Ferrous Export Corridors: Sanctions, Bans, and Workarounds – Navigating the Shifting Landscape

Navigate the 2025 ferrous metals trade landscape shaped by sanctions, export bans, and carbon regulations. Discover strategic workarounds for scrap, semi-finished steel, and raw material corridors amid shifting EU CBAM, Waste Shipment rules, and geopolitical tensions.

SCRAP METAL TRADE & POLICY

TDC Ventures LLC

11/18/202522 min read

Nighttime port with steel coils and scrap under a lit map of Europe and Asia.
Nighttime port with steel coils and scrap under a lit map of Europe and Asia.

The global ferrous metals industry still underpins daily life, from rebar in highways to sheet in cars. In 2024 world crude steel production was about 1.88 billion tonnes, almost flat versus recent years, while steelmaking generated roughly 4.1 billion tonnes of CO2, or around 7 to 8 percent of global greenhouse gas emissions.

Since 2022, ferrous export corridors that connect scrap, ore, and semi-finished products to mills have turned into a visible instrument of policy. Sanctions, tariffs, export bans, and carbon rules are no longer background noise. They sit inside pricing, availability, contract structures, and bank approvals.

Export bans, sanctions, and real-time policy shifts continue to redraw maps. They create barriers for exporters and push buyers to search for compliant and secure channels. To operate in this environment in 2025, you need current intelligence, disciplined risk tools, and sourcing strategies that can turn quickly when rules move.

Ferrous Export Corridors: The New Geopolitical Chessboard

Over the last decade the global steel supply chain has become a political chessboard. That has not eased in 2024 and 2025.

Case in Point – The Russia Ukraine War

Before 2022, Russia and Ukraine together supplied well over 15 percent of seaborne iron and steel trade, with the Black Sea the core route. The invasion in 2022 and rounds of EU, US, and allied sanctions cut direct Russian flows into many Western markets, while Ukrainian export capacity took a direct hit from plant destruction and blocked ports.

By 2024, the picture was more complex, not simpler. The EU still imported around 5.34 million tonnes of iron and steel products from Russia in 2024, worth more than 2.5 billion euros, even after several products moved onto sanctions schedules. These flows concentrate in slab, semi-finished, and products where exemptions or loopholes remain, and they keep Russia present in the European value chain despite formal restrictions.

Ukraine's crude steel output fell more than 70 percent in 2022 to about 6.3 million tonnes, then slipped to roughly 6 million tonnes in 2023. In 2024, with a defended Black Sea corridor back in partial use, production recovered to about 7.58 million tonnes. Output in the first four months of 2025 was around 2.43 million tonnes, only 1 percent higher than the same period of 2024 and still far below the pre-war range above 20 million tonnes. For traders and mills this means Ukrainian supply is back, but fragile, port dependent, and heavily exposed to security headlines.

EU Green Initiatives, CBAM, and Waste Shipments

The EU's Carbon Border Adjustment Mechanism (CBAM) moved deeper into its transition phase in 2024 and 2025. Importers now report embedded emissions for covered products such as steel each quarter from October 2023 to December 2025. Financial obligations, meaning the purchase and surrender of CBAM certificates, start from January 2026.

At the same time, the new EU Waste Shipment Regulation 2024/1157 was adopted and will apply from May 2026. From May 2027, exports of waste, including ferrous scrap, to non-OECD countries that are not on an approved list will be prohibited. This shifts the debate from "Will the EU restrict scrap exports" to "How quickly and how tightly will the new rules bite".

The market has already moved. EU ferrous scrap exports to third countries fell to about 16.7 to 17.0 million tonnes in 2024, down roughly 11 percent from more than 19 million tonnes in 2023 and at a five year low, even though the EU still held about a 30 percent share of global steel scrap exports. Metals were still the largest recyclable raw material export category, with about 19 million tonnes shipped in 2024, and Türkiye remained the top destination for EU recyclable raw materials with around 12.3 million tonnes.

The net effect is a slow tightening of outward flows from Europe. Scrap is still leaving, but with lower volumes, more conditions, and clear legal milestones in 2026 and 2027 that will shape who can receive it.

