To strengthen the EU’s circular economy and industrial resilience, robust measures are needed to retain high-value scrap within Europe and curb environmentally harmful recycling practices abroad. Circularity not only boosts innovation and sustainability but also reduces dependence on volatile global supply chains.

Simplifying the Carbon Border Adjustment Mechanism (CBAM) for finished and semi-finished products is crucial to reduce the administrative burden on small and medium-sized enterprises (SMEs). Additionally, expanding the scope of CBAM is essential to prevent circumvention by importing finished metal products. Trade defence measures on steel and aluminium should ensure protection for the entire metal value chain, including downstream products, to prevent circumvention of these measures and support competitiveness.

European trade policies should reward high-quality recycling and closed material loops for permanent materials like aluminium and steel, which can be recycled repeatedly without losing their inherent properties. Future measures must address the entire value chain, including downstream metal packaging products. We are ready to support the Commission and offer proposals to achieve these goals.