Restrictions on scrap exports in Ukraine: history, current situation, and essence of the problem

Since 2015, Ukraine has been trying to stop large-scale scrap exports by imposing export duties, which have risen from €10/ton to €180/ton since then. However, for various reasons, this goal has not always been achieved. Starting in 2026, Ukraine wants to set a zero quota on ferrous scrap exports.

GMK Center explains how the situation with scrap export restrictions has developed and why more decisive measures are needed.

Background

The issue of regulating ferrous scrap exports from Ukraine has a long history. For example, in 2012, quotas were in place (900,000 tons per year), while in the late 2010s, the main tools were not absolute bans and the distribution of export permits, but export duties and temporary restrictions, which were periodically extended.

In 2017, a duty of €10/ton was in effect, which was subsequently increased to €30/ton. In 2018–2019, the rate was first increased to €42/ton, and then to €58/ton. These duties were intended to limit the outflow of strategic raw materials and provide Ukrainian steel enterprises with the necessary resources.

However, this level of duties proved to be insufficient. In the first half of 2021, scrap exports grew almost 14 times, reaching 231,000 tons. It was precisely this significant increase in raw material exports that necessitated the adoption of more effective regulatory measures.

In the fall of 2021, the Ministry of Economy proposed two options for solving the scrap export problem. First, the ministry prepared a draft resolution on a temporary ban on exports until the end of 2022. Later, the ministry developed a bill to increase the export duty to €200/ton.

In the end, the option to increase the duty was chosen as an alternative to a complete export ban. In December 2021, the Verkhovna Rada decided to increase the export duty to €180/t, which was a logical step given the rapid growth in scrap exports.

Insufficient restraint

Over time, the €180/t duty ceased to restrain the flow of scrap exports, as evidenced by statistical data. In January–September 2025, scrap exports from Ukraine grew by 54.1% to 311.8 thousand tons. The growth in raw material exports was even higher in 2023 and 2024, increasing 3.4 times year-on-year to 182,500 tons and 60% year-on-year to 293,200 tons, respectively. At the same time, scrap collection fell from 4-5 to 1.2-1.5 million tons per year, due to the economic downturn and military operations.

There are two reasons for the growth in scrap exports after 2022:

1. The possibility of transiting and re-exporting scrap through neighboring countries without paying dutiesVirtually all Ukrainian scrap is exported to EU countries (mainly Poland), with which there is a zero export duty under the Free Trade Agreement. From the EU countries, the raw materials are re-exported to Turkey and other third countries. In recent years, Poland has become a transit hub for Ukrainian scrap. By the end of 2024, Polish scrap exports to Turkey had more than doubled, reaching 529,000 tons compared to 228,000 tons a year earlier.
2. High scrap prices

Global scrap prices are high enough that even with the duty, exports remain economically viable.

For the reasons above, the issue of restricting scrap exports to ensure raw materials for the Ukrainian steel industry remains relevant.

A new stage of regulation

Public information about the possibility of introducing quotas on scrap exports appeared in April, although the idea was first voiced at a meeting of the Verkhovna Rada Committee on Economic Policy on March 28, which was attended by MPs and representatives of the Ministry of Economy. It took more than six months to implement this idea, which was initiated by the Ukrmetprom public association and the Federation of Employers of Ukraine.

In May, the Ministry of Economy submitted for public discussion a draft resolution of the Cabinet of Ministers proposing the introduction of licensing and quotas for the export of ferrous scrap with a zero quota for 2025. The relevant changes were to be made to Annex 1 of CMU Resolution No. 1481 of December 24, 2024, which defines the list of goods whose export and import are subject to licensing, as well as annual quotas.

In November, a new version appeared — a draft resolution of the Cabinet of Ministers “On the approval of lists of goods whose export and import are subject to licensing, and quotas for 2026.”

The document proposes:

• to introduce licensing and quotas for the export of scrap;
• to set the quota for ferrous scrap for the next year at zero.

The option of effectively banning exports by setting a zero quota is expected and logical, and in the current circumstances seems to be the only possible solution. This is because Ukraine cannot change the terms of the Free Trade Agreement with the EU, which provides for zero export duties on scrap.

This practice is in line with global and European trends. The EU is actively discussing a ban and restrictions on scrap exports (primarily to Turkey and India) to ensure raw materials for local steel industry. As of the end of March 2025, 48 countries around the world had introduced 75 restrictions on scrap exports. One country may have more than one restriction, and 38% of them have introduced a partial or complete export ban.

According to a study by GMK Center, in the long term, scrap will gradually lose its status as an export commodity due to global trade barriers. Scrap plays an important role and is considered a strategic resource that should ensure the competitiveness of the local steel industry, including as part of the green transition, so countries are seeking to retain raw materials for their own needs.