Turkey's Evolving Role

Turkey kept its position as the world's largest importer of ferrous scrap. In 2024 the country imported about 20.09 million tonnes of ferrous scrap, up 6.7 percent from 2023. In the first nine months of 2025, imports dropped by around 6.8 percent year on year to roughly 13.94 million tonnes as weaker steel demand, cheap semi-finished alternatives, and changing supplier mixes took effect.

Throughout 2024 Turkish mills often capped scrap prices by switching to imported Chinese billet when spreads and transit times allowed. By early 2025 Turkey had shifted more of its scrap sourcing toward Russian and some EU suppliers, while flows from the United States and the United Kingdom into Turkey fell markedly compared with early 2024.

For exporters into Turkey this means a more crowded and politically sensitive market, especially as Russian material competes on discount and some Western buyers step back for sanctions reasons. For Turkish EAFs it preserves options but increases reputational and compliance exposure.

Emerging Hubs: India and Southeast Asia

India and Southeast Asia have moved from "emerging" to "central" in ferrous flows.

India produced about 151.1 million tonnes of crude steel in fiscal 2024 to 2025 and had steelmaking capacity close to 200 million tonnes. The government and industry plan to lift capacity to about 300 million tonnes by 2030 or 2031 and to more than 330 million tonnes by 2030 in some scenarios. Steel demand growth in India is projected near 9 percent per year in 2025 and 2026, which makes the country one of the main demand engines in the coming decade.

Southeast Asia is on its own capacity surge. ASEAN-6 steelmaking capacity is expected to rise from about 78 million tonnes per year in 2022 to 94 million tonnes by 2024 and could reach around 182.5 million tonnes by 2030. Much of this capacity comes through cross-border and joint-venture investment by Chinese companies and a visible shift toward electric arc furnaces and DRI routes in newer projects.

Both India and Southeast Asia lack sufficient domestic obsolete scrap in the short term. That keeps them tied to import corridors from Europe, North America, the CIS, and the Middle East, while they build out local collection and more EAF capacity.

Bottom line

In 2025 ferrous export corridors are even less about raw geography and even more about who controls port access, whose material clears CBAM and Waste Shipment rules, who can accept or refuse Russian and other contentious origins, and who can align logistics with sudden policy changes. Real-time intelligence and scenario planning are now as important as price or grade.

2. Key Market Drivers Behind Export Bans and Sanctions

The ferrous trade still moves under a set of broad forces that have only strengthened since 2020.

A. Protectionism and National Security

Large producers from India to Indonesia and from the EU to the US continue to use trade tools to protect domestic industry or blunt inflation. India provides a clear case. After a brief period of export duties on steel products in 2022, India is now trying to defend its market against a surge of cheap imports, especially from China, using a temporary 12 percent tariff on some steel imports while still pushing for a capacity target of 300 million tonnes by 2030 to 2031.

Across many regions the number of temporary duties, quotas, or export licensing regimes touching steel and scrap remains high. Since 2020 more than 40 percent of global ferrous trade has crossed at least one jurisdiction that has experimented with export controls or duties on steel or raw material at some point. National interest and supply security still trump pure market logic when inflation or energy shocks hit.

B. Environmental Regulations

Steel remains one of the hardest industrial sectors to decarbonize. In 2024 the sector produced about 1.886 billion tonnes of steel and emitted roughly 4.1 billion tonnes of CO2 equivalent. Each tonne of steel produced led on average to about 2.18 tonnes of CO2 equivalent when counting direct and indirect emissions. That keeps steel's share of global anthropogenic emissions in the 7 to 8 percent range.

At the same time, using one tonne of scrap instead of virgin materials avoids roughly 1.5 tonnes of CO2 and saves iron ore, coal, and limestone. That simple physics sits behind many of the new rules.

European scrap export restrictions and CBAM are two sides of the same push. The EU wants cleaner domestic production, fewer free ETS allowances by 2034, and imported steel that faces a carbon price similar to domestic producers. CBAM is in a reporting-only phase until the end of 2025, but from 2026 importers of iron and steel will have to buy CBAM certificates linked to the EU ETS price. At the same time, the Waste Shipment Regulation will tighten which non-OECD countries can receive EU scrap and on what terms.

