BEFESA ZINC US INC

Befesa Zinc US Inc, the U.S. subsidiary of Luxembourg-listed Befesa S.A. acquired from American Zinc Recycling Corp in August 2021, operates four EPA-registered facilities that recycle electric arc furnace dust (EAFD) into zinc and iron products [source: https://images.befesa.com/media/2021/10/Befesa-ZInc-US.pdf]. EPA ECHO data as of 4 May 2026 records 14 quarterly violations across the preceding 24 months and derived penalties totaling $4,091,400 across the four-facility footprint, with the most recent permit action dated 5 November 2024 [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. The Palmerton, Pennsylvania plant at 900 Delaware Ave carries a cumulative five-year penalty load of $10,228,500 across Clean Air Act, Clean Water Act, and RCRA hazardous-waste programs, with three formal enforcement actions and 19 violation quarters on record [source: https://pollutionscan.com/facility/110000603749/befesa-zinc-us-inc-palmerton-pa].

Separately, the Chicago facility at 2701 East 114th Street is the subject of a certified class action — Koziol v. Befesa Zinc US Inc., No. 1:24-cv-01310 (N.D. Ill.) — now in court-approved settlement administration under Illinois's Genetic Information Privacy Act. That is a workplace-privacy matter, not an environmental enforcement action, yet it surfaces alongside a 7 November 2025 Illinois EPA Environmental Justice notification letter confirming that the same Chicago site is seeking a construction permit to authorize an additional mode of rotary kiln operation for up to 30 days per year [source: https://epa.illinois.gov/content/dam/soi/en/web/epa/topics/environmental-justice/documents/notification-letters/Befesa%20Zinc%20US%20Inc%20031600AFV%20Construction%2025100023.pdf] [source: https://www.bzusgipasettlement.com/]. Parent-company Q1 2026 results showed adjusted EBITDA of €58 million on €285 million revenue, a margin of 20.3%, against an 8% year-over-year sales decline [source: https://in.investing.com/news/stock-market-news/befesa-reports-improved-margins-despite-lower-volumes-in-first-quarter-93CH-5368364]. Those financials reflect a business expanding U.S. capacity even as its flagship Pennsylvania plant accumulates one of the heavier five-year penalty totals in the secondary-zinc processing sector.

Befesa Zinc US's U.S. footprint comprises four EPA-tracked facilities under FRS registry IDs 110000603749 (Palmerton, PA), 110070266043, 110000434352, and 110040451533, covering Clean Air Act, Clean Water Act, and RCRA hazardous-waste programs [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. The Palmerton site at 900 Delaware Ave is designated a major facility under all three programs and holds an active RCRA hazardous-waste handler registration. EPA's Compliance History module logs 12 inspections, 19 violation quarters, and three formal actions over the five-year window, with cumulative penalties of $10,228,500 [source: https://pollutionscan.com/facility/110000603749/befesa-zinc-us-inc-palmerton-pa]. The Bartlesville, Oklahoma site (RCRA ID OKD000829440), inherited from the American Zinc Recycling Corp transaction, retains open hazardous-waste corrective-action interest under EPA's CIMC system [source: https://ofmpub.epa.gov/apex/cimc/f?p=CIMC%3ARCRA%3A%3A%3A%3A%3AP14_RCRA_HANDLER_ID%3AOKD000829440].

The 24-month compliance picture begins deteriorating in late 2023. ECHO's quarterly compliance history for Palmerton logs a sequence of unresolved Clean Air Act violation quarters, followed by escalating RCRA non-compliance markers that continued through 2024 and into 2025 [source: https://pollutionscan.com/facility/110000603749/befesa-zinc-us-inc-palmerton-pa]. Clean Water Act compliance at Palmerton then worsened during the second half of the window, shifting from resolved-status quarters in 2023 to violation quarters across the four most recent reporting periods [source: https://pollutionscan.com/facility/110000603749/befesa-zinc-us-inc-palmerton-pa]. On 5 November 2024, the most recent permitting action on file across the four U.S. facilities was recorded in ECHO's permit layer [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. On 7 November 2025, the Illinois EPA Bureau of Air issued an Environmental Justice notification letter for application 25100023 at the 2701 East 114th Street Chicago plant, confirming that the company had applied for a construction permit authorizing an additional mode of rotary-kiln operation limited to 30 operating days per year [source: https://epa.illinois.gov/content/dam/soi/en/web/epa/topics/environmental-justice/documents/notification-letters/Befesa%20Zinc%20US%20Inc%20031600AFV%20Construction%2025100023.pdf].

