Green Paper On better ship dismantling {SEC(2007) 645}
Date: 2007-05-22
Institutions: European Commission
Subjects: environmental protection, environmental standard, export of waste, hazardous waste, international standard, public health, vessel, waste recycling

COMMISSION OF THE EUROPEAN COMMUNITIES 

Brussels, 22.5.2007 
COM(2007) 269 final 

GREEN PAPER 

On better ship dismantling  

(presented by the Commission) 

{SEC(2007) 645} 

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GREEN PAPER 

On better ship dismantling  

1. 

INTRODUCTION: 
PROBLEM 

EUROPE'S  CONTRIBUTION  TO  TACKLING  A  WORLDWIDE 

The  dismantling  of  ships  in  the era  of  globalisation  is  a  reason  for  concern.  At  present  it  is 
sustainable  from  a  narrow  economic  point  of  view,  but  the  costs  for  human  health  and  the 
environment are high. A radical change is needed as soon as possible. 

•  Each year between 200 and 600 sea-going ships of over 2 000 dead weight tons (dwt) are 
dismantled  worldwide.  A  peak  is  expected  in  2010  when  around  800  single-hull  tankers 
will have to be phased out. 

•  Nowadays two thirds or more of these ships are dismantled on beaches and river banks on 
the  Indian  sub-continent,  with  Bangladesh  currently  holding  the  largest  share  of  the 
market. 

•  Between  2001  and  2003  14%  of  the  ships  that  went  for  scrapping  flew  the  flags  of  EU 
Member States and 18% the flags of states which acceded to the EU in 2004. At least 36% 
of world shipping tonnage in 2006 was owned by companies domiciled in the EU. 

•  Approximately 100 warships and other government vessels flying EU flags - most of them 
French  and  British  -  are  expected  to  be  decommissioned  in  the  next  10  years.  The  naval 
vessels  that  were  built  between  the  1960s  and  the  early  1980s  contain  relatively  high 
quantities of asbestos and other hazardous materials. 

•  From  the  ships  scrapped  between  2006  and  2015  an  estimated  5.5  million  tonnes  of 
materials of potential environmental concern will end up in dismantling yards (in particular 
oil sludge, oils, paints, PVC and asbestos). 

•  None of the sites used for ship dismantling on the Indian sub-continent has containment to 
prevent pollution of soil and water, few have waste reception facilities, and the treatment 
of waste rarely conforms to even minimum environmental standards. 

•  Ship scrapping is an important source of raw materials in South Asia. Bangladesh derives 
80-90%  of  its  steel  from  end-of-life  ships.  The  prices  paid  for  them  by  ship-breaking 
companies are now well in excess of $400 per light displacement ton (ldt) in Bangladesh 
and thus considerably higher than in other countries. 

•  Ship-breaking is a dangerous activity. According to a recent Indian report, one in six of the 
workers  at  Alang,  India's  largest  dismantling  site,  is  suffering  from  asbestosis.  The  fatal 
accident  rate  is  said  to  be  six  times  higher  than  in  the  Indian  mining  industry.  In 
Bangladesh  some  200  ship-breaking  workers  died  in  accidents  between  1998  and  2003. 
NGOs estimate the total death toll from ship scrapping at several thousands, and this will 
increase  considerably  as  more  inexperienced  labourers  are  recruited  to  deal  with  peak 
numbers of single-hull tankers in the coming years. 

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•  At present there is "green" ship recycling capacity, i.e. conforming to environmental and 
safety standards, to handle at most 2 million ldt/year worldwide, which is around 30% of 
the predicted total scrapping demand in normal years. Most of these facilities - particularly 
in China, but also in some EU Member States - find it difficult to operate, as they cannot 
offer  the  same  scrap  prices  and  have  much  higher  costs  than  their  competitors  in  South 
Asia. 

In principle, the transfer of end-of-life ships from industrial to developing countries is covered 
by international law on the shipment of waste, and the export from the European Community 
of vessels containing hazardous materials is banned by the EC's Waste Shipment Regulation. 
However, in recent years several high-profile cases of European ships going for recycling to 
South Asia have shown the problems of implementing this legislation.  

These  obvious  deficiencies  and  the  failure  to  provide  for  socially  and  environmentally 
sustainable  ship  dismantling  have  alerted  the  international  public  and  created  political 
momentum.  The  International  Maritime  Organisation  -  IMO  -  has  started  to  work  on  an 
international  convention  for  the  safe  and  environmentally  sound  recycling  of  ships.  Some 
maritime countries, such as the UK, are developing national strategies for government vessels 
and  ships  flying  their  flag.  The  European  Parliament  and  non-governmental  organisations 
have demanded action at EU level.  

In  its  conclusions  of  20  November  2006  the  Council  of  the  EU  acknowledged  that 
environmentally sound management of ship dismantling is a priority for the European Union. 
It stated that recent events and forecasts of tonnages to be dismantled in the near future call 
for  urgent  and  appropriate  action  from  the  international  community,  including  the  EU.  The 
Council welcomed the Commission's intention to work towards an EU-wide strategy on ship 
dismantling.  This  strategy  should  strengthen  the  enforcement  of  existing  Community  law, 
recognising  the  specificity  of  the  maritime  world,  developments  taking  place  therein, 
particularly in international maritime legislation, and the final objective of reaching a globally 
sustainable solution. In this context, the Commission is invited to assess the need for building 
up sufficient ship dismantling capacity in the EU. 

The Commission already set out its position in the Green Paper on Maritime Policy of June 
20061. It proposed that a future EU maritime policy should support initiatives at international 
level to achieve binding minimum standards on ship recycling and promote the establishment 
of  clean  recycling  facilities.  However,  the  EU  might  also  have  to  pursue  a  set  of  regional 
initiatives  to  account  for  the  gaps  in  the  forthcoming  international  regime  and  the  possible 
delay until it becomes effective. 

This  Green  Paper  attempts  to  come  up  with  fresh  ideas  on  ship  dismantling,  in  order  to 
continue  and  intensify  the  dialogue  with  Member  States  and  stakeholders  and  prepare  the 
ground for future action in the context of EU policies, including the future Maritime Policy. 
The main purpose of this exercise is the protection of the environment and of human health; 
the objective is not to artificially bring back ship recycling business volumes to the EU, thus 
depriving  countries  in  South  Asia  of  a  major  source  of  revenue.  On  the  contrary,  while 
acknowledging the structural comparative cost advantage of such countries, the ultimate aim 

1 

References are to be found at the end of the Annex. 

