The European Commission recommends excluding categories of ferrous and non-ferrous scrap metal from the list of waste permitted for export to Egypt because of insufficient evidence of effective environmental oversight, inspection and industrial waste management. While reports speak of a government response sent to Brussels, Zawia3 has been unable to verify its submission, and the House of Representatives’ Industry Committee has received no official copy. With European restrictions approaching in May 2027, Egyptian factories’ ability to secure alternative scrap supplies, and their cost, remain open questions.
On 18 September 2026, the European Commission published a draft list of countries outside the Organisation for Economic Co-operation and Development that could be authorised to receive specific types of non-hazardous waste from the European Union, as part of the implementation of the European Waste Shipment Regulation, Regulation (EU) 2024/1157. The assessment covered applications from 32 countries and regional or customs groupings seeking to continue receiving this waste. The draft does not impose a blanket ban on the scrap trade; it identifies countries meeting the conditions for receiving particular types of European waste. Under the new rules, restrictions are scheduled to apply from 21 May 2027. Exports of non-hazardous waste destined for recovery to non-OECD countries will stop unless the receiving country is on the approved list for the waste types concerned. The European regulation set 21 November 2026 as the deadline for adopting the first list of countries authorised to receive the covered waste, while consultation on the draft list ended on 16 October 2026. The fate of shipments to Egypt therefore depends on the Commission’s decision on Egypt’s inclusion and the types of waste that may be exported to it.
The European Commission expressed reservations about Egypt’s application to receive metal waste from the EU, finding that the information provided was insufficient to demonstrate compliance with requirements for environmentally sound management of that waste. According to the draft European assessment document, Egypt submitted its formal application on 21 February 2025. The Egyptian authorities then provided additional information on 30 September 2025 and 8 January 2026 in response to Commission requests for the data needed to assess the application. The draft recommended including specific waste types among the categories that could be authorised for export to Egypt, while not recommending the inclusion of categories of ferrous and non-ferrous metal waste. The European reservations therefore do not concern all forms of trade between Egypt and the EU, but Egypt’s eligibility to receive specific types of waste under the conditions of the new regulation.
Six Categories Accepted, but Metal Scrap Excluded from the European Recommendation
The Commission recommended that six waste categories could be included among those accepted for Egypt: paper, textiles, rubber, wood, glass, and organic, agricultural and food waste. It did not recommend including categories of ferrous and non-ferrous metal waste, which comprise specific codes in the international waste classifications adopted in the document. The Commission also excluded plastic waste listed under code B3011 because Article 39 of the European regulation completely prohibits exporting any plastic waste to non-OECD countries. Meanwhile, it removed slaughterhouse waste, such as hides, wool and bones, from the waste shipment regulation because it is subject to European veterinary quarantine and animal by-product rules under Regulation EC No 767/2009 rather than export rules.
The main European reservations focused on insufficient evidence of the application of environmental controls to metal waste treatment in Egypt. The observations covered information on industrial emissions, the management of waste from shredding and smelting operations, energy efficiency and mechanisms for monitoring pollutants, including dust, heavy metals, dioxins, furans, nitrogen oxides and sulphur dioxide. They extended to the handling of residues after treatment, including slag and lightweight waste from scrap shredding, alongside questions about the waste management system’s ability to provide accurate, verifiable data on the quantities generated, treated and disposed of. The Commission also considered that the information provided on treatment facilities’ capacity did not adequately explain the capacity available for each waste type or their ability to receive imported waste after meeting domestic market needs.
In a domestic move coinciding with discussion of the European file, the minister of investment and foreign trade issued Decision No 501 of 2026 on requirements for importing metal scrap and waste. According to the announcement by the General Organization for Export and Import Control, the decision requires an advance annual import permit from the Waste Management Regulatory Authority and restricts scrap imports to factories licensed to use it as a production input or licensed recycling plants. It also includes shipment inspection controls, including verification that shipments contain no hazardous materials and subjecting them to radiation screening. While the Egyptian controls seek to regulate scrap entry and inspection before customs clearance, the Commission’s observations concern inspection and enforcement data, treatment facilities’ capacity and the management of waste resulting from recycling operations.
Licences and Penalties, but Where Is the Enforcement Data?
The European assessment document reveals a more specific gap in this file. It notes that Egyptian legislation includes penalties ranging from fines to imprisonment, facility closures and confiscation of equipment, as well as requiring offenders to re-export shipments or bear waste removal costs where applicable. The fines cited in the document range from EGP 20,000 to EGP 25 million depending on the offence. However, the Egyptian authorities supplied no quantitative data showing the number or value of penalties imposed for waste shipment violations, nor did they explain how frequently penalties were applied or the results of enforcement action. One assessment gap thus concerns the lack of statistical evidence that rules are enforced, rather than merely existing in legislation. In its assessment, the European Commission identified several elements of Egypt’s waste management framework, including licensing requirements for certain activities and the existence of the national Waste Information Management System (WIMS), affiliated with the Waste Management Regulatory Authority, for registering companies, carriers, landfills and importers.
In the Commission’s view, the existence of legal rules and registration systems is insufficient to demonstrate effective oversight on the ground. It noted a lack of statistical information on the number of inspections carried out, violations recorded, fines imposed and the extent to which penalties were enforced. It also requested further details of waste movement controls, including prior approvals, confirmation that shipments arrive and are treated, and the ability to trace their routes in accordance with Basel Convention requirements. The challenge is therefore not limited to having legislation regulating waste management. It includes providing verifiable evidence of its enforcement, measuring compliance and demonstrating the relevant authorities’ ability to detect and address violations.
