling projects spanning its packaging, automotive, and aerospace segments. Joerg has said these could be larger or smaller than Neuf-Brisach, but as of 22 September 2026, none have confirmed euro figures or timelines.

The reason is direct. Scrap feedstock availability, not market demand or decarbonisation targets, is the binding input to the investment decision. Constellium has said its EU recycling expansion is at risk of suspension if sufficient domestic scrap cannot be secured.

Constellium sources scrap both internally and from external suppliers, which means it is exposed to market-wide shortages, not just its own processing constraints. If exports keep draining feedstock, the company’s own plants risk under-utilisation.

That is the signal worth noting. One of Europe’s largest aluminium producers is treating scrap access as the constraint on its next wave of capital expenditure. That tells you something specific about where the real bottleneck in the circular economy sits: not in demand, not in technology, but in feedstock the WSR may or may not keep at home.

For readers wanting to understand the full landscape of structural barriers facing EU recyclers, our full explainer on Europe’s aluminium recycling challenges covers collection infrastructure gaps, alloy contamination issues, and how CBAM interacts with scrap availability across packaging, automotive, and aerospace end markets.

What the scrap data reveals, and what to watch before May 2027

The scale of the outflow is what makes the policy fight urgent. EU aluminium scrap exports reached 1,257 kilotonnes in 2024, and more than 600,000 tonnes left in the first half of 2025 alone, according to AluReport. India, Thailand, and China are the primary destinations.

The 51% export rise between 2019 and 2024 is the most visible symptom of a structural aluminium recycling supply gap that predates the policy debate, driven by collection fragmentation, alloy contamination in mixed post-consumer streams, and a price differential that has consistently favoured export over domestic processing.

There is a pointed irony in the destination data. India, the country whose FTA concerns prompted the Commission to drop the duty, will be barred from importing EU metal waste under the WSR from May 2027, per Reuters (18 September 2026). Trade policy and environmental policy are pulling in opposite directions, and the tension is unresolved.

The downstream consequences fall into three areas if the WSR proves as porous as industry fears:

Taken together, the 51% export rise, the policy reversal, and Constellium’s suspended decisions point to a single reading: Europe is losing the feedstock faster than it is building the capacity to justify retaining it.

The next twelve months will settle whether the framework holds. Three variables are the ones to track.

1. The exemptions list. How many of the 32 non-OECD applicants are approved, and on what terms. The consultation closed 16 October 2026; the outcome sits inside the November finalisation.
2. The OECD loophole. Whether flows to OECD destinations, Turkey in particular, are addressed through supplementary measures, or left open.
3. Constellium’s final investment decisions. Whether its evaluation-stage projects proceed will function as a market-based verdict on whether the WSR is working. Delivered on a roughly 12-month horizon.

FACE and Recycling Europe have not abandoned their case for a trade instrument, which leaves the door open for political pressure to revive an export duty if the WSR falters in its first operational year.

The regulatory architecture is still being assembled. The industry opposition is organised and on the record. The capital that will measure success or failure remains uncommitted. Investors and supply chain planners with exposure to EU aluminium should treat this as an active, unresolved risk, not a settled development, and watch these three variables rather than wait for a verdict.

This article is for informational purposes only and should not be considered financial advice. Investors should conduct their own research and consult with financial professionals before making investment decisions.

Forward-looking statements regarding regulatory outcomes and investment decisions are speculative and subject to change based on policy developments and company performance.