C. Geopolitical Leverage

Steel and scrap remain tools of economic pressure. Sanctions related to the Russia Ukraine conflict, and wider US and EU sanctions regimes, keep a large share of global iron and steel capacity inside compliance maps. Russia still supplies metals to the EU and other regions but with changing product mix, financial channels, and heavy discounting in some markets.

For China, both a major importer of scrap and a leading exporter of semi-finished and finished steel, tariff changes, export refunds, and licensing tweaks remain a flexible tool to manage domestic employment, industrial policy, and external influence. Surges of Chinese exports in 2024 and 2025 depressed prices in many regions and pressured local producers from Europe to India.

D. Demand Dislocations

Global apparent steel demand fell by about 0.9 percent in 2024 to around 1.75 billion tonnes, and worldsteel expects demand in 2025 to be flat near that level, with only a modest 1.3 percent rebound to about 1.77 billion tonnes in 2026. OECD analysis sees global demand rising only 0.7 percent per year on average through 2030, with declining demand in China offset by steady growth elsewhere.

That slow growth, mixed with pockets of strong expansion in India and parts of Southeast Asia, invites more frequent policy tweaks. Countries facing weak domestic demand and high costs look outward. Those facing strong demand growth look to protect domestic feedstock and capacity.

Key statistic

A 2023 OECD survey still resonates in 2025. More than half of global steel buyers ranked "regulatory surprise risk" as their top supply concern, ahead of pure price volatility. That perception has not softened after two more years of sanctions, new tariffs, and CBAM preparation.

3. Scenario Analysis: Shifting Trade Routes and Impact on Demand

Scenario planning is no longer an academic exercise. For traders, mills, and logistics providers, it guides supplier selection, contract terms, and freight exposure. The examples below now sit against 2024 and 2025 data rather than early-war assumptions.

Scenario 1: Sanctions Take Hold – The Russia Case

Key dynamics in 2025

• EU sanctions reduced imports of many Russian steel products, yet the EU still bought about 5.34 million tonnes of iron and steel from Russia in 2024, about half of early 2020s levels and concentrated in categories with exemptions.

• Russian mills redirected more semi-finished and finished products to Türkiye, North Africa, the Middle East, and parts of Asia. Discounts against EU benchmarks remain significant in many deals, especially where cargoes need opaque routes or more complex financing.

• As of late 2025 many buyers in Asia, the Middle East, and Africa still purchase Russian steel or billet, but they face higher banking and insurance scrutiny. Some banks treat any deal involving Russian material as enhanced due diligence, even where activities are not directly banned.

• Ukraine's partial recovery and use of a protected Black Sea corridor has brought some material back into the market, but flows remain vulnerable to any change in security conditions.

Risk points

• Secondary sanctions remain a moving target. Even non-Western buyers risk future penalties if they trade with entities or cargoes that later fall under stricter regimes.

• Value-chain "washing" through third countries, re-rolling, or misdeclared origin increases legal, reputational, and contractual risk for every party in the chain.

Scenario 2: EU Scrap Export Tightening – Circular Economy and Waste Shipment Rules

2024 and 2025 brought more clarity on EU scrap flows and future rules.

• EU ferrous scrap exports to third countries fell to about 16.7 to 17.0 million tonnes in 2024, down roughly 11 percent from over 19 million tonnes in 2023 and the lowest level in five years.

• The Waste Shipment Regulation 2024/1157, which entered into force in May 2024 and applies from May 2026, introduces a country-by-country approval system for non-OECD destinations that wish to keep importing non-hazardous waste such as scrap. Countries not on the approved list by May 2027 will be cut off.

• The EU remains the world's largest exporter of steel scrap, with about a 30 percent share in 2024, but the direction of travel is clear. More material is expected to stay in-region over time to feed "green steel" projects and to support local circular economy goals.

Market implications

• Basis 2024 volumes, the new regime affects a scrap export baseline of roughly 17 million tonnes per year. As more of that material is locked to OECD destinations or banned from non-approved non-OECD buyers, competition will intensify in remaining open routes.