The document discussed Egypt’s position regarding relevant international environmental agreements, including the Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and Their Disposal. It also noted that Egypt had not joined the Minamata Convention on Mercury when the assessment was prepared, and cited the Egyptian authorities’ stated intention to take steps towards joining it by the end of 2026. Announcing an intention to join does not mean that the process has been completed. Assessing the situation requires distinguishing between the commitments included in the authorities’ responses and the legal and executive steps actually taken.
The European assessment required completion of data on Egypt’s waste management system, including long-term estimates of the quantities of waste generated, treated, recycled, landfilled and imported, with explanations of data sources and calculation methods. The requested information also includes updated lists of licensed facilities, their addresses, permits and capacities by waste type, alongside details of the environmental conditions attached to licences, emission limits, soil and groundwater protection measures, and controls preventing the mixing or dilution of waste to circumvent pollution thresholds. The technical requirements also include information on measures used to limit pollutants arising from treatment operations, including dust, heavy metals, dioxins, nitrogen oxides and sulphur oxides. This information matters because it enables the Commission to assess the Egyptian system’s ability to manage imported waste according to the required standards, rather than relying solely on legislation or licences for which insufficient enforcement data is available.
Four Factories in the Picture, but the Reservations Go Beyond Them
Mohamed Hanafi, executive director of the Chamber of Metallurgical Industries at the Federation of Egyptian Industries, says the factories concerned must take action to demonstrate compliance with the relevant environmental requirements. He explains that the matter is not limited to submitting a written response but requires actual measures and a report on them. Hanafi tells Zawia3 that, according to his statement, the observations concern four Egyptian factories using metal scrap: two belonging to Ezz Steel, along with Suez Steel and El Marakby. He explains that each factory must provide evidence of compliance with the requirements, with the data and measurements subject to verification to determine whether standards have been met.
Hanafi’s statements do not provide evidence that the European reservations are confined to four factories or to carbon emissions alone. The European assessment reviewed by Zawia3 concerns the waste management, oversight and data systems at national level. Zawia3 contacted Ezz Steel’s marketing director, George Matta, who declined to comment on Hanafi’s remarks about the Commission’s technical observations concerning the handling of industrial waste at two of the company’s factories.
Hanafi says he does not know whether the Egyptian authorities have already sent the required measures to the European Commission, noting that failure to meet the requirements before the new rules take effect could expose European scrap flows to Egypt to restrictions. However, he does not expect this to increase domestic steel prices, arguing that the impact of restrictions will depend on the factories affected and the market’s ability to replace raw materials from other sources.
The Government’s Response Remains Unconfirmed, and Parliament Has No Copy of the Memorandum
On 18 October 2026, Egyin alone published a report entitled “Egypt Responds to Brussels to Preserve European Scrap Imports and Save the Steel Industry”. It quoted Hassan El Marakby, deputy chairman of the Chamber of Metallurgical Industries at the Federation of Industries, as saying that the government sent Egypt’s file to the European Commission on 15 October. It reportedly included technical data supplied by the chamber and factories on scrap consumption, environmental standards followed and ways of handling emissions. However, this account could not be independently verified by the time of publication. Zawia3 contacted El Marakby to confirm that the file had been sent and to verify its contents, as attributed to him, but he did not answer the questions.
By contrast, MP Rania El-Shimi tells Zawia3 that the House of Representatives’ Industry Committee has not received an official copy of the government’s memorandum to the European Commission and has no confirmed information about its submission. To establish whether the file had actually been sent or whether the Commission had received it and found it compliant, Zawia3 contacted the Ministry of Industry and Trade through the director of the minister’s office, but no response had arrived by the time of publication.
El-Shimi adds that a meeting was held on 13 October involving representatives of the ministries of local development, environment, industry, investment and foreign trade, alongside the Industrial Development Authority, to discuss European requirements relating to metal scrap imports. She says parliament’s Industry Committee asked the government for a copy of the memorandum responding to the Commission’s conditions. She explains that the requirements concern not only factories but also government procedures and the controls to be applied to the relevant industrial facilities. However, she notes that she has no confirmed information about whether the memorandum was actually sent to the European side or which shortcomings still need to be addressed.
MP Rania El-Shimi says the factories’ current problem centres on their need to import metal scrap, rather than an inability to comply with environmental conditions. She adds that the requirements factories need to meet will become clearer after procedures are completed and the Commission reviews the government’s response. In this regard, Zawia3 contacted Nahed Youssef, chair of the Industrial Development Authority, to ask whether the government had sent its response to the European Commission or whether it was still being prepared, but Youssef preferred not to respond.
15,000 to 20,000 Factories? Estimates without Supporting Statistics
Mohsen El-Tagoury, deputy head of the Importers Division, says the division supports imposing environmental requirements and specifications on metal scrap imports, arguing that compliance helps Egyptian factories improve operating efficiency and expand production. He tells Zawia3 that Egypt can seek alternative sources of raw materials, pointing to Italy, France and the United Kingdom, without providing data on the available quantities or import costs from these markets. Regarding the number of factories dependent on imported scrap, El-Tagoury estimated approximately 15,000 to 20,000, but provided no statistics supporting the estimate or explaining how it was calculated. He also cited 40% as the European share of total scrap imports, according to his statement.
Ultimately, the possibility of replacing European scrap with supplies from alternative markets still needs to be tested against the figures. Suggesting that Egypt can replace its imports with supplies from Italy and France does not resolve the problem, because both are EU members. Switching to suppliers outside the EU requires knowing the quantities available, prices, shipping costs and how suitable the scrap is for Egyptian factories. The deputy head of the Importers Division offered no estimates of the quantities that could be secured from the United Kingdom or other markets, or of the difference in landed cost per tonne compared with current European sources.
