The future Circular Economy Law of the European Union is emerging as one of the major regulatory tools to strengthen the transition towards more efficient and sustainable production systems. According to Steel for Packaging Europe (SfPE), the regulatory text should ensure access to secondary raw materials within the continent, reduce dependence on imports, and guarantee industrial resilience through closed resource cycles. The association has published a position paper identifying key priorities and recommendations for the European Commission, which is currently in the drafting phase of the legislation.

The sector emphasizes that the current extended producer responsibility (EPR) systems remain fragmented among Member States and, in many cases, ineffective. SfPE argues that EPRs should evolve towards harmonized mechanisms that charge fees proportional to the actual net cost of collecting, sorting, and preparing each material for recycling, discounting the revenue obtained from the sale of the secondary raw material. The organization insists that cross-subsidization between materials should be avoided and that the funds raised should be reinvested exclusively in improving the collection and recycling of the material stream itself.

Another priority highlighted is the need to strengthen separate collection and progressively eradicate the landfilling of recyclable materials. SfPE points out that, although steel is highly recyclable and can be separated from mixed fractions thanks to its magnetic properties, deficiencies in the collection infrastructure continue to cause resource losses. The entity calls for clear labeling rules, homogeneous collection systems, and the introduction of landfill bans and economic incentives that favor the recovery of materials with value.

Regarding recycled content targets, the association warns that they are not a suitable tool for steel packaging, which already operates in a robust scrap market and a closed material cycle. SfPE argues that imposing recycled content targets could distort a market that is functioning correctly and that, instead, the regulatory focus should be on improving the availability and quality of scrap within the EU.

The document also urges that future legislation explicitly recognize the “permanent material” character of steel, capable of being recycled indefinitely without loss of properties. This distinction—it emphasizes—should be reflected in the waste hierarchy and in the design of regulatory instruments, differentiating truly circular materials from those that degrade their quality in each cycle.

SfPE also warns about the increasing pressure on the availability of ferrous scrap in Europe. The industry uses around 80 million tons annually, while exports of nearly 19 million tons, coupled with increased demand from new low-emission steel projects, could create tensions before 2030. The association calls for harmonized end-of-waste criteria, improvements in the classification and protection of scrap within the European market to ensure the supply of a strategic resource.

Among the final recommendations addressed to the European legislator, SfPE proposes: harmonizing EPRs and adjusting fees to the material reality; promoting high-quality separate collection and banning the landfilling of recyclable packaging; avoiding recycled content targets in steel; recognizing steel as a permanent material; and ensuring the availability of scrap to support industrial decarbonization.

For the association, only the setting of binding high-quality recycling targets and the substantial improvement of collection will allow progress towards a truly circular economy. The organization concludes that non-recyclable packaging should be progressively eliminated to meet the objectives of the Green Pact and strengthen European value chains.