• Substitutes such as DRI and HBI continue to gain traction, especially in the Middle East and North Africa, where large new DRI projects are under construction or in planning, many with hydrogen-ready designs.

• Smaller Asian re-rollers and EAFs that relied on cheap European scrap without investing in traceability or long-term contracts are most exposed.

Scenario 3: New Corridors – India and Southeast Asia Rise

Growth drivers

• India's steel consumption is forecast to grow about 9 percent in both 2025 and 2026, supported by infrastructure, housing, and automotive demand. At the same time, India is targeting crude steel capacity of 300 million tonnes by 2030 to 2031 and 500 million tonnes by 2047, up from around 205 million tonnes of capacity in fiscal 2024 to 2025.

• ASEAN capacity is expected to more than double from about 94 million tonnes per year in 2024 to roughly 182.5 million tonnes by 2030, with Chinese investors playing a major role in new projects.

• Many new Southeast Asian plants are choosing EAF and hydrogen-capable DRI technology to stand out on emissions and to access future green-steel premiums.

Market impact

• India and ASEAN will pull increasing volumes of scrap, ore, and semi-finished products from every exporting region. That includes redirected Russian material, Middle Eastern DRI, and EU or US scrap where rules allow.

• Regional indices such as the Metal Bulletin SEA Index gain importance as more contracts reference regional price signals instead of only CFR Turkey or traditional European benchmarks.

• Corridor risk does not only run north-south. Indian and Southeast Asian buyers have to manage growing exposure to carbon rules in export destinations, including CBAM in the EU, which will price carbon content of their steel from 2026 onward.

Scenario 4: Black Sea and Alternative Routes – Logistics Under Strain

During the height of the Black Sea blockade, more than 80 percent of Ukrainian steel and raw material exports switched from sea to rail and road routes through EU neighbours and alternative ports. That lifted costs and stretched lead times.

In 2024 a protected "Ukrainian corridor" in the Black Sea reopened some seaborne exports. This contributed to an increase of about 21.5 percent in Ukrainian steel output in 2024 compared with 2023 and helped support GDP growth. Yet the corridor remains vulnerable to military escalation, insurance pricing, and any shift in naval risk perception.

For traders and mills that rely on Black Sea material, that means blending rail, truck, and sea options and treating any single port or route as interruptible.

Practical Strategies For Exporters, Importers, Mills, And Traders

Sections 4 to 8 already contained strategy guidance. The logic still holds in 2025, but the parameters have shifted around 2024 data and the coming CBAM and Waste Shipment milestones.

4.1 Exporters: Surviving In A World Of Bans And Sudden Rule Changes

Exporters in "swing" countries cannot assume that today's open corridor will stay open. You need plans for normal conditions, partial restrictions, and full bans.

Build a corridor portfolio, not a single outlet

Relying on one main corridor, for example EU to Turkey, is even more dangerous now. EU ferrous scrap exports to third countries slipped to about 16.7 to 17.0 million tonnes in 2024 from above 19 million tonnes in 2023 as policy pressure intensified and freight costs shifted.

Exporters are better placed if you:

• Maintain at least three outlet regions, for example Mediterranean EAFs, South Asia, and Southeast Asia.

• Keep at least one corridor within OECD, where future EU rules will still allow non-hazardous scrap exports under stricter conditions.

Align quality, documentation, and routing with "worst case" policy

Most export restrictions and Waste Shipment rules favour:

• Higher quality, low contamination scrap.

• Cargoes destined for OECD or for approved non-OECD destinations with clear end-users.

• Traceable intra-company or long-term offtake flows with strong documentation.

Given this, exporters should:

• Upgrade sorting and cleaning so that all main products can meet high-grade thresholds if rules tighten mid-year.

• Build complete documentation chains for each lot, including photos at load, weighbridge records, radiation certificates, and yard QC reports mapped to each container or bulk parcel.

• Pre-plan alternative routings and forwarders if one port, transit state, or shipping line becomes constrained for sanctions or Waste Shipment reasons.

Use contracts that anticipate export interference

For every sale, ask early what happens if your government or the EU changes licensing, bans certain HS codes, or tightens CBAM and Waste Shipment rules before sailing. Then put that into the contract.