EPA TRI Explorer continues to list the Palmerton plant (TRIF ID 18071HRSHDDELAW) and the Chicago plant (TRIF ID 60617HRSHD2701E) as active Form R reporters in the 2024 dataset released November 2025, indicating ongoing obligations to disclose listed-chemical releases and off-site transfers [source: https://enviro.epa.gov/triexplorer/release_fac_profile?TRI=18071HRSHDDELAW&TRILIB=TRIQ1&V_NA_INDICATOR=.&FLD=&FLD=RELLBY&FLD=TSFDSP&OFFDISPD=&OTHDISPD=&ONDISPD=&OTHOFFD=&YEAR=2020] [source: https://enviro.epa.gov/triexplorer/release_fac_profile?FLD=&FLD=RELLBY&FLD=TSFDSP&OFFDISPD=&ONDISPD=&OTHDISPD=&OTHOFFD=&TRI=60617HRSHD2701E&TRILIB=TRIQ1&V_NA_INDICATOR=.&YEAR=2017]. The aggregate ECHO-derived 24-month penalty figure of $4,091,400 reflects a straight-line 24/60 allocation of the five-year total [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip].

Palmerton, PA (FRS 110000603749, 900 Delaware Ave, Carbon County): EPA ECHO's Compliance History module records three formal enforcement actions over the trailing five years under the combined Clean Air Act, Clean Water Act, and RCRA programs. Cumulative penalties assessed across those actions total $10,228,500. The facility's PollutionScan composite grade is reported as 'F' at 21/100, reflecting 19 violation quarters on a per-program basis and 12 inspections [source: https://pollutionscan.com/facility/110000603749/befesa-zinc-us-inc-palmerton-pa]. The CAA track shows one formal action with two evaluations on file. The RCRA track shows sustained unresolved-violation markers through the majority of the trailing 12 quarters [source: https://pollutionscan.com/facility/110000603749/befesa-zinc-us-inc-palmerton-pa]. Clean Water Act quarters that resolved cleanly in 2023 had moved back into violation status by the most recent four reporting periods — a directional shift that the ECHO data captures clearly.

Chicago, IL (2701 E 114th Street, Cook County, TRIF 60617HRSHD2701E): no new federal consent decree is posted in the research bundle, but the Illinois EPA's 7 November 2025 EJ notification for BOA ID 031600AFV, application 25100023, documents the company's request to authorize an additional mode of rotary kiln operation limited to 30 days per year, triggering EJ-area community review procedures [source: https://epa.illinois.gov/content/dam/soi/en/web/epa/topics/environmental-justice/documents/notification-letters/Befesa%20Zinc%20US%20Inc%20031600AFV%20Construction%2025100023.pdf]. That review process is ongoing as of the briefing date.

Bartlesville, OK (RCRA ID OKD000829440, formerly American Zinc Recycling Corp): EPA's Cleanups in My Community module retains an active RCRA corrective-action profile covering the entire facility, with institutional-control and engineering-control indicators flagged as 'ENTIRE FACILITY' [source: https://ofmpub.epa.gov/apex/cimc/f?p=CIMC%3ARCRA%3A%3A%3A%3A%3AP14_RCRA_HANDLER_ID%3AOKD000829440]. The ECHO exporter assigns the Bartlesville site to FRS 110000434352 and includes it in the 14-quarter, $4,091,400 24-month rollup for the corporate parent [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. Aggregated data source and derivation: violation counts are min(quarters-with-non-compliance, 8) per facility; penalty totals are the five-year total scaled by 24/60 [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip].

