Background

Critical raw materials are becoming scarcer. Export restrictions increasingly appeal to many countries, with the Organisation for Economic Co-operation and Development (OECD) reporting a fivefold increase in such measures since 2009. Between 2022 and 2024, approximately 70 percent of global exports of cobalt and manganese faced export limitations. While nations such as China and India predominantly impose these measures, emerging markets like Argentina, Vietnam, and Burundi have also embraced them. The United States introduced restrictions on batteries and other scrap materials in August 2026.

In recent years, the EU shifted from being a net importer to a net exporter of scrap metal, fuelling debates within Brussels about introducing restrictions. The goals include enhancing recycling capacity, fortifying the circular economy, and ensuring a stable raw material supply for European industries. Export restrictions doubly impact Germany's economy: as an importer of critical raw materials and a potential exporter of secondary materials to markets outside Europe.

FAQ

Why does the economy fundamentally oppose scrap export restrictions?

Export restrictions might seem a straightforward way to retain secondary raw materials. However, they often provoke retaliation by trade partners via counter-tariffs or their export bans, resulting in a double burden for Germany’s economy, affecting both the import of critical raw materials and the export of finished goods.

What is the EU Commission planning specifically?

The European Commission expects to propose export duties on aluminium and copper scrap in autumn 2026, resulting from the EU’s transition from net importer to net exporter of scrap metals. Whether similar measures will follow for other materials such as battery-recycling waste remains unclear.

Under what conditions would export restrictions be acceptable?

The German Chamber of Commerce and Industry acknowledges some targeted measures under exceptional cases are acceptable when structural market distortions exist or strategically significant material streams are heavily exported, threatening European value chains. Temporary tariffs or quotas are preferable over outright bans. This requires impact assessments, business involvement, and regular evaluation clauses.

How will the EU’s plans affect medium-sized recycling companies?

The proposed ban might particularly harm medium-sized recyclers if European industries cannot quickly absorb the affected materials. Scrap that cannot be exported may require storing, tying up capital and jeopardising the viability of recycling chains.

What does the German Chamber of Commerce and Industry propose instead of export restrictions?

The German Chamber advocates for positive incentives, including faster recycling facility approvals, reducing bureaucratic barriers for secondary material classifications, boosting research funding along the value chain, and utilising trade agreements to counter discriminatory export restrictions imposed by third countries. Europe’s framework conditions should promote recycling rather than isolation.

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