• Add clear "regulatory change" clauses that define events such as new duties, licensing rules, or bans.

• Align Incoterms with your risk appetite. Under FOB, the buyer takes freight risk but the seller remains responsible for export clearance and compliance. Under CFR or CIF, you carry more of the exposure and should price it accordingly.

• Build a regulatory risk margin into the price that can be partially rebated if the cargo clears without extra costs.

Engage with trade bodies early

At EU level, groups like Eurofer and EuRIC continue to influence how scrap export restrictions roll out and how CBAM data rules apply. Exporters that bring credible, yard-level data into these discussions can sometimes gain early visibility on rule changes and help shape transitional arrangements or carve-outs.

4.2 Importers And Mills: Securing Tonnage While Staying Compliant

Scrap-dependent EAFs now sit inside a narrow channel between domestic regulators and external policy shocks.

Design a "laddered" sourcing mix

Turkey imported about 20.09 million tonnes of ferrous scrap in 2024, then saw a 5 to 10 percent year-on-year drop in imports during the first three quarters of 2025 as weaker demand and more use of semi-finished products such as cheap Chinese billet took effect.

Mills in similar positions should:

• Secure a base load from politically stable suppliers with strong compliance records.

• Add a second tier of opportunistic cargoes from higher-risk origins, capped to a controlled share of the melt.

• Keep a third tier of substitute metallics such as DRI, HBI, or pig iron to cover scrap shortfalls or policy shocks.

Couple physical sourcing with financial hedging

• Use scrap indices such as CFR Turkey, plus rebar or HRC futures, to hedge margins on exposure corridors.

• Lock in FX cover on contracts priced in dollars when local receivables are in other currencies, especially where sanctions or tariffs can trigger fast rate moves.

• Structure purchase formulas on indices plus freight and carbon surcharges rather than pure flat prices to share risk.

Build a live "traffic light" system for counterparties

Classify suppliers and origins as green, amber, or red and tie each colour to purchasing limits and approvals. That system should combine sanctions screening, KYC, ownership checks, and corridor risk. It should also adjust as CBAM, Waste Shipment, or national sanctions lists change.

Secure substitutes before you need them

EU proposals and adopted measures on scrap exports, plus rising internal demand for scrap-based "green" EAF output, mean non-OECD buyers will face tighter access to EU scrap from 2026 to 2027. Mills that have already invested in:

• Local scrap collection schemes.

• DRI units using local gas and, later, hydrogen.

• Long-term HBI and pig iron contracts.

enter the next round of restrictions from a stronger position.

4.3 Traders And Intermediaries: Turning Volatility Into Repeat Business

For traders, 2024 and 2025 confirmed that compliance and corridor knowledge are not overhead. They are core services.

• Specialize in specific corridors and keep live matrices showing origin–destination pairs, voyage times, port congestion, main insurance conditions, and sanctions overlays.

• Offer "compliance plus logistics" instead of only price finding. Pre-screen lots, maintain template contracts, and help mills interpret CBAM, Waste Shipment, and local rules.

• Use structured pricing that references scrap indices, freight benchmarks, and explicit carbon or compliance premia. Maintain options in the contract to shift ports or adjust sailing windows if policy conditions change.

• Build relationships with banks, insurers, and inspection firms that understand sanction and carbon risk. Traders who can bring a credible compliance "package" to both yard and mill can often unlock trades that others cannot.

5. Building A Risk And Compliance Toolset For Ferrous Trade

Geopolitics, carbon policy, and waste rules are now part of the ferrous P&L. The strongest companies treat policy and compliance like maintenance or safety: as a routine.

5.1 Map Your Policy Exposure

Start with a corridor map covering at least the past 24 months. For every origin, transit point, and destination, capture:

• Known sanctions and watch lists.

• Export or import restrictions, including CBAM scope and Waste Shipment rules.

• Environmental rules and any carbon reporting obligations.

• Customs and inspection requirements.

Tag each corridor with a qualitative risk score based on rule-change frequency, corruption risk, and history of detention or delay. Refresh this map at least quarterly.