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of  the  EU  is  to  ensure  that  minimum  environmental  and  health  and  safety  standards  are 
observed worldwide. 

2. 

KEY ISSUES 

2.1. 

Legal situation: the ban on exports of hazardous waste 

In  the  late  1980s  cases  of  toxic  waste  from  industrialised  countries  sent  to  developing 
countries resulted in international outrage. Eight thousand drums of chemical waste dumped 
in Koko Beach, Nigeria, and ships like the Karin B sailing from port to port trying to offload 
their  cargoes  of  hazardous  waste  made  the  newspaper  headlines.  A  reinforced  international 
legal  framework  was  called  for.  The  United  Nation's  Basel  Convention  was  adopted  on  22 
March 1989 to set up a framework for controlling the movement of hazardous wastes across 
international  frontiers.  To  date  168  countries  have  signed  the  Convention  and  165  have 
ratified it. The European Community as a whole is a party to the Basel Convention, as are all 
the Member States. 

An absolute ban on exports of hazardous waste from OECD countries to non-OECD countries 
was adopted in 1995 as an amendment to the Basel Convention. The ban was introduced due 
to  political  concerns  raised  both  by  developing  and  developed  countries  regarding  the 
increased amounts of hazardous waste being exported from developed countries to developing 
countries and then managed in an uncontrolled and risky manner. 

This "Basel ban" was incorporated into EU legislation in 1997 and is binding on all Member 
States (Articles 14 and 16 of the current  Waste Shipment  Regulation2). The EU is the most 
important  global  player  to  have  implemented  the  ban  in  domestic  legislation.  The  USA,  for 
example,  has  not  ratified  the  Basel  Convention  even  in  its  un-amended  form.  Among  the 
larger  countries  which  are  parties  to  the  Convention,  China,  Indonesia,  Egypt  and  Nigeria 
have accepted the ban amendment, while Australia, Brazil, Canada, India, Japan, Korea and 
Russia  have  not.  The  EU  and  its  Member  States  are  promoting,  together  with  their 
international partners, the ratification of the "Basel ban" which constitutes a key element for 
the improvement of the legal framework for international shipments of waste. 

In international waste shipment law it is recognized that a ship may become waste as defined 
in  Article  2  of  the  Basel  Convention  and  that  at  the  same  time  it  may  be  defined  as  a  ship 
under  other  international  rules3.  The  definition  of  waste  in  Community  law,  according  to 
which waste means any substance or object in the categories set out in Annex I to the Waste 
Framework Directive4 which the holder discards or intends or is required to discard, applies 
also  to  ships  sent  for  dismantling.  If  a  vessel  contains  considerable  quantities  of  hazardous 
substances,  or  in  the  words  of  the  relevant  waste  entry  GC  030,  has  not  been  "properly 
emptied" of hazardous materials, it will be considered a hazardous waste. The export of such 
a vessel for scrapping from the EC to a non-OECD country is prohibited under the Basel ban 
and  the  Waste  Shipment  Regulation,  and  any  dismantling  must  take  place  under 
environmentally  sound  conditions  in  an  OECD  country.  The  alternative  is  to  have  the  ship 
decontaminated  (pre-cleaned)  in  such  a  way  that  the  ship  no  longer  constitutes  a  hazardous 
waste. This legal interpretation was confirmed by the French Conseil d'État in the case of the 
former aircraft carrier Clemenceau5. 

The  obligations  for  the  EU  Member  States  under  conventions  of  the  International  Maritime 
Organisation (IMO) do not invalidate these waste shipment rules, even though a ship should 

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not  be  stopped  or  undergo  "undue  delay"  if  it  has  valid  IMO  certificates.  The  Basel 
Convention and the export ban on hazardous waste, as implemented at EU level through the 
Waste Shipment Regulation, are binding and need to be enforced in the Member States. Both 
systems  of  rules  are  compatible,  since  both  the  Law  of  the  Sea  and  IMO  conventions  also 
provide  for  the  rights  (and  duties)  of  coastal  states  to  enforce  other  applicable  rules  of 
international law with regard to environmental protection.  

In practice, the notification requirements of the Basel Convention, which are binding on all its 
parties,  are  rarely  complied  with  in  the  case  of  end-of-life  ships.  It  is  difficult  to  apply  the 
export ban under the EC Waste Shipment Regulation if a ship has left European waters and 
the owner then decides to send it for dismantling in other parts of the world. Specific legally 
binding  international  rules  on  ship  recycling  are  proposed  in  the  draft  Convention  that  is 
currently being discussed in the IMO, but do not exist at present. 

2.2. 

The economics of ship dismantling 

Currently the ship dismantling market functions as follows. Ship-owners who have decided to 
end the economic life of a vessel will look for a cash buyer. This basically happens when the 
maintenance  costs  of  the  vessel  start  to  exceed  possible  revenue,  or  when  the  vessel  has 
become unattractive for the second-hand market, i.e. it is unlikely that it can be sold on. The 
cash buyer will either be a dedicated broker or the scrap yard operator himself. Typically, the 
ship  will  take  cargo  for  a  final  voyage  to  the  area  where  the  scrap  yard  is  located.  After 
completion of this voyage, the  ship  will be brought, under its own power, to the scrap yard 
where it will be dismantled. 

The  cash  buyer  pays  a  price  in  US$  per  light  displacement  ton  (ldt),  which  is  roughly 
equivalent  to  the  steel  weight  of  the  ship.  For  years  the  price  has  been  around  150  US$/ldt 
(with  lows  around  100  US$/ldt  and  highs  around  200  US$/ldt),  but  recently  the  strong 
demand for steel scrap in China and the low supply of ships have driven prices up to record 
levels of nearly 500 US$/ldt for average vessels and more for particularly valuable ones. The 
highest prices are currently paid in Bangladesh. 

A very large crude oil tanker (VLCC) with a cargo carrying capacity of 300,000 tonnes or so 
will be around 45,000 ldt so can fetch 5 to 10 million US$ (or even much more), depending 
on market conditions. These figures are just rough indications as the price is also affected by 
other factors like the amount and quality of the steel, the presence of metals such as copper or 
nickel,  and  the  equipment  that  can  still  be  sold.  Whether  or  not  there  are  problematic 
substances on board do not seem to affect the price. 

The Commission looked into the economics of ship scrapping in a study conducted in 20006. 
The  study  concluded  that  under  current  conditions  it  would  be  extremely  difficult  to  make 
ship  recycling  economically  viable  while  at  the  same  time  respecting  sound  environmental 
standards for various reasons. 

