EN    EN EN 
 
EN    EN  COMMISSION OF THE E UROPEAN COMMUNITIES 
Brussels, 19.11.2008 
SEC(2008) 2847  
  
COMMISSION STAFF WORKING DOCUMENT 
Accompanying document to the 
COMMUNICATION FROM THE COMMISSION 
 
Summary Impact Assessment for an EU strategy for better ship dismantling 
{COM(2008) 767 final} 
{SEC(2008) 2846} 
 
EN 2   EN COMMISSION STAFF WORKING DOCUMENT 
Accompanying document to the 
COMMUNICATION FROM THE COMMISSION 
 
Summary Impact Assessment for an EU strategy for better ship dismantling 
This is a summary of the impact assessment (IA) accompanying the Commission proposal for 
an EU strategy on better ship dismantling.  
The IA identifies the problem as a global market  failure in the sense that the present ship 
recycling market operates under unacceptable c onditions for the environment and workers' 
health in South Asia, and that this failure c oncerns also the EU on account of the high number 
of European-flagged and European-owned ships that go for scrapping to facilities in 
Bangladesh, India or Pakistan. 
The general objective of an EU strategy on ship dismantling is to ensure that ships with a 
strong link to the EU in terms of flag or  ownership are dismantled only in safe and 
environmentally sound facilities worldwide. This  includes as specific obj ectives: to prevent, 
in line with the Waste Shipment Regulation, th e export of hazardous e nd-of-life ships from 
the EU to developing countries and to redu ce significantly and in a sustainable way by 2015 
the negative impacts of shipbreaking, especial ly in South Asia, on human health and the 
environment without creating unnecessary economic burdens.  
Four options were considered to address these objectives: 1) a continuation of the current 
level of EU activities as "baseline", 2) a policy with emphasis on voluntary action by 
shipowners and recycling facili ties, 3) rules to implement ke y provisions of the forthcoming 
IMO Convention and complement it with certain mandatory provisions, a nd 4) an integrated 
policy approach combining selected le gislative and non-legi slative measures. 
The first option  would imply a low level of EU activit y, essentially relying on Member States 
for the implementation of the IMO Ship Recy cling Convention in th e longer term. Taking no 
additional action at EU level would mean in  the short and medium term, until the new 
international regime is in place and transposed by Member States, that the current trends in 
ship dismantling would continue unabated. The problems of enforcement of the Waste 
Shipment Regulation with regard to end-of- life ships and the decommissioning of a ship 
outside the EU waters, will remain unsolved. 
The second option  would favour non-legislative measures  to promote voluntary action by the 
shipping industry, i.e. encourage shipping comp anies to use only safe and environmentally 
sound ship dismantling facilities. It would focus on positive incen tives and not on the stricter 
enforcement of the current EC Waste Sh ipment Regulation. Two sub-options are 
distinguished, according to whether incentives should be used to encourage clean ship dismantling in the EU or candi date countries, or promote be tter practices worldwide. 
The impacts of the actions under Option 2 are summarized in the following table: 
Table 1: Measures to encourage voluntary action and their impacts 
 
EN 3   EN Sub-option  / 
measure Positive impacts 
Affected group or concern: 
Likelihood / intensity Negative impacts 
Affected group or concern: 
Likelihood / intensity Recommended 
selection: 
Sub-option 1: 
Encourage dismantling 
in EU/OECD    
Subsidies for EU 
dismantling Environment + workers' safety 
in South Asia: high / high 
Jobs + revenue in EU recycling 
industry: high / medium 
Fishing in South Asia: 
medium / medium 
 Jobs in South Asia: high / high 
Costs for EU: high / high 
Revenue for industry in S. Asia, 
steel supply (especially 
Bangladesh) : high / high 
Trade relations with South Asia: 
high / high 
Subsidies could lead to distortion of competition and have no 
support in EU state aid rules: high 
/ high  Reject 
    
EU coordination for 
warships Environment + workers' safety 
in South Asia: low  / medium 
Jobs + revenue in EU recycling 
industry: low / medium  Costs for EU navies: low / 
medium  
Environment + workers' safety in 
EU: low / low  Reject  
Sub-option 2: 
Encourage clean 
dismantling worldwide     
Campaign for voluntary 
agreements Environment + workers' safety 
in South Asia: low  / medium (but 
potentially effective in short 
term) 
Jobs + revenue in EU recycling 
industry: low / low  No major impacts Accept  
EU certification & 
audit scheme Environment + workers' safety 
in South Asia: low  / medium   
Jobs + revenue in EU recycling 
industry: low / medium  Costs for shipowners + recycling 
facilities: low / low (or even net 
positive)  Accept  
Award scheme Environment + workers' safety 
in South Asia: medium  / low   
Reputation for EU shipowners + 
other participants: medium / 
medium 
Jobs + revenue in EU recycling 
industry: medium / low  Costs for EU: high / low  Accept  
Technical assistance for 
developing countries Environment + workers' safety 
in South Asia : medium / medium  
Fishing in South Asia:   
medium / medium  Costs for EU: high / low 
Effect on competition:  
medium / low  Accept  
Participation in pilot 
projects Environment + workers' safety 
in South Asia : low / low  
Jobs + revenue in EU recycling No major impacts Accept  
 