5.2 Integrate Sanctions And KYC Screening Into Trade Flow

Sanctions on Russian steel and coal, and regular additions to SDN lists, have proved how quickly finance can choke trade, even where goods are technically allowed.

Practical steps:

• Screen counterparties, vessels, and banks through at least one commercial or bank-provided sanctions system before booking.

• Check beneficial ownership, especially where companies are registered in transit hubs that are known for acting as "bridges" for sanctioned material.

• Collect standardized KYC packs from regular partners and tie approval levels to transaction size and corridor risk.

5.3 Carbon Rules, Scrap Flows, And Traceability

In 2024 the iron and steel sector emitted roughly 4.1 billion tonnes of CO2 equivalent, about 7 to 8 percent of global emissions. At the same time more than 460 million tonnes of ferrous scrap were melted worldwide, and producers in the EU, India, and Turkey increased their scrap consumption year on year.

Carbon rules such as CBAM and national ETS schemes will increasingly link CO2 footprints to trade access and tariffs. To keep premium-market access you should:

• Track scrap origin at least to country and yard level.

• Record mill process routes and typical scrap ratios.

• Build the ability to issue basic CO2 intensity and recycled content statements that can plug into CBAM and customer systems.

Digital product passports, QR-coded certificates, and simple internal ledgers can support this. You do not need full blockchain infrastructure for most contracts in 2025, but you do need consistent, auditable records.

5.4 Scenario Planning And Stress Testing

With world steel demand close to 1.75 billion tonnes in 2024 and expected only to edge up to around 1.77 billion tonnes in 2026, small policy shocks can move price and availability sharply.

Run regular stress tests such as:

• A 20 percent further drop in EU scrap exports to non-OECD markets relative to 2024 levels.

• A new export duty on scrap or semi-finished products in a key supplier country.

• A doubling of freight rates on a core route after conflict or port congestion.

For each scenario, estimate:

• Availability by corridor and grade.

• Expected spreads between domestic and imported scrap, DRI, and hot metal.

• Cash-flow impact on your own operations and on key counterparties.

You can start with simple spreadsheets and published data. What matters is that you think through these scenarios on a regular schedule, not that you build a perfect model.

6. Case Studies: How Different Players Adjusted To The New Corridors

Case Study 1: A Turkish EAF Mill Rewrites Its Sourcing Playbook

Background

A mid-sized Turkish EAF producer, reliant on imported scrap for around 90 percent of its metallics, built its historic model on EU and UK feedstock. As EU scrap debates intensified and 2024 volumes to third countries dropped, competition for remaining export tons rose.

Actions

• The mill signed new annual contracts with US, Baltic, and some domestic suppliers, even at slightly higher base prices, to loosen its dependence on EU yards.

• It added DRI from the Middle East at roughly 10 to 15 percent of its metallic charge to diversify away from pure scrap.

• It introduced a traffic-light supplier risk classification and linked purchasing limits to compliance checks.

Outcomes

• Average scrap costs rose by about 5 to 7 dollars per tonne in the first year because of longer voyages and quality differences.

• The mill avoided the sharpest price spikes when rumours of further EU scrap restrictions surfaced, because it could lean on non-EU and DRI supply.

• Banks and insurers rewarded the more structured risk approach with slightly better working capital and marine cover terms.

Case Study 2: An EU Scrap Processor Shifts From Export-First To Domestic Green Steel

Background

An EU-based processor used to export over 60 percent of its ferrous scrap to non-EU destinations. Growing CBAM expectations and the Waste Shipment Regulation convinced management that outbound flows would face heavier scrutiny and, over time, more limits.

Actions

• The company opened long-term talks with regional EAF mills positioning low-CO2 steel for automotive and construction customers.

• It invested in better sorting, including sensor-based systems, to deliver higher-grade scrap for mills that want to raise scrap ratios.

• It implemented traceability tools for municipal and industrial scrap sources, aligned with mills' recycled content and CO2 disclosure needs.

Outcomes

• Export volumes fell, but domestic contracts grew in both volume and margin, as mills paid for quality and traceability.

• The processor won "strategic supplier" status with several mills and reduced its exposure to freight and WSR-related export risk.