•  The number of ships available for scrapping depends on conditions on the freight market. 
If ships can still earn good money, owners will not decide to send the ship for scrapping. In 
the  past  two  years,  scrapping  volumes  were  very  low  due  to  a  booming  and  profitable 
freight market. The large majority of ships for scrapping will have to come from the deep 
sea  merchant  fleet  and  will  be  mainly  tankers  and  bulk  carriers  (which  are  the  "volume" 
segments).  Other  market  segments,  such  as  warships,  inland  waterways  vessels  and 
offshore structures, are of limited size and availability and so can hardly provide a steady 

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stream  of  material  for  large-scale  recycling.  The  operator  of  a  modern  recycling  facility 
will  therefore  have  difficulty  building  a  business  model  that  fully  covers  its  amortisation 
costs.  This  is  why  the  remaining  operators  in  Europe  were  able  to  survive  only  by 
concentrating on niche markets, in particular offshore structures, fishing boats and inland 
waterway vessels7. 

•  Ships  are  individual  constructions  with  a  long  life-cycle  and  will  have  undergone  many 
repairs  and  maintenance  in  their  20-30  years  of  operation.  Very  little  of  this  will  be 
properly documented. The recycling facility therefore does not know what it is taking on 
and  what  recycling  work  will  be  required.  This  is  particularly  true  for  passenger  ships 
which contain a wide range of materials, including composites which are very difficult to 
separate  and  recycle.  The  ships  currently  heading  for  the  scrap  yards  were  built  in  the 
1970s  using  materials  that  are  no  longer  used  today  (e.g.  asbestos).  Consequently,  the 
amount of manual labour required is significant and likely to remain a major cost factor. 
The use of heavy machinery for these types of vessels will be limited. 

•  Some materials on board can be recycled and will create revenue. Others need expensive 

treatment, for which costs are significant but difficult to calculate in advance. 

•  The main revenue streams for scrap yards in Asia are steel which is used in building, and 
the second-hand market in ships' equipment. These revenue streams basically do not exist 
in developed countries due to regulatory requirements.  

Another factor is the difference in labour costs between Asia and Europe. While labourers on 
demolition  sites  in  Bangladesh  and  India  earn  1-2  US$/day  and  employers'  expenses  for 
safety and health are negligible, the costs in Europe can be estimated at around 250 US$/day 
for a worker in the Netherlands and 13 US$/day in Bulgaria8. 

These  differences  in  labour  costs,  environmental  and  health  requirements  and  revenue  from 
recycling and second-hand materials explain why operators in South Asia can offer far better 
prices  to  ship-owners  than  their  potential  competitors  in  other  countries.  In  Bangladesh 
breakers who have no environmental or health and safety costs currently pay 450-500 US$/t 
for a ship, while Chinese facilities with slightly better standards offer half this price and US 
operators  a  tenth.  Indeed,  in  the  days  before  the  boom  in  steel  prices  recycling  yards  in 
industrial countries even used to charge for the dismantling of naval vessels. 

As  a  consequence  of  market  developments,  the  dismantling  capacity  in  the  EU  has  been 
reduced in the last 20 years to a marginal level. Nowadays there are facilities for larger ships 
mainly  in  Belgium,  Italy  and  the  Netherlands,  with  a  combined  capacity  of  about  230,000 
ldt/year, and a multitude of smaller facilities for fishing vessels and other small craft in most 
other  maritime  Member  States.  Taken  together,  the  existing  capacity  in  the  EU  for  ship 
dismantling  may  be  estimated  at  approximately  500,000  ldt  per  year9.  Besides,  licensing 
procedures  are  ongoing  in  the  UK  to  allow  dismantling  activities  in  two  existing  shipyards 
which would have considerably more capacity (600,000 ldt/year in the case of Able UK). This 
enumeration  does  not  include  the  many  disused  dry  docks  in  ports  all  over  Europe,  which 
would be technically suitable for dismantling, but are not likely to be reopened under current 
economic conditions.  

More sizeable than the existing capacity in the EU is that of neighbouring Turkey which, as a 
member country of the OECD, qualifies in principle as a destination even for hazardous waste 

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exports. About 20 dismantling yards on the shore of Aliaga (near Izmir) have a joint capacity 
of approximately 1 million tons per year, which is today largely unused.  

The  EU  facilities  in  general  meet  high  standards  of  occupational  safety  and  environmental 
protection. Their Turkish counterparts have made considerable advances in environmental and 
safety  management  over  the  last  years,  even  though  there  are  still  some  environmental 
concerns.  There  are  also  a  number  of  facilities  with  piers  for  shipbreaking  in  China,  which 
have been upgraded in recent years to acceptable quality standards, but whose capacity does 
not  amount  to  much  more  than  500,000  ldt  a  year.  The  dismantling  facilities  in 
Brownsville/Texas and other locations in the USA have a similar quality but are in principle 
not open to foreign vessels. 

The  existing  capacity  for  clean  ship  dismantling  in  the  EU,  as  well  as  in  Turkey  is  thus 
sufficient  for  the  warships  and  other  state-owned  vessels  -  an  estimated  100  of  more  than 
1,000 ldt, with a combined tonnage of up to 500,000 ldt10 - that will be decommissioned over 
the next 10 years, but only for a minor part of the merchant fleet under EU flags. According to 
UNCTAD reports, a tonnage of between 6 and 30 million dwt have been sold for breaking per 
year between 2000 and 2005, while approx. 23% of the world merchant fleet fly the flags of 
EU Member States11. 

This problem of insufficient "clean" capacity will be aggravated by the forthcoming phasing-
out of all single-hull oil tankers. Accidents involving tankers like the Erika and the Prestige 
have  caused  major  environmental  disasters  in  recent  decades.  In  reaction  to  this,  EU 
legislation  and  international  rules  were  adopted  for  the  gradual  phasing-out  of  single-hull 
tankers and will begin to have maximum effect in the next decade. It is estimated that about 
1,300  single-hull  tankers  will  be  decommissioned  and  go  for  scrapping  by  the  year  2015, 
about  a  third  of  them  under  the  flags  of  Member  States12.  The  demand  for  ship  recycling 
capacity  is  expected  to  peak  around  the  year  2010,  the  main  phasing-out  date  for  these 
tankers. However, there will also be increases in the longer term, due to the general boom in 
shipbuilding over the last years.  