EN 4   EN Sub-option  / 
measure Positive impacts 
Affected group or concern: 
Likelihood / intensity Negative impacts 
Affected group or concern: 
Likelihood / intensity Recommended 
selection: 
industry: low / low  
Guidance for 
shipowners (global list 
of dismantling 
facilities) Environment + workers' safety 
in South Asia: medium  / medium  
Jobs + revenue in EU recycling 
industry: medium / medium  Costs for EU research: high / low  
 Accept  
1.1. The actions presented above as accep table would encourage voluntary actions 
by shipowners to improve the worldwide practice of ship dismantling, but will 
not necessarily address the gaps with regar d to end-of-life ships in the current 
EU legislation. 
Under the third option , key elements of the future Ship Recycling Convention (survey and 
certification requirements for ships, essential re quirements for recycling facilities, and rules 
on communication and reporting) w ould be transposed and complemented where necessary to 
fill gaps. Beyond implementation, additional measur es could be envisaged to extend future 
Convention standards to government  vessels of Member States, to require EU-flagged ships 
go only to audited and certified f acilities for dismantling, and to es tablish a list of ships ready 
for scrapping to improve the control system of  the Waste Shipment Regulation for ships. In 
this context, some other possible actions - mo re prohibitions on hazardous materials in ships, 
stricter obligations for pre-cleaning or a ban on beaching - are also assessed. The option 
would cover other measures (guidance doc uments, IMPEL-TFS projects, infringement 
proceedings, cooperation with third countries) to ensure better enforcement of current waste 
shipment law with regard to end-of-life ships. 
The impacts of the actions under Option 3 are summarized in the following table: 
Table 2: Measures on ship recycling and their impacts 
Measure Positive impacts 
Affected group or concern: 
Likelihood / intensity  Negative impacts 
Affected group or 
concern:  
Likelihood / intensity  Recommended 
selection 
Measures to implement 
the IMO Ship Recycling Convention    
Inventory of Hazardous 
Materials, surveys and 
certificates Early harmonization of safety 
rules in EU would  
- establish level playing field  
- reduce costs for shipowners + 
shipyards - increase effectiveness of health 
+ safety controls:  
medium / medium  No additional costs in relation 
to baseline (IMO Convention) Accept  
Requirements for ship 
recycling facilities No major impacts, potential 
reduction of costs for 
Management Plan No additional costs in relation 
to baseline (IMO Convention) Accept  
 
EN 5   EN Measure Positive impacts 
Affected group or concern: 
Likelihood / intensity  Negative impacts 
Affected group or 
concern:  
Likelihood / intensity  Recommended 
selection 
Information duties of 
recycling states Transparency, more effective 
implementation:  
 medium / medium  Additional administrative 
burden for MS: 
 medium / low  Accept  
Reporting requirements 
for shipowners + recycling facilities No major impacts, potential 
reduction of costs by rule on single contact point No additional costs in relation 
to baseline (IMO Convention) Accept  
Complementing 
measures     
Extension of rules to 
government vessels - Environment + workers' safety 
in South Asia,  - Jobs + revenue in EU recycling 
industry:  
 medium / medium 
(higher if additional rules on 
sale of ships)  Costs for EU navies:  
medium  / medium  
Environment + workers' safety 
in EU: 
low / low 
Jobs + revenue in South Asian 
facilities:  medium/low  Accept  
More extensive bans on 
hazardous materials Marine environment : 
 high / high 
Workers' safety + health:  
 high / medium  Interference with EU product 
legislation: 
 high / high 
Competitive position of EU 
ship suppliers: 
 medium / high 
Effectiveness of risk 
investigations: 
 medium / medium Reject 
Stricter pre-cleaning 
obligations for EU-flagged ships Environment + workers' safety 
in South Asia, low / medium  
- Jobs + revenue in EU recycling 
industry: low / medium   Costs for shipowners: 
 medium / medium  
Re-flagging of EU ships: 
 high / medium  
Additional risks of accidents en 
route + for safety/ environment 
in SouthAsia : 
 low / medium Reject  
(as ineffective) 
Ban on beaching for EU-flagged ships Environment + workers' safety 
in South Asia, low / medium  
- Jobs + revenue in EU recycling 
industry: low / medium  Costs for shipowners:  
 low / medium  
Re-flagging of EU ships: 
 high / medium  Reject  
(as ineffective) 
Obligation for EU-
flagged ships to use 
only certified facilities  Environment + workers' safety 
in South Asia: medium  / medium  
- Jobs + revenue in EU recycling 
industry: low / medium 
- Jobs + revenue in class 
societies : 
medium / medium  Costs for shipowners + 
recycling facilities: 
medium / medium 
Re-flagging of EU ships: 
medium / medium  Accept  
List of ships ready for Pr evention of hazardous waste 
ship exports from EU:  Administrative burden for 
shipowners:  Accept  
 
