Secondary raw materials are no longer a nice-to-have. Reusing materials reduces the pressure on primary raw materials and makes chains less dependent on scarce resources. But as soon as those materials cross borders, a circular opportunity quickly turns into a difficult playing field of quality requirements, waste status, documentation and regulations. Are you working with international material streams? Then it's time to look beyond availability and price.
This is not a theoretical story. The European Commission is working on a Circular Economy Act in 2026 to support a Single Market for secondary raw materials. With this, the EU aims to increasethe supply of high-quality recyclates, boost demand for secondary materials and reduce the European economy's dependence on primary raw materials. At the same time, the European circularity rate is still around 11.8%, while the ambition is to move toward 24% by 2030. The direction is clear. The practice is still far from that.
In short: international trade in secondary raw materials offers enormous opportunities for circularity and security of supply. But these opportunities can only be realized if quality, classification, traceability and compliance are in order. Without a grip on those basics, a circular flow quickly turns into a supply chain risk.
Why international trade in secondary raw materials is growing
International trade in secondary raw materials is growing because Europe simply wants to become less vulnerable. Demand for materials is increasing, geopolitical dependencies are under a magnifying glass, and recycling is becoming increasingly important for security of supply. The Critical Raw Materials Act makes this concrete: the EU wants to increase its own extraction, processing and recycling of strategic raw materials and aims for 25% recycling of the annual need for strategic materials in 2030. Secondary raw materials are thus moving from a sustainability issue to a strategic raw materials issue.
Figures also show that this issue is no longer on the fringes. According to Eurostat, the EU exported 35.7 million tons of recyclable raw materials to non-EU countries in 2024. Imports stood at 46.7 million tonsin the same year .Metals accounted for more than half of exports, while in the case of imports, mainly organic materials weighed heavily. Thus, secondary raw materials have long since ceased to be local residual streams, but international material streams with economic and strategic value.
This presents opportunities. International trade makes it possible to process or apply materials where the most value is created. After all, not every region has the same processing capacity, market or industrial demand. But this is precisely where the crux lies: the larger and more international the chain, the greater the risk of loss of quality, obscurity or delay.
Once secondary raw materials cross borders, things get complicated
In theory, international trade in secondary raw materials sounds logical. In practice, the complexity often starts with one simple question: is this still waste, or already a raw material? That distinction determines what rules apply to storage, transport, processing and export. If you wait too long to make that assessment, there are almost immediate risks of delays, additional requirements or even the wrong processing route.
Moreover, different countries, supply chain partners and processors do not always look at the status of a material in the same way. What is treated as a secondary raw material in one situation may still be seen as waste elsewhere. And that is precisely where things often go wrong in practice: not because the material has no value, but because legal and operational reality lags behind the circular ambition.
The tightened European rules make this even more visible. The new EU Waste Shipment Regulation entered into force on May 20, 2024, imposing stricter conditions on cross-border waste streams. On April 29, 2026, the European Commission even had to come up with a targeted amendment to allow existing export streams of mixed household waste to Switzerland. This shows how sensitive classification and regulations are once a material stream crosses borders.
This is what organizations get stuck on in practice
Those working internationally with secondary raw materials often face the same recurring bottlenecks:
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Lack of clarity about waste or product status, with direct consequences for exports, processing and permits.
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Quality differences and contamination in material streams, putting pressure on employability and market value.
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Additional documentation and compliance requirements, especially if chain partners interpret the same stream differently.
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Insufficient traceability, making origin, composition or processing steps difficult to prove.
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Price pressure from primary raw materials, making secondary materials seem commercially less attractive, even if they score better circularly.
This is precisely why international trade in secondary raw materials is not something that you organize "on top of it". Without a grip on quality and chain information, the value of secondary raw materials remains vulnerable.
What this means for organizations
Do you work with secondary raw materials? Then you have to look beyond volume, price and a nice circular promise. The real question is whether those materials also land reliably, applicable and legally correct in your chain. This affects not only recyclers and traders, but equally producers, buyers and sustainability managers who want to use circular raw materials in products or processes.
It also means that secondary raw materials can no longer be approached as "by-products" of waste management. Once they are deployed strategically, strategic requirements also apply. Think consistent quality, security of supply, correct classification and conclusive documentation. If one of those links falters, delays, additional costs or discussions about applicability quickly arise.
For sustainability managers, there is an additional task there. Circularity claims not only have to sound good, but they also have to hold up as soon as auditors, chain partners or regulators ask about origin, processing route or material status. Especially in international chains, this becomes more acute. The longer the chain, the more important it becomes to be able to demonstrably track and substantiate material flows.
Keep control of international trade in secondary raw materials: 4 key focus areas
Anyone who takes international trade in secondary raw materials seriously must therefore focus on getting a grip. These four points of attention will help turn a circular flow into a reliable raw materials chain:
Map the classification early on
Don't wait until a material stream gets stuck at the border. Ensure clarity early in the chain: is this legally still waste, or already a raw material? That very distinction determines how much leeway there is for transport, processing and application.
Secure quality, not just availability
Availability alone is not enough. A secondary raw material must be clean, stable and applicable. As soon as quality changes or contamination increases, not only does practical applicability decrease, but so does economic value.
Make traceability part of chain management
Origin, composition, processing steps and documentation must be traceable. Not as a paper sideline, but as the basis for better decisions. Those who organize traceability well not only reduce risks, but also strengthen the credibility of circular claims.
Don't regulate compliance after the fact
With stricter European rules for waste shipment and more focus on strategic materials, compliance is no longer a final check. It is a prerequisite for material flows internationally to function reliably at all. Those who address this too late not only risk delay, but also additional costs and reputational damage.
From circular ambition to reliable raw materials chain
International trade in secondary raw materials will only become more important in the coming years. Not because circularity is a buzzword, but because access to materials, security of supply and competitiveness are increasingly coming together. Europe wants to accelerate and structure that market, but it will only succeed if organizations organize their chains maturely.
Therefore, now is the time to take a critical look at international material flows. Is the classification correct? Is the quality predictable? Is the documentation in order? And is it clear where in the chain the greatest risks are? Whoever does not ask these questions now will soon be behind the times. Those who do ask them lay the foundation for a circular chain that not only sounds ambitious, but actually works.
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