For  the  moment  the  ship  scrapping  market  is  still  economically  viable,  leaving  aside  the 
extreme  externalisation  of  costs.  Owners  have  significant 
from  selling 
decommissioned ships (the Very Large Crude Carrier – VLCC - given above as an example 
would today cost some 90 million US$ to build new, and would fetch 10 million US$ or more 
after 25 years of use). Scrap yards make profits from recycling the materials recovered. But 
the market only functions under highly problematic conditions that will be described below. 
This  is  less  and  less  acceptable  for  the  public  in  the  developed  countries  where  most  ship-
owners reside and where the financial returns from the ship's operations are collected, and it is 
not compatible with principles of environmental and social sustainability.  

income 

2.3. 

Environmental and social impacts 

Most vessels contain large amounts of hazardous materials, such as asbestos (in particular if 
built  before  the  1980s),  oils  and  oil  sludge,  PCBs  (polychlorinated  biphenyls),  and  heavy 
metals in paints and equipment. So when sent for dismantling, these ships, represent one of 
the major streams of hazardous waste from industrialised countries to the developing world. 
In  2004  a  study  for  the  Commission  (DG  TREN)  estimated  that  oil  sludge  from  end-of-life 
ships  alone  will  total  between  400,000  and  1.3  million  tonnes  per  year  until  2015.  Of  the 
hazardous  waste  in  dismantling  facilities  every  year,  asbestos  will  amount  to  1,000-3,000 
tonnes, TBT 170-540 tonnes and environmentally harmful paints 6,000-20,000 tonnes13.  

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The  scrapping  of  ships  in  Bangladesh,  India  and  Pakistan  takes  place  on  sandy  beaches 
without  any  containment  or  barriers  to  prevent  water  and  soil  pollution.  There  are  few 
reception  facilities  for  hazardous  waste,  and  materials  that  cannot  be  recycled  are  usually 
dumped on the spot. PVC coatings of cables are often burnt in open fires. 

The impact of these practices on the environment has rarely been studied in detail. Available 
data suggest that the physico-chemical properties of sea water, beach soil and sediments are 
considerably affected by shipbreaking14. Oil pollution of the beaches and the adjoining sea is 
clearly visible on aerial photographs of the dismantling sites at Alang (India) and Chittagong 
(Bangladesh), and NGOs report that vegetation and fish have disappeared from these areas. 

Safety and health conditions in the South Asian scrap yards are critical. There is a high risk of 
dangerous accidents, particularly because of the lack of heavy machinery (cranes) and safety 
equipment  for  workers.  According  to  a  2004  government  report  in  India,  there  were  434 
incidents at the Alang yards between 1996 and 2003, killing 209 labourers15. In Bangladesh, 
according  to  media  reports,  more  than  400  workers  have  been  killed  and  6,000  seriously 
injured over the last 20 years16. The fact that Bangladesh, unlike India, does not even require 
"gas-free-for-hot-work" certification in practice accounts for the particularly low costs there, 
but also for the high frequency of lethal explosions at the dismantling yards. 

In  addition,  it  is  estimated  that  thousands  contract  irreversible  disease  from  handling  and 
inhaling toxic substances without minimum precautions or protection. According to a medical 
report  to  the  Indian  Supreme  Court  in  September  2006,  16%  of  the  workforce  handling 
asbestos  in  Alang  were  found  to  be  suffering  from  asbestosis  and  thus  at  serious  risk  of 
mesothelioma17. As is known from medical research, the incidence of this form of lung cancer 
reaches its peak only several decades after exposure. 

In  2005  there  were  an  estimated  25,000 scrapyard  workers  in  Bangladesh.  In  India  the 
workforce  in  boom  times  amounted  to  about  40,000,  which  had  shrunk  to  6,000  by  late 
200618. For both countries it can be said that most workers come from the poorest regions of 
the  country  and  are  usually  unskilled.  They  work  without  contracts  and  health  or  accident 
insurance  and  are  not  allowed  to  form  trade  unions.  There  is  little  or  no  compensation  for 
accidents. Some degree of child labour for the lighter work is common. 

The  conditions  in  shipbreaking  facilities  have  been  criticised  by  environmental  and  human 
rights organisations and the media, and by India's Supreme Court. However, the governments 
of the South Asian states seem reluctant to enforce a change in practices as they regard ship 
dismantling  as  an  economically  important  activity  which  should  be  impeded  as  little  as 
possible. 

2.4. 

International state of play 

The problem of ship dismantling has been discussed for many years, both within the EU and 
within  the  international  organisations  involved:  the  International  Maritime  Organisation 
(IMO),  the  International  Labour  Organisation  (ILO)  and  the  Basel  Convention  (or  more 
precisely  its  parent  body,  the  United  Nations  Environment  Programme,  UNEP).  All  three 
organisations  have  developed  non-binding  technical  guidelines  for  ship  recycling19.  At  two 
meetings  in  2005,  a  Joint  ILO/IMO/Basel  Convention  Working  Group  on  Ship  Scrapping 
discussed  a  co-ordinated  approach  to  the  issue  in  order  to  avoid  duplication  of  work  and 
overlapping of roles, responsibilities and competencies between the three organizations. 

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Since 2005, the IMO has been working towards a binding international regime for clean ship 
dismantling.  The  EU  Member  States  and  the  Commission  take  part  in  this  work.  A  draft 
Convention on the Safe and Environmentally Sound Recycling of Ships is being negotiated in 
the  organisation's  Marine  Environment  Protection  Committee  (MEPC)  for  adoption  by  a 
diplomatic  conference  in  2008/2009,  to  enter  into  force  some  years  later.  The  draft  has  an 
annex  containing  regulations  on  requirements  for  ships  (including  design,  construction, 
operation and maintenance) and for ship recycling facilities, and some reporting requirements. 
It aims at a "cradle to grave" approach to ship recycling, with a view to avoiding hazardous 
materials  in  new  ships  and  removing  them  from  existing  ships  during  their  period  of 
operation. Technical details, which also cover the environmentally sound management of ship 
recycling facilities, are supposed to be set out in recommended guidelines supplementing the 
Convention. 

According to the current draft, the Convention - in line with other IMO instruments - will not 
apply to smaller vessels of less than 400 or 500 gross tons, nor to warships, naval auxiliary or 
other  vessels  which  are  state-owned  or  -operated  and  used  only  on  non-commercial 
government service. Controversial issues, which will be discussed by IMO working groups in 
2007,  include  the  question  as  to  whether  reference  should  be  made  to  rules  and  standards 
outside  the  framework  of  IMO,  the  environmental  baseline  standard  for  ship  recycling 
facilities, future reporting requirements (in particular whether state-to-state notification should 
be necessary as under the Basel Convention) and the type of compliance mechanism to help 
with implementation of the Convention.  