EN 6   EN Measure Positive impacts 
Affected group or concern: 
Likelihood / intensity  Negative impacts 
Affected group or 
concern:  
Likelihood / intensity  Recommended 
selection 
scrapping medium / medium  
Marine safety + environment 
(prevention of accidents) in EU: 
medium / medium 
Environment + workers' safety 
in South Asia:  low / medium   low / low (higher for owners of 
older ships)  
Admin. burden for authorities:  
 medium / medium   
Loss of revenue for EU transit 
ports in the Mediterranean:  
 medium / medium  
WSR enforcement 
measures     
Guidance document on 
waste ships Prevention of hazardous waste 
ship exports: medium / medium   
Environment + workers' safety 
in South Asia:  low / medium  Administrative burden for EU 
+ Member States: high / low  Accept 
IMPEL-TFS project Preven tion of hazardous waste 
ship exports: medium / medium   
Environment + workers' safety 
in South Asia:  low / medium  Administrative burden for EU 
+ Member States: high / low  Accept 
Infringement 
proceedings Prevention of hazardous waste 
ship exports: medium / high   
Environment + workers' safety 
in South Asia:  low / medium  Costs for EU + MS: low / low  Accept 
Cooperation with third 
countries Prevention of hazardous waste 
ship export, transit and import:  low / medium  (countries of 
destination), medium / medium  
(Egypt)  
Environment + workers' safety 
in South Asia:  low / medium  Administrative burden for EU 
+ Member States:   high / medium  Accept 
 
The fourth option  combines a selection of rules under option 3 with certain supporting 
actions under option 2 in an integrated policy approach. This would include rules to implement, as a priority, key elements of the envisaged Ship Recycling Convention as soon as 
adopted by the IMO diplomatic conference fores een to take place in May 2009, in particular 
provisions concerning surveys and certificates fo r ships, essential requirements for recycling 
facilities and rules on reporting and communication. It would also include rules for the clean 
dismantling of warships and other government vessels and on certified dismantling facilities, 
and a list of ships ready for scrapping. S upporting actions would mean a range of non-
legislative measures, such as a campaign for voluntary commitments, streamlining of shipping 
aids, certification and award sc hemes, and technical assistan ce to developing countries, but 
not subsidies for ship dismantling in the EU.  
Table 3: Net impacts of measures unde r Option 4 (integrated policy approach) 
 
EN 7   EN Measure Positive impacts 
 Negative impacts 
 Net impact / 
interference 
 
