Targeted consultation: EU measure for aluminium scrap – questionnaire for stakeholders

The Confederation of Swedish Enterprise is sceptical of export restrictions as a trade policy tool and emphasises that open markets and free trade are essential for Europe’s competitiveness, resilience and long-term industrial strength. The proposed restrictions on aluminium scrap represent a significant departure from established EU trade principles and risk undermining integrated global value chains. Introducing such measures would weaken the EU’s credibility as a proponent of rules-based trade and expose European industry to retaliation.

There is a substantial risk that export restrictions would set an undesirable precedent and contribute to broader policy proliferation, market fragmentation and regulatory uncertainty. This concern is reinforced by the global surge in export controls on critical raw materials since 2020, with an increasing focus on processed materials and intermediates. Further EU restrictions would add to this trend and increase risks for downstream industries already facing high costs and intense competition.

From a circular economy perspective, efficient recycling depends on open international markets, and trade restrictions risk reducing recycling efficiency and increasing system-wide costs. Any impact assessment must clearly demonstrate that export restrictions would in practice increase aluminium scrap availability in the EU, as this causal link cannot be assumed. The analysis must also account for risks of circumvention and illegal exports, including of end-of-life vehicles.

The assessment should evaluate effects across the entire aluminium value chain and ensure full compatibility with WTO rules and free trade agreements. While acknowledging the exceptional geopolitical context, Swedish Enterprise stresses that trade restrictions must remain temporary, proportionate and subject to robust review. Less trade-distortive alternatives, such as addressing energy costs, strengthening demand for recycled aluminium, supporting recycling investments, improving internal market functioning, and using existing trade defence instruments, must be fully explored and shown to be insufficient before export restrictions are considered as a measure of absolute last resort.