In  the  context  of  the  Basel  Convention,  the  key  issue  under  discussion  is  whether  the 
proposed  Ship  Recycling  Convention  will  ensure  an  equivalent  level  of  control  and 
enforcement as under the Basel Convention. The 8th Conference of the Parties on 1 December 
2006  reiterated  this  demand  and  stated,  among  other  things,  that  the  future  legal  instrument 
should generate conditions of ship dismantling that protect workers and the environment from 
the adverse impacts of hazardous wastes and unsafe working practices. 

3. 

OPTIONS FOR IMPROVING EUROPEAN MANAGEMENT OF SHIP DISMANTLING  

The  Commission  has  examined  the  wide  variety  of  issues  involved  and  identified  some 
options  for  closing  or  at  least  narrowing  the  implementation  gap  and  improving  the 
management of ship dismantling. These options should not be seen as mutually exclusive, but 
as supplementing and supporting each other. 

3.1. 

Better enforcement of EU waste shipment law 

The EU Member States are under an obligation to apply and enforce the EC Waste Shipment 
Regulation, including the "Basel ban" on hazardous waste exports.  

Even  though  the  mobility  of  ships  makes  it  relatively  easy  to  circumvent  the  export  ban, 
enforcement  could  be  improved,  at  least  in  the  case  of  vessels  and  shipping  lines  which 
regularly operate in European waters. This will require: 

•  more  controls  by  waste  shipment  and  port  authorities  in  European  ports,  targeting  ships 
that are above a certain age (25 years) or where other indications make it likely that they 
are intended for dismantling; 

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•  possibly additional guidance by the Commission and the Member States on the definition 
of waste and hazardous waste in relation to ships, and a list of recycling facilities that meet 
standards of environmentally sound management and are safe to workers; 

•  more systematic co-operation and information exchange between the Member States, and 
between  them  and  the  Commission,  including  the  use  of  databases  and  press  reports  to 
identify potential end-of-life ships and follow their route to dismantling facilities;  

•  more  cooperation  with  certain  third  countries,  in  particular  recycling  states  and  transit 

states (e.g. Egypt in relation to end-of-life ships that pass through the Suez Canal); 

•  a  policy  focus  on  warships  and  other  state-owned  ships  and  commercial  vessels  that 

regularly operate in EU waters (e.g. ferries).  

As the Waste Shipment Regulation does not apply only to EU-flagged ships, but to all waste 
exports,  and  thus  end-of-life  ships  that  leave  EU  ports,  ship-owners  are  not  able  to  escape 
controls by re-flagging to non-European flags. The risk that shipping activity in Europe might 
be reduced by tighter enforcement is not very high as long as the EU remains an economically 
attractive  and  profitable  market.  More  realistic  is  the  risk  that  irresponsible  non-European 
ship-owners affected by controls might abandon their vessels in EU ports, so that eventually 
proper disposal has to be paid for by the taxpayer. This kind of problem can only be addressed 
by more efficient enforcement of maritime rules in general. 

3.2. 

International solutions 

Within the international bodies involved, there seems to be general agreement that the most 
important issue is to ensure that ships are recycled in an environmentally sound and safe way. 
In  order  to  create  a  level  playing-field  worldwide,  binding  international  standards  are 
necessary. Such  standards should  generate a real change in current dismantling  practices by 
stopping  the  frequent  pollution  of  soil  and  water,  and  by  protecting  workers  from  accidents 
and contamination. For instance, safe containment of oil residue spills, the prior removal of 
asbestos  with  protective  equipment,  gas-freeing  precautions  to  prevent  explosions,  and 
machinery to carry heavy loads safely should all be made mandatory. 

There will still probably be a price difference between European and Asian countries, even if 
the  latter  meet  high  environmental  and  health  standards,  but  it  is  less  likely  to  prove 
prohibitive  in  all  cases.  In  the  foreseeable  future,  developing  countries  will  be  able  to  offer 
lower  labour  costs  and  higher  prices  for  steel  and  reusable  equipment.  Still,  there  would  be 
greater  scope  for  the  price  gap  to  be  bridged  by  voluntary  measures  that  allow  a  certain 
amount  of  ship  dismantling  to  take  place  in  Europe  where  there  are  particularly  high  "zero 
pollution" and "zero human health harm" standards.  

The future international Convention will be essential for solving the ship dismantling problem 
globally. Thus, the IMO is the most relevant forum to deal at the global level with this issue. 
The new Convention will have repercussions on the Waste Shipment Regulation and other EU 
law  on  environmental  protection  and  safety  at  work.  The  Community  as  a  whole  needs  to 
pursue the objective of becoming a party to this specific Convention of the IMO, . This can be 
done by including in the Convention a clause on regional economic integration organisations 
("REIO clause"), as is the case in all recent multilateral environmental agreements. In order to 
achieve safe and environmentally sound international standards as soon as possible, there is a 
need to reinforce the role of the Community in the IMO.  

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It is in  the interests of the EU, firstly, that the work of the IMO be  concluded as swiftly as 
possible, and, secondly, that the Convention be sufficiently broad in scope and generate sound 
standards  for  health  protection  and  environmental  management,  as  well  as  the  mechanisms 
necessary  for  their  enforcement.  For  this,  the  Convention  should  establish  clear  obligations 
and  prerogatives  of  flag  states,  port  states  and  recycling  states,  and  a  fair  balance  between 
them. The IMO system has to be made effective in the sense of creating a system under which 
ships can only be dismantled in an environmentally sound and safe way.  

It is unlikely that the forthcoming legal instrument will include an obligation to decontaminate 
a  ship  prior  to  its  final  voyage,  since  pre-cleaning  is  seen  by  the  shipping  industry  as 
impracticable from a safety point of view or uneconomic. Under the draft Convention, prior 
removal  of  hazardous  materials  may  not  be  required  if  the  recycling  facility  chosen  is  fully 
authorised  to  manage  the  type  or  amount  of  hazardous  materials  contained  in  the  ship.  The 
draft  (as  of  December  2006)  seeks  to  match  the  individual  ship's  requirements  and  the 
capabilities of the recycling yard by means of a Recycling Plan and an International Ready for 
Recycling Certificate. However, there is still a need to clarify that, in case the final recycling 
facility  is  not  capable  of  managing  certain  hazardous  materials,  the  owner  of  an  end-of-life 
ship  must  select  another  yard  or  remove  the  materials  for  safe  disposal  or  recovery 
beforehand. For the time being, since the Waste Shipment Regulation requires vessels to be 
"properly emptied" of hazardous materials in order to be classified as non-hazardous waste, 
the  Commission  works  on  a  study  concerning  the  risks,  costs  and  benefits  of  pre-cleaning. 
The results should be ready in the late spring of 2007.  