Inventory of 
Hazardous 
Materials, surveys 
and certificates Early harmonization of 
safety rules in EU would  
- establish level playing 
field  - reduce costs for 
shipowners + shipyards 
- increase effectiveness of health + safety controls:  
medium / medium  No additional costs in 
relation to baseline (IMO 
Convention) Medium positive impact; no 
interferences expected.  
Requirements for ship recycling facilities No major impacts, potential 
reduction of costs for Management Plan No additional costs in 
relation to baseline (IMO Convention) Minor positive impact; 
no interferences expected. 
Information duties 
of recycling states Transparency, more 
effective implementation  Minor additional burden 
for MS Minor positive impact;  
no interferences expected. 
Reporting 
requirements for 
shipowners + 
recycling facilities No major impacts, potential 
reduction of costs by rule 
on single contact point No additional costs in 
relation to baseline (IMO 
Convention) Minor positive impact;  
no interferences expected.  
Extension of rules to government 
vessels Less pollution + health 
impacts from contaminated 
warships in South Asia,  
More jobs + revenue in EU 
recycling industry: Higher costs / less revenue 
for EU navies 
Possibly minor impacts on 
jobs + revenue in South Asia 
Possibly minor impacts on 
environment + workers' safety in EU  Medium positive impact;  
no interferences expected. 
Obligation to use 
only certified 
facilities  Less pollution + health 
impacts from EU-flagged 
ships in South Asia 
More jobs + revenue in 
certified facilities, possibly 
in EU  
More jobs + revenue in 
classification societies : Higher costs / less revenue 
for shipowners, minor 
certification costs for recycling facilities 
Possibly out-flagging of 
EU ships Medium positive impact, if 
no major out-flagging. 
Combination with campaign for voluntary action/CSR 
necessary. 
List of ships ready 
for scrapping. 
 Prevention of hazardous 
waste ship exports from EU 
Contributes to protection of 
marine environment by less 
old ships + accidents in EU 
waters  
Minor impact on 
environment + workers' 
safety in South Asia More administrative 
burden for authorities and owners of older ships 
through monitoring + 
controls 
Loss of revenue for EU 
transit ports in the Mediterranean: Medium positive impact. 
Could interfere with encouragement for voluntary 
actions by shipowners. 
WSR enforcement 
measures     
- Guidance 
document on waste Better compliance with 
WSR / prevention of 
hazardous waste ship More administrative 
burden for authorities and 
owners of older ships Medium positive impact. 
Rigid execution of measures 
could interfere with 
 
EN 8   EN Measure Positive impacts 
 Negative impacts 
 Net impact / 
interference 
 
ships 
- IMPEL-TFS 
project 
- Infringement 
proceedings exports from EU  
Minor impact on 
environment + workers' 
safety in South Asia through additional 
controls  encouragement for voluntary 
actions. 
Cooperation with 
third countries 
(countries of destination + 
transit) Possibly better compliance 
with Basel Convention / 
prevention of hazardous waste ship export, transit 
and import: 
Possibly medium impact on 
environment + workers' 
safety in South Asia More administrative 
burden for EU + Member 
States Potentially medium positive 
impact, but successful 
cooperation with countries of destination not likely. No 
interferences expected. 
Measures for 
voluntary actions    
Streamlining 
existing shipping 
aids Better compliance with 
WSR / prevention of 
hazardous waste ship exports from EU  
Minor impact on 
environment + workers' safety in South Asia  
More jobs + revenue in EU 
recycling industry  
 Higher costs / less revenue 
for ferry operators:  
 Medium positive impact; no 
interferences expected 
Campaign for voluntary 
agreements with shipowners Possibly medium impacts 
on environment + workers' 
safety in South Asia, especially in short term  No major impacts Potential for positive impact, 
especially in short term. 
Interference by legislative + enforcement measures 
possible. 
Award scheme Minor impact on 
environment + workers' safety in South Asia  
Better reputation for EU 
shipowners + other participants 
Possibly more jobs + 
revenue in EU recycling 
industry Minor costs for EU + 
industry participants (but presupposes already high 
standards). Medium positive impact; if 
transparent + broad scheme no interferences expected. 
Technical assistance for developing 
countries Possibly medium impacts 
on environment + workers' safety in South Asia  
Possibly better conditions 
for local fishermen in South Asia:   Costs for EU funds  
Possibly distortion of 
competition with other 
recycling states  
 Potential for positive impact, 
dependent on cooperation from recycling state. No 
interferences expected. 
Participation in pilot projects Minor impacts on 
environment + workers' No major impacts Minor positive impact. No 
interferences expected. 
 
EN 9   EN Measure Positive impacts 
 Negative impacts 
 Net impact / 
interference 
 
safety in South Asia 
Guidance for 
shipowners (global 
list of "green" 
dismantling facilities) Possibly medium impacts 
on environment + workers' 
safety in South Asia  
Possibly more jobs + 
revenue in EU recycling 
industry No major impacts 
 Medium positive impact. No 
interferences expected. 
 
The impact analysis of these options presents an assessment of environmental, social and 
economic impacts. It gives an indication on the extent to which each of the options can resolve the problem, and discusses the costs and possible drawbacks. As the Communication 
on an EU ship dismantling strategy does not represent a concrete legislative proposal, 
and that the impacts of such measures th at may be adopted subsequently will be 
analysed in detail in separate IAs, the level of analysis is deemed proportionate at this 
stage. 
The conclusion of this IA is that the fourth option (integrated policy ap proach) is preferable, 
as it is the only one that can achieve altoge ther positive environmental, social and economic 
impacts in the short and medium as well as in the long term. This option would ensure a high 
level of compliance with current waste shipme nt law and reduce significantly in the next 
years the negative impacts of sh ipbreaking on human health and the environment, especially 
in South Asia, without creating excessive burden on EU taxpayers.