Case Study 3: An Indian Flat Steel Producer Navigates Domestic Policy And Global Carbon Pressure

Background

India plans to lift crude steel capacity from around 200 million tonnes to about 300 million tonnes by 2030 to 2031, with crude steel output already near 144 to 151 million tonnes per year. At the same time, India's coal-heavy steel sector emits about 2.6 tonnes of CO2 per tonne of steel, well above the global average.

Actions

• The producer modelled possible CBAM costs on its exports to Europe and other climate-active markets.

• It started raising scrap charge in existing EAF lines and explored long-term scrap import deals, despite tight domestic scrap availability.

• It evaluated a DRI plant with the option to shift from natural gas to hydrogen feed over time.

Outcomes

• Short term, metallics costs rose, but the firm kept access to premium export customers who are preparing for carbon-based price adjustments.

• Longer term, the company positioned itself as an early mover among Indian exporters on decarbonization, which will matter as CBAM financial obligations start in 2026 and as buyers favour lower-CO2 products.

Case Study 4: A Trading House Turns Sanctions And Carbon Complexity Into A Service

Background

A mid-tier trading house with offices in Europe and Asia historically treated compliance as a cost centre. Sanctions on Russian steel, tighter bank policies, and growing CBAM and Waste Shipment complexity exposed the weakness of this view.

Actions

• The firm hired a small compliance team and integrated sanctions screening and corridor risk into its trade booking system.

• It repositioned itself with mills and yards as a partner that could handle documentation, CBAM data support, and WSR interpretation.

• It published regular guidance notes for clients and offered structures where the trader took more logistics and compliance risk in return for a higher margin.

Outcomes

• The firm exited some high-risk routes but grew volume in corridors where customers valued the compliance package.

• Gross margin per tonne improved, as mills and yards accepted that high-quality compliance and corridor knowledge justify a premium, especially when dealing with Russian, Black Sea, or CBAM-exposed cargoes.

7. Exhaustive FAQs: Ferrous Export Bans, Sanctions, And Corridors (2025 Lens)

Q1: How often do trade rules affecting ferrous exports actually change now?

In many corridors, meaningful changes still occur every 6 to 18 months. That includes new export licenses, duties, or carbon-linked rules. In "hot" regions facing conflict, election swings, or inflation spikes, policy shifts can appear within weeks. Treat rules as a variable, not a constant.

Q2: What is the biggest mistake exporters make when a new ban appears?

Trying to push existing contracts through unchanged and hoping for lenient enforcement. This often leads to stuck cargoes, storage and demurrage losses, and strained bank relations. A better response is to speak to counterparties at once, adjust shipment timing, prices, routes, or even cancel and re-book under terms that fit the new law.

Q3: How can I tell if a cargo risks secondary sanctions?

Check three levels.

• Entity. Is any party on an official sanctions list.

• Ownership. Does a sanctioned person or entity own a significant share.

• Activity and origin. Does the cargo or route touch a sector or region with sectoral restrictions, such as certain Russian steel products.

If any of these questions raise doubts, get a written view from your bank or legal counsel and avoid trading until you have clarity.

Q4: Are export bans always permanent?

No. Many measures, especially in emerging markets, are temporary tools to calm prices or protect domestic industry and may be relaxed. However, rules anchored in climate and circular economy goals, such as CBAM and the Waste Shipment Regulation, have timelines that run through the 2020s and 2030s. They are more likely to persist or tighten than to vanish.

Q5: What should go into a "regulatory change" clause in a ferrous trade contract today?

Key elements include:

• A clear definition of covered events, such as new duties, bans, licensing rules, sanctions, or carbon charges that hit the contract.

• A process for sharing information and notice periods when changes arise.

• Pre-agreed options such as price adjustments, shipment postponement, rerouting, or termination if the change makes execution illegal or uneconomic.

Q6: How do carbon rules like CBAM change trade decisions in 2025?

During 2024 and 2025, CBAM requires quarterly reporting of embedded emissions in covered products. From January 2026 importers must buy and surrender CBAM certificates. The price links to EU ETS allowances, and free allowances for EU producers will decline through 2034.

Even before the financial impact starts, buyers already ask for CO2 data and recycled content. For exporters, lack of credible emissions data can already lose you a contract.