To  change  the  EC  Waste  Shipment  Regulation  or  other  Community  law  affected  by  the 
proposed Convention is currently not an option. This EU legislation should and will remain in 
force and there are no plans for changes until international rules under the IMO achieve the 
same high standard. In particular, there is no reason to modify the Basel Convention system 
for controlling transboundary waste shipments and to grant exemptions for end-of-life ships 
unless and until a new international regime guarantees an equivalent level of control for them. 

However,  in  order  to  enhance  Community  involvement  in  the  IMO  negotiations  on  an 
international Ship Recycling Convention, it is necessary: 

(a) 

(b) 

(c) 

to establish a Community position and possibly give the Commission a mandate for 
the  further  negotiation  of  the  IMO  Ship  Recycling  Convention,  because  of  the 
Community legislation that might be affected;  

to have a "REIO clause" inserted in order for the Community to become a party to 
the Ship Recycling Convention;  

to  intensify  the  co-ordination  of  positions  in  the  negotiations  between  the  EU 
Member  States  and  the  Commission;  co-operation  is  already  good  but  further 
reinforcement is needed.  

After their adoption, the Convention and its guidelines have to be transposed into Community 
law in order to make them mandatory for EU-flagged ships or ships entering EU waters. This 
was  the  case  with  a  number  of  IMO  conventions,  like  for  instance  the  Anti-fouling  System 
(AFS)  Convention,  introduced  into  Community  law  by  Regulation  (EC)  No  782/2003.  This 
approach to establish EU rules on the basis of international legal instruments is currently the 
basis  of  EU  actions  in  maritime  transport  issues  which  allows  taking  into  account  the 
specificities of international shipping. 

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The Ship Recycling Convention, however, may come too late to solve the problem of phased-
out single hull tankers, as IMO conventions take on average six years to enter into force, and 
the  peak  for  phasing-out  is  expected  around  2010.  So  while  it  is  necessary  to  push  for  the 
earliest possible entry into force of the Convention, solutions have to be found for the interim 
period.  

3.3. 

Strengthening EU ship dismantling capacity 

As  described  above  under  2.2,  the  available  capacity  for  ship  dismantling  in  the  EU  and  in 
other  OECD  countries  (especially  Turkey)  is  sufficient  for  all  the  warships  and  other  state-
owned  vessels  that  will  be  decommissioned  over  the  next  10  years,  but  not  for  the  much 
higher number of oil tankers and other large merchant ships that fly EU flags or are owned by 
EU-domiciled  companies.  This  situation  will  not  change  significantly  even  after  several 
shipyards  in  the  UK  that  have  applied  for  the  necessary  licences  become  operational  in  the 
near future20. Even if upgraded recycling facilities in China are included as an option for those 
EU ships that become waste outside of European waters, there will be a considerable deficit in 
safe and environmentally sound dismantling capacity over the next years. 

However,  the  under-utilization  of  existing  "green"  or  upgraded  facilities  in  the  EU,  Turkey 
and  China  shows  that  the  problem  of  ship  dismantling  is  more  on  the  demand  than  on  the 
supply side. Current market conditions make it impossible for EU operators to compete with 
South Asian yards which can offer much lower costs and higher metal prices. As long as there 
is  no  level  playing-field  in  the  form  of  effective  and  sound  mandatory  standards  for  ship 
dismantling worldwide, European facilities will have difficulty competing in the market and 
ship-owners will tend to send their vessels to sub-standard Asian sites.  

Reacting  to  this  situation,  the  Council  of  the  EU  has  issued  a  statement  on  17  May  2006, 
according to which Member States would use their best endeavours to increase capacity for 
ship dismantling in the EU. Furthermore, the Member States would do their utmost to ensure 
that  good  progress  is  made  in  the  international  negotiations  to  establish  mandatory 
requirements at the global level on ship dismantling. In the Council conclusions adopted on 
20 November  2006,  before  the  8th  Conference  of  the  Parties  of  the  Basel  Convention,  the 
Commission  was  invited  to  assess  the  need  for  building  up  sufficient  ship  dismantling 
capacity in the EU. 

Looking at ways to strengthen the position of clean ship dismantling facilities in general and 
EU  facilities  in  particular  for  the  interim  period,  until  a  new  international  regime  has 
established a level playing-field worldwide, action should focus on state-owned vessels. The 
governments of EU Member States are under a special obligation to comply with Community 
legislation and to act in an exemplary manner with regard to the dismantling of warships and 
other  vessels  which  are  state  property.  As  regards  warships,  an  additional  responsibility  is 
derived  from  the  relatively  high  proportion  of  hazardous  materials  (especially  asbestos)  on 
board older vessels. 

The governments of Member States could trigger the supply of "green" dismantling and pre-
cleaning  services  for  their  end-of-life  ships  by  way  of  public  tenders,  in  which  they  follow 
strict public procurement rules that allow dismantling only in accordance with current waste 
shipment  law  and  high  standards  of  environmentally  sound  management.  The  viability  of 
dismantling  facilities  in  Europe  could  be  promoted  already  by  more  transparency  in  the 
time-schedule,  and  EU-wide 
decommissioning  of  state-owned  ships,  a  coordinated 
harmonisation of the quality standards required by governments in dismantling contracts. 

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Where  Member  States  sell  their  vessels  for  further  use  to  other  countries  or  commercial 
buyers, they can still retain some leverage by including provisions on dismantling, such as a 
clause on prior government consent to disposal, in the sales contract. Such provisions are part 
of the proposed UK Ship Recycling Strategy published in March 200621. 

In relation to the much larger merchant fleet, the economic considerations described above are 
of  prime  importance.  As  long  as  no  binding  international  regime  is  fully  established,  and 
probably  even  after  that  date,  strong  incentives  are  needed  to  induce  changes  in  the  current 
practices  of  the  shipping  industry.  In  the  longer  term,  the  objective  should  be  to  establish  a 
sustainable funding system whereby ship-owners and possibly other beneficiaries of shipping 
contribute  to  the  safe  and  environmentally  sound  dismantling  of  ships  worldwide.  Possible 
details of such a system are discussed below (3.6). 

For the interim period, voluntary commitments in the spirit of Corporate Social Responsibility 
can  play  a  certain  role  and  should  be  encouraged  (see  below  3.5).  Awards  and  certification 
systems in particular can help to show the way forward.  