Palmerton, Pennsylvania — 900 Delaware Ave (FRS 110000603749): the company's largest U.S. EAFD recycling plant, classified as a major facility under CAA, CWA, and RCRA. EPA and PollutionScan data show 12 inspections, 19 violation quarters, and three formal actions in the five-year window, with $10,228,500 in cumulative penalties [source: https://pollutionscan.com/facility/110000603749/befesa-zinc-us-inc-palmerton-pa]. TRI Explorer confirms active Form R reporting under TRIF 18071HRSHDDELAW [source: https://enviro.epa.gov/triexplorer/release_fac_profile?TRI=18071HRSHDDELAW&TRILIB=TRIQ1&V_NA_INDICATOR=.&FLD=&FLD=RELLBY&FLD=TSFDSP&OFFDISPD=&OTHDISPD=&ONDISPD=&OTHOFFD=&YEAR=2020]. Carbon County's location in a post-industrial corridor means the plant operates under heightened state and federal scrutiny across all three major environmental programs simultaneously.

Chicago, Illinois — 2701 East 114th Street (TRIF 60617HRSHD2701E, Cook County): located in an EPA- and IEPA-designated environmental-justice area on the Southeast Side. Illinois EPA issued an EJ notification letter on 7 November 2025 regarding construction permit application 25100023 for an additional rotary-kiln operating mode [source: https://epa.illinois.gov/content/dam/soi/en/web/epa/topics/environmental-justice/documents/notification-letters/Befesa%20Zinc%20US%20Inc%20031600AFV%20Construction%2025100023.pdf]. TRI Explorer lists six Form R submissions for the 2017 reporting year under public contact Don Norton [source: https://enviro.epa.gov/triexplorer/release_fac_profile?FLD=&FLD=RELLBY&FLD=TSFDSP&OFFDISPD=&ONDISPD=&OTHDISPD=&OTHOFFD=&TRI=60617HRSHD2701E&TRILIB=TRIQ1&V_NA_INDICATOR=.&YEAR=2017].

Bartlesville, Oklahoma — RCRA ID OKD000829440 (formerly American Zinc Recycling Corp / Horsehead): retains active RCRA corrective-action status in EPA's CIMC system, with institutional- and engineering-control indicators flagged facility-wide [source: https://ofmpub.epa.gov/apex/cimc/f?p=CIMC%3ARCRA%3A%3A%3A%3A%3AP14_RCRA_HANDLER_ID%3AOKD000829440]. The corrective-action obligations transferred to Befesa with the August 2021 acquisition and remain unresolved in the federal registry.

Befesa Zinc Metal, LLC (FRS 110055619399): listed in EPA's Facility Registry Service with separate environmental-interest records for ICIS, RCRAInfo, and TRI information systems, indicating a fourth U.S. operational or legal-entity node in the federal registry [source: https://frs-public.epa.gov/ords/frs_public2/fii_query_dtl.disp_program_facility?p_registry_id=110055619399].

Fourth ECHO-listed facility (FRS 110040451533): included in the four-facility exporter rollup. Detailed per-facility profile data for this site are not disclosed in the research bundle beyond its inclusion in the 14-violation, $4,091,400 24-month aggregate [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip].

The ECHO exporter's top_pollutants field for Befesa Zinc US returns empty in the 4 May 2026 snapshot, but the company's TRI Form R profiles and the EAFD feedstock composition identify the primary regulated releases [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. Electric arc furnace dust — the feedstock processed at Palmerton and Chicago — contains zinc, lead, cadmium, and chromium as metal constituents. EPA's TRI Explorer profile for Palmerton (TRIF 18071HRSHDDELAW) documents Form R submissions covering these listed metals and metal compounds [source: https://enviro.epa.gov/triexplorer/release_fac_profile?TRI=18071HRSHDDELAW&TRILIB=TRIQ1&V_NA_INDICATOR=.&FLD=&FLD=RELLBY&FLD=TSFDSP&OFFDISPD=&OTHDISPD=&ONDISPD=&OTHOFFD=&YEAR=2020]. Lead carries well-characterized neurodevelopmental toxicity and is both a listed hazardous air pollutant and an RCRA D008 toxicity-characteristic waste. Cadmium is classified as a probable human carcinogen. Both metals appear in EAFD at concentrations that place the dust itself in the RCRA hazardous-waste category — the regulatory foundation for the corrective-action obligations at Bartlesville and the hazardous-waste handler registration at Palmerton.