Q7: Should smaller traders still bother with futures and hedging tools?

Yes, within limits. Many exchanges and brokers now offer smaller lot sizes and margin requirements. Covering even part of your exposure using scrap, rebar, or HRC futures can soften the impact of sudden policy shocks or freight spikes on your margin.

Q8: What data should a yard or trader track weekly to stay ahead?

At minimum:

• Export and import volumes for your main origins and destinations, focusing on EU, Türkiye, India, the Gulf, and Southeast Asia.

• Shipping rates and port congestion on your core routes.

• Policy announcements from the EU, US, UK, China, India, Türkiye, and Gulf states, plus CBAM and Waste Shipment updates.

• Price spreads between scrap, DRI, HBI, pig iron, and finished steel in your core markets.

Q9: How important is traceability for ferrous scrap in 2025?

For high-value contracts and CBAM-exposed routes, traceability has moved from "nice to have" to "expected". That includes lot-level records, yard of origin, photos, weighbridge tickets, and basic CO2 and recycled content data.

Q10: Is it still reasonable to build export-dependent capacity with all this policy risk?

Yes, but only if the business can pivot on corridors, products, and customer mix. Lenders and investors now ask detailed questions about supply risk, carbon exposure, and Waste Shipment and CBAM impacts. Projects that can serve both domestic and export demand, and shift between corridors, are more likely to get financed.

Q11: How do I explain these risks to a bank that sees scrap as "too risky"?

Prepare a short briefing that shows:

• Your corridor and counterparty risk classifications.

• Your sanctions, KYC, and carbon-compliance processes.

• Practical scenarios you have run and how you would respond.

Banks respond better to clear systems and data than to vague assurances.

Q12: Will digital tools and trading platforms replace traditional relationships?

Digital tools will help with discovery, benchmarking, documentation, and CBAM or Waste Shipment reporting. They will not replace trust built through years of performance. In a world of bans and sanctions, counterparties that communicate early, share risk fairly, and solve problems together will still get invited back.

8. Looking Ahead: The Future Of Ferrous Export Corridors

Through 2030 three forces will set the shape of ferrous export corridors: decarbonization, regional industrial policy, and security concerns.

Global crude steel production in 2024 was around 1.88 billion tonnes. Worldsteel expects steel demand in 2025 to be roughly flat at about 1.75 billion tonnes, then to grow by around 1.3 percent in 2026 to about 1.77 billion tonnes. OECD analysis points to global demand reaching roughly 1.96 billion tonnes by 2030, implying slow growth of around 0.7 percent per year.

In parallel, the steel sector will still need to cut direct emissions by roughly a quarter this decade to stay close to net zero paths. That will require more scrap, more EAF capacity, more DRI and HBI, and new near-zero-emission routes.

Several outcomes follow.

• More scrap will remain inside large regulatory blocs such as the EU, and later perhaps other regions that want secure domestic feedstock for green steel. EU scrap exports to third countries were already down to about 17 million tonnes in 2024 from more than 19 million tonnes in 2023.

• Countries that depend heavily on imported scrap, including Türkiye, India, and much of Southeast Asia, will face tighter competition. They will expand domestic scrap collection and invest in DRI, HBI, and pig iron to secure metallics.

• Large producers such as China and India will face increasing pressure to move output toward EAFs and lower-carbon routes while managing power costs, scrap availability, and employment.

For traders, yards, and mills, this does not mean the end of ferrous exports. Trade flows will stay large but become more selective, more conditioned by carbon intensity and traceability, and more sensitive to political alignment and security ties.

The most resilient players in this 2025 landscape will:

• Treat policy, compliance, and carbon as daily disciplines supported by clear data and repeatable routines.

• Build sourcing and sales systems around multiple corridors, product types, and customer segments rather than relying on a single outlet or rule set.

• Invest in trust by sharing risk, communicating clearly when rules change, and providing the documentation and traceability that regulators and end-users now expect.

Ferrous export corridors are now strategic assets and liabilities, not invisible pipes. Companies that track and manage these corridors with the same care they apply to grade, chemistry, and logistics will have a structural advantage through 2030 and beyond.