The  question  as  to  whether  or  not  direct  financial  support  should  be  given  to  clean  ship 
dismantling  facilities  in  the  EU  or  to  ship-owners  who  send  their  vessels  to  "green"  yards, 
either for full ship dismantling or for decontamination, should receive special attention. Such 
support to innovative facilities might indirectly reduce the number of ships dismantled under 
unacceptable conditions. It is, however, easy to see the risk that huge sums would be needed 
for a long period of time without creating a sustainable industrial activity and risking cross-
subsidisation  to  other  activities,  particularly  in  the  shipbuilding  sector  where  competition  is 
very  strong.  Apart  from  this,  subsidising  dismantling  facilities,  and  even  more  ship-owners 
directly,  would  go  against  the  "polluter  pays"  principle  of  European  law.  For  this  reason, 
unsurprisingly, the state aid rules on this kind of aid are rather limited.  

The current EU guidelines on environmental state aid22, which are the instrument to define the 
scope of such  aid,  include  certain  waste management services but not ship dismantling as a 
possible object.  Whether subsidies for  certain activities, such as innovative investments,  the 
disposal  of  asbestos  or  the  participation  of  a  company  in  certification  and  monitoring 
schemes, are state aid in this sense and allowed by the guidelines, has to be assessed at present 
on  a  case-by-case  basis.  European  cohesion  policy  can  also  provide  support  for  shipyards, 
including for recycling facilities, on condition that this is in accordance with the objectives, 
rules and procedures of the policy. 

3.4. 

Technical assistance and transfer  of  technology and  best practices to recycling 
states 

In  spite  of  poor  and  dangerous  working  conditions  and  the  degradation  of  the  local 
environment, ship-breaking yards are economically important for South Asian countries. For 
instance,  Bangladesh  probably  derives  about  90%  of  its  steel  supply  from  ship  dismantling, 
and the industry provides jobs for tens of thousands of workers.  

In  order  to  encourage  an  upgrading  of  facilities  in  these  countries,  it  will  be  necessary  to 
provide technical assistance and encourage better regulation. On a small scale this is already 
done  by  international  organisations,  some  OECD  countries,  and  also  the  Commission.  This 
technical  and  financial  aid  should  be  reviewed  in  close  collaboration  with  the  affected 
countries and other international donors, with the aim of promoting safe and environmentally 
sound  ship  dismantling.  The  EU  will  soon  negotiate  new  or  updated  political  or  economic 

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agreements  with  a  number  of  recycling  states,  and  where  appropriate,  will  explore  how  the 
goals of improved labour practices and environmental standards could be reflected. 

Within  the  EU,  there  is  a  considerable  amount  of  experience  and  technology  for 
environmentally friendly ship-dismantling available. The EU should endeavour to share such 
experience with the recycling states and to promote the relevant transfers of technology and 
best practices. By the same token, the EU can transfer experience and practices in relation to 
dealing with the risks posed by asbestos, thus helping to raise the standards of protection and 
precaution in the countries concerned.  

Beyond the technical level, however, it is necessary to acknowledge that the absence or non-
implementation  of  elementary  rules  on  safety  at  work  and  environmental  protection  is 
strongly linked with structural poverty and other social and legal problems in some areas of 
South Asia, such as the lack of property rights and the frequency of extremely short leases for 
operators on coastal land, the weakness of enforcement authorities, and the existence of bad 
governance  practices.  In  order  to  achieve  sustainable  change,  assistance  will  have  to  be 
embedded in a wider framework. 

3.5. 

Encouraging voluntary action 

Merchant  ships  generate  large  profits  for  their  owners  over  a  relatively  long  operating  life. 
When  a  ship  becomes  waste  at  the  end  of  its  life,  the  owner,  as  the  person  who  has  also 
typically taken the decision to send the ship for scrapping and is thus "producer" of the waste, 
is best placed to ensure that its disposal or recovery takes place in a safe and environmentally 
sound  way.  Ship-owners  who  take  their  profession  seriously  should  not  tolerate  the  current 
dismantling  practices,  which  endanger  the  life  and  health  of  workers  and  pollute  the 
environment. 

Voluntary commitments by ship-owners, their associations and their customers are potentially 
the simplest and quickest way to change practices on the ground. The shipping company P&O 
Nedlloyd,  for  instance,  (now  part  of  the  Maersk  Group)  has  formed  a  partnership  with 
Chinese facilities whose environmental and safety standards were upgraded through technical 
assistance and training. Intertanko, the organisation of independent tanker owners, announced 
in  September  2006  the  adoption  of  an  "Interim  Strategy",  according  to  which  ship-owners 
should  only  use  recycling  facilities  that  have  made  demonstrable  advances  in  terms  of  the 
safety and environmental management in Section C of the draft international Convention. 

The  Conference  of  the  Parties  of  the  Basel  Convention,  in  a  decision  of  1  December  2006, 
called upon ship-owners and other stakeholders to take all practical steps to ensure that end-
of-life ships are dismantled in an environmentally sound manner. 

Voluntary agreements may be effective when they are properly designed in terms of substance 
and  comprise  clear  mechanisms  to  ensure  implementation  of  the  commitments  taken  by 
private stakeholders as well as systems for monitoring and control. A commitment of this type 
is a useful first step to generate change. It should therefore be publicly encouraged and, where 
possible,  supported  with  incentives  from  the  European  Union  and  the  Member  States,  after 
which implementation will have to be monitored. If it then turns out that the commitment is 
not followed up in practice, legislation may still be necessary. 

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3.6. 

Ship dismantling fund 

Especially in the longer term it will not be acceptable for investment in clean ship dismantling 
facilities in Europe or Asia to be subsidised out of public funds. "Polluter pays" and producer 
responsibility  principles  require  that  the  owners  take  full  responsibility  for  proper  disposal. 
Such  a  sustainable  funding  system  could  be  organised  on  a  voluntary  basis,  with 
commitments particularly from the shipping industry, but in view of strong competition on the 
market it seems more effective to establish it as a mandatory element of the new international 
regime  on  ship  dismantling.  The  IMO  would  be  in  the  best  position  to  operate  this  fund, 
similar 
the  MARPOL  Convention. 
To guard against re-flagging to states that do not join the fund system, contributions should be 
linked  to  registration  at  IMO  or  the  operation  of  ships  over  their  lifetime,  e.g.  through  port 
fees or mandatory insurance schemes.  

the  existing  oil  pollution 

funds  under 

to 

This link to the ship's operational phase is also preferable to a deposit at the time a ship is first 
built, since often the shipyard that built the ship will no longer exist when the vessel is finally 
scrapped. If an IMO-based fund is not achievable, a regional system could be considered. 