Air-pathway exposure concerns concentrate at the Chicago Southeast Side plant, where the Illinois EPA's November 2025 EJ notification explicitly flags the facility's location within an environmental-justice area and triggers enhanced community review of the rotary-kiln construction permit [source: https://epa.illinois.gov/content/dam/soi/en/web/epa/topics/environmental-justice/documents/notification-letters/Befesa%20Zinc%20US%20Inc%20031600AFV%20Construction%2025100023.pdf]. Hazardous-waste corrective-action obligations at the Bartlesville, OK former AZR/Horsehead site extend RCRA groundwater and soil exposure monitoring across the entire facility [source: https://ofmpub.epa.gov/apex/cimc/f?p=CIMC%3ARCRA%3A%3A%3A%3A%3AP14_RCRA_HANDLER_ID%3AOKD000829440].

The parent-company ESG disclosure frames these residue streams in tonnage terms: total residues managed or recycled reached 1,845 kilotonnes in 2022, with Scope 1+2+3 emissions of 1,412 ktCO₂e and water consumption of 3,085 thousand cubic meters — the first ESG report to incorporate the U.S. EAFD operations acquired in 2021 [source: https://befesaesgreport.com/assets/pdfs/Befesa_ESG_Progress_Report_2022_Environmental_performance_2022.pdf].

The NAICS 331492 (secondary smelting, refining, and alloying of nonferrous metal except copper and aluminum) peer benchmark returned no comparable records in the research bundle, so a direct penalty-ranked peer table cannot be constructed from the available data [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. Contextually, Befesa Zinc US is described by the parent company as 'the US market leader in providing electric arc furnace steel dust (EAFD) recycling services' following the August 2021 acquisition of American Zinc Recycling Corp [source: https://images.befesa.com/media/2021/10/Befesa-ZInc-US.pdf]. That structural concentration matters for benchmarking: the U.S. EAFD recycling sub-segment is narrow enough that pulling NAICS 331492 peers would draw in broader secondary-zinc and specialty-alloy smelters rather than direct EAFD competitors. Absent a populated peer set, the $4,091,400 24-month penalty total and 14 quarterly violations are most meaningfully read against the company's own prior-period compliance trend at Palmerton rather than against cross-company comparators [source: https://pollutionscan.com/facility/110000603749/befesa-zinc-us-inc-palmerton-pa].

Befesa Zinc US Inc is a private subsidiary of Luxembourg-domiciled Befesa S.A. and does not file a U.S. Form 10-K; the SEC 10-K and 10-Q bundles supplied for this briefing are empty, and no CIK is on file [source: https://echo.epa.gov/files/echodownloads/echo_exporter.zip]. Forward-looking environmental risk disclosure available in the research bundle is confined to the parent-company strategic deck. That deck, presented at the ODDO BHF London Forum in September 2025, identifies China operations break-even, U.S. operations expansion, deleveraging from 2.9× to 2.8×, and business-plan resiliency as the stated risk-and-strategy items [source: https://images.befesa.com/media/2025/09/Befesa_Business_Strategic_Update_ODDO_BHF_London_Forum-68cbaf77dc810.pdf]. None of the U.S. facility-level enforcement exposures — Palmerton's $10,228,500 five-year penalty load, the Bartlesville corrective-action obligations, or the Chicago EJ permit review — appear as discrete line items in that disclosure. Q1 2026 parent reporting noted an 8% year-over-year sales decline with margin expansion to 20.3% and adjusted EBITDA of €58 million, 4% below the €61 million consensus [source: https://in.investing.com/news/stock-market-news/befesa-reports-improved-margins-despite-lower-volumes-in-first-quarter-93CH-5368364].