EU Ship Recycling Regulation: Progress, Challenges, and the Path Forward

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  • The European List of authorised ship recycling facilities has become a global benchmark.
  • The 14th edition of the European List includes additions in Netherlands and Türkiye.
  • The list now comprises 43 facilities, with 31 in Europe, 11 in Türkiye, and 1 in the US.

On 19 February, the European Commission published the results of the EU Ship Recycling Regulation (SRR) evaluation. The evaluation verifies that the Regulation has overall been successful in its aims, notably through the creation of the European List of approved ship recycling facilities. The list has helped to improve environmental and social standards in ship recycling and has emerged as a leading benchmark for stakeholders and authorities inside and outside the EU, reports Safety4Sea.

Challenges and Limitations

In spite of these successes, the Regulation’s effectiveness has been to a large extent undermined by some industry practice. One of the principal challenges is the common strategy of shipowners reflagging a vessel from an EU Member State to a non-EU flag shortly before recycling. This change is economically driven, enabling shipowners to dispose of their end-of-life ships to shipbreaking facilities in South Asia, where there are fewer regulatory standards and greater profits. Moreover, hazardous materials inventories continue to be a chronic problem. Most ships lack proper stockpiles, and even when they exist in the recycling phase, they are of poor quality, which complicates effective monitoring and safe breaking.

Next Steps for Regulation

The review precedes the Hong Kong Convention’s entry into force in June 2025, a global treaty that establishes ship recycling norms that in certain respects are lower than the SRR’s. The European Commission intends to consider how the convention will be implemented and if it can be reinforced to match more closely with EU standards. Parallel to this, the Commission will closely follow up on the application of the SRR and work in concert with Member States, non-EU States, and interested parties to discourage EU-flagged ships from avoiding recycling in their yards. Clarity on the regulation requirements as well as strict adherence to enforceable penalties will also be promoted through efforts.

Revisions of the European List of Recycling Facilities

On 18 February, the European Commission adopted the 14th edition of the European List of ship recycling facilities. The revision added one new yard in the Netherlands and one in Türkiye, and removed three facilities in Latvia, Lithuania, and Türkiye. Consequently, the European List now includes 43 approved recycling plants, 31 of which are in Europe (the EU, Norway, and the UK), 11 in Türkiye, and one in the United States.

While European shipowners own about 30% of the world’s fleet by tonnage, much of these are broken down outside the EU. Most of them find their way to South Asia, where working conditions in breaking ships are commonly dangerous to people and the environment.

Lessons Learned and Future Considerations

Re-flagging is still the most serious issue in implementing the SRR. To solve this problem successfully, it has to be clarified how ships that are to be recycled are to be identified and who should take responsibility for guaranteeing compliance. The present role of cash buyers, who mediate the end-of-life ships’ sale, makes enforcement more difficult. Adequate mechanisms must be investigated so that shipowners cannot bypass their duties so that ships owned by the EU are recycled by the standards set.

Among the possible solutions being debated is presenting a financial incentive, as described in Article 29 of the SRR. This might be in the form of a ship recycling permit for all ships visiting EU ports, closing the economic gap between breaking up ships at EU-listed yards and those breaking up under unsafe and environmentally destructive conditions. Another idea is to transfer responsibility from the registered owner, linked to a ship’s flag, to the beneficial owner, making it more difficult for shipowners to avoid their responsibilities by re-flagging. Yet these concepts have caused a great deal of discussion among parties, and their prospective implications are worth further examination.

Harmonised Worldwide Recycling Requirements

The potential to enhance the Hong Kong Convention via SRR provisions has been proposed by shipowner associations and certain EU Member States as a good next step toward more ambitious and harmonized worldwide recycling requirements. In addition, it is important to see that SRR standards remain fair and efficient for EU-listed facilities. Additional improvements may include the establishment of more criteria for measuring waste management and steel recovery operations, the application of more stringent pollution control measures, and the use of cleaner dismantling and recycling technologies.

To enhance the accuracy of hazardous materials inventories, there should be an increase in oversight throughout the whole chain of responsibility. This involves boosting the qualifications of specialists who create these inventories, enhancing the process of procuring materials and suppliers’ statements, and creating enhanced guidance and investigative materials for regulatory enforcement.

Entry into Force of the Hong Kong Convention

Making the SRR enforceable will necessitate EU Member States to enact clear and enforceable sanctions for breach. The sanctions must be sufficiently punitive to deter breaches. More clarity is also necessary on how the SRR relates to other legal regimes.

With the imminent entry into force of the Hong Kong Convention, there is also a chance to simplify reporting and certification requirements, minimizing administrative costs while ensuring regulatory effectiveness. Lastly, a future revision of the SRR can explore how the Regulation can more harmoniously contribute to wider EU goals, such as competitiveness, resilience, and climate neutrality. This can be achieved by incorporating circular economy thinking, encouraging the use of resources efficiently, and consolidating the EU’s leadership in sustainable and responsible ship recycling.

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Source: Safety4Sea