3.7. 

Other options 

Several other measures might be useful to assist the process of upgrading the ship dismantling 
industry in the short and medium term: 

(a) 

EU legislation, in particular on single-hull oil tankers. As these tankers will make up 
a  major  proportion  of  the  end-of-life  ships  to  be  scrapped  in  the  next  few  years,  it 
might  be  worth  considering  action  to  supplement  the  relevant  maritime  safety 
legislation with rules on the clean and safe dismantling of the vessels. 

Some Member States have indicated that they would support such a proposal if the 
Commission  took  the  initiative.  The  disadvantage  of  this  legislation  is  that,  since 
single-hull tankers are largely banned from EU ports anyway, it would be addressed 
mainly  to  EU  flag  states  and  could  thus  trigger  off  a  wave  of  re-flagging,  without 
producing benefits for safety and the environment.  

Apart from the specific issue of oil tankers, more general measures are conceivable 
to prevent the use of hazardous materials in the construction of new ships. The recent 
adoption of the new chemicals legislation REACH (Regulation (EC) No 1907/2006) 
provides  the  regulatory  framework  as  regards  the  use  of  hazardous  chemicals. 
Whether  additional  measures,  specific  to  the  use  of  other  substances  in  the 
construction  of  vessels,  are  needed  would  require  thorough  analysis  and  impact 
assessment. 

Streamlining  of  shipping  aids  with  a  link  to  green  ship  dismantling.  Community 
funding  for  the  shipping  industry  and  state  aids  for  maritime  transport  could  be 
linked  to  the  beneficiary's  use  of  clean  and  safe  dismantling  facilities  for  all  ships 
under its control. 

Establishment  of  a  European  certification  system  for  clean  ship  dismantling  and 
awards  for  exemplary  green  recycling.  Existing  or  in  future  improved  certification 
systems, such as EMAS, could be used for the benefit of improving the management 
of  ship  dismantling  facilities  and  making  this  improvement  transparent  for  clients 

(b) 

(c) 

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and  the  public.  The  intended  revision  of  the  EMAS  Regulation  might  open  the 
system also for non-EU sites and thus enable interested operators e.g. in Turkey to 
acquire an environmental management certificate of good standing. Apart from this, 
early action by ship-owners, recycling facilities and other stakeholders towards safe 
and pollution-free practices in ship dismantling could be encouraged by a green label 
or human health and  safety  award  scheme.  The  already  existing "Clean Marine" or 
"Green  Awards"  for  shipping  lines  and  ports  could  serve  as  an  inspiration.  In 
addition, a public register of clean facilities could give guidance to ship-owners. 

(d) 

Intensifying  international  research  on  ship  dismantling.  At  present,  the  Sixth 
Framework  Research  and  Development  Programme  of  the  European  Commission 
funds  one  research  project  on  the  issue  ("SHIPDISMANTL")  which  looks  at 
technological  options  under  the  aspect  of  international  cooperation.  In  this 
framework, research institutes and dismantling yards from the EU, Turkey and India 
develop Decision Support Systems (DSS) that will be made available for free to the 
ship-breaking industry worldwide. The recently published first call for proposals of 
the Seventh Framework Programme defines explicitly the research area of end-of-life 
strategies for vessels as a priority.  

Apart  from  this  and  other  research  that  was  and  is  undertaken  by  the  Commission 
itself23, more scientific cooperation in partnership mode involving teams from Asia 
and  Europe  would  be  useful  to  analyse  the  options  and  their  implications  in  an 
integrated  way  that  includes  environmental,  social,  economic  and  institutional 
aspects. It would then be possible to propose courses of action on a scientific basis 
which  could  be  helpful  to  the  different  domestic  players  and  in  international 
negotiations.  However,  it  might  be  several  years  before  the  results  of  this  research 
become available.  

4. 

CONCLUSION  

This Green Paper gives the basic facts on ship dismantling and explains the problems. There 
are more details and data in the Annex. To give us a clearer view of the action required of the 
EU, we ask Member States, stakeholders and the public to consider the following questions. 

1. 

2. 

3. 

4. 

How can the enforcement of current Community law (Waste Shipment Regulation) 
affecting end-of-life ships be improved? What is the best mix of measures to divert 
EU-flagged  or  EU-owned  vessels  to  dismantling  sites  with  high  environmental  and 
safety standards?  

Would guidance on waste shipment rules and definitions on end-of-life ships help to 
improve  implementation  of  rules  and  business  practices,  and  what  form  should  it 
take? 

What is the best way of steering the current negotiations on the IMO Ship Recycling 
Convention in order to improve ship dismantling practices globally?  

Should  the  EU  aim  at  global  environmental  and  safety  standards  under  the  IMO 
Convention that are comparable with EU standards? 

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5. 

6. 

7. 

8. 

9. 

How  can  the  EU  best  ensure  that  European  ships  are  dismantled  in  a  safe  and 
environmentally  sound  way  during  the  interim  period  before  the  IMO  Convention 
becomes  effective?  What  about  ships  owned  by  the  public  sector?  Will  national 
strategies and voluntary commitments by ship-owners be sufficient? What additional 
measures would be needed at EU level? 

Should the EU and its Member States take an active role in increasing the EU's own 
ship recycling capacity, and how? 

What  measures  and  actions  should  the  EU  take  to  encourage  South  Asian  states  to 
introduce  and  implement  higher  environmental  and  safety  standards  for  ship 
dismantling? 

What  measures  and  actions  should  the  EU  take  to  encourage  ship-owners  to  direct 
end-of-life ships to dismantling sites with high environmental and safety standards?  

How  should  the  EU  secure  sustainable  funding  for  clean  ship  dismantling  in 
accordance with the polluter pays principle, and what measures and actions should it 
take? 

Contributions in the context of this consultation process should be sent to the Commission by 
30 September 2007, by email to the address “ship-dismantling@ec.europa.eu”, or by post to 
the following address: 

European Commission 

Directorate-general Environment 

Unit G.4 “Sustainable production and consumption” 

B-1049 Brussels 

This  Green  paper  and  the  contributions  received  will  be  published  on  the  Commission’s 
website, unless requests not to do so have explicitly been made. In late 2007, the Commission 
intends  to  present  its  analysis  of  the  responses  received  together  with,  if  appropriate,  its 
proposal and/or initiatives for an EU strategy on ship dismantling. 

EN 

17 

   EN