COMMISSION STAFF WORKING DOCUMENT Evaluation of Regulation (EU) No 1257/ 2013 of the European Parliament and of the Council of 20 November 2013 on ship recycling and amending Regulation (EC) No 1013/2006 and Directive 2009/16/EC Accompanying the document Report from the Commission to the Council and the European Parliament on the application of Regulation (EU) No 1257/2013 of the European Parliament and of the Council of 20 November 2013 on ship recycling and amending Regulation (EC) No 1013/2006 and Directive 2009/16/EC
Date: 2025-02-19
Institutions: Directorate-General for Environment, European Commission
Subjects: EU Member State, hazardous waste, health control, marine pollution, pollution from ships, prevention of pollution, recycling technology, ship's flag, vessel, waste recycling

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 19.2.2025  SWD(2025) 40 final  COMMISSION STAFF WORKING DOCUMENT Evaluation of Regulation (EU) No 1257/ 2013  of the European Parliament and of the Council of 20 November 2013 on ship recycling and amending Regulation  (EC) No 1013/2006 and Directive 2009/16/EC                                        Accompanying the document Report from the Commission to the Council and the European Parliament  on the application of Regulation (EU) No 1257/2013 of the European Parliament and of the Council of 20 November 2013 on ship recycling and amending Regulation (EC) No 1013/2006 and Directive 2009/16/EC       {COM(2025) 52 final}  
 
 
TABLE OF CONTENTS 

GLOSSARY ....................................................................................................................... 2 

1. 

INTRODUCTION ..................................................................................................... 3 

1.1. 

1.2. 

Purpose and scope of the evaluation ........................................................... 3 

Methodology, robustness and limitations .................................................... 4 

2.  WHAT WAS THE EXPECTED OUTCOME OF THE INTERVENTION? ........... 5 

2.1 

2.2 

Description of the intervention and its objectives ....................................... 5 

Point of comparison .................................................................................. 10 

3.  HOW HAS THE SITUATION EVOLVED OVER THE EVALUATION PERIOD?
 ................................................................................................................................. 10 

4.  EVALUATION FINDINGS.................................................................................... 23 

4.1. 

To what extent was the intervention successful and why? ........................ 24 

4.1.1. 

To what extent was the SRR effective? ...................................................... 24 

4.1.2.  

To what extent was the SRR efficient? ...................................................... 42 

4.1.3. 

To what extent is the SRR coherent? ......................................................... 47 

4.2. 

4.3. 

How did the EU intervention make a difference and to whom? ............... 49 

Is the intervention still relevant? ............................................................... 51 

5.  WHAT ARE THE CONCLUSIONS AND LESSONS LEARNED? ..................... 55 

ANNEX I   PROCEDURAL INFORMATION ............................................................... 63 

ANNEX II METHODOLOGY ........................................................................................ 69 

ANNEX III EVALUATION  MATRIX ........................................................................... 73 

ANNEX IV OVERVIEW OF BENEFITS AND COSTS ................................................ 85 

ANNEX V  STAKEHOLDERS CONSULTATION - SYNOPSIS REPORT ................. 89 

ANNEX VI INTERNATIONAL AND EU LEGAL FRAMEWORKS APPLICABLE TO 
THE TRANSBOUNDARY MOVEMENTS AND RECYCLING OF END-OF-LIFE 
SHIPS .................................................................................................................... 101 

ANNEX VII REPORTING REQUIREMENTS UNDER SRR AND ADMINISTRATIVE 
BURDEN ............................................................................................................... 104 

ANNEX VIII MORE DATA ON VESSