Under the new rules, non-OECD countries must submit a request by 21 February 2025 to be able to continue importing recycled materials classifed as waste from the EU (Annex VIII - WSR). If no request is submitted by that deadline, a blanket ban on EU exports of recycled materials to those nearly 150 countries will take effect by 21 May 2027.

Despite EuRIC’s continuous efforts to ensure compliance, EuRIC warns that, based on its experience, most non-OECD countries are simply not ready yet to meet the EU’s new, complex procedures. These involve huge data sets and numerous questions, creating an overwhelming burden on non-OECD countries’ administrations. Furthermore, outreach from European authorities to non-OECD countries seems to have been largely insufficient, leaving these countries uninformed on the new WSR rules’ economic impact on global trade and the supply of recycled materials. This lack of clarity and preparedness threatens to disrupt existing business relationships and damage the functioning of recycling markets. A collapse of outlet markets would also artificially shrink the EU recycling industry, result in the landfilling of recyclable waste, and lead to the loss of trust in waste sorting among EU citizens.

To safeguard the competitiveness of the EU recycling industry, EuRIC calls on the European Commission to urgently implement the following 5 critical measures to faciliate a realistic, workable, and business-friendly transition to the new rules:

1. Implement the 21 February 2025 deadline in a flexible manner or extend it by at least 6 months.

2. Postpone the application of 2027 export rules, to allow businesses enough time to adapt without crippling supply chains.

3. Actively engage with third countries to secure outlet markets and the competitiveness of the European recycling industry.

4. Ensure transparency on the status of feedback from non-OECD countries, including creating, publishing and keeping up-to-date a list of those countries that submitted a request according to Annex VIII of the WSR.

5. Promote a continuous dialogue with third countries to early identify and address potential trade barriers.

Time is of the essence to avoid the collapse of international trade in recycled materials and ensure that European recycling companies have stable market outlets.

EuRIC therefore urges the European Commission and EU legislator to take immediate action to extend the WSR deadlines and allow EU recyclers and their customers worldwide sufficient time to adjust to the new rules. A flexible and smooth transition is urgently needed to ensure international trade in recycled materials, and to protect the competitiveness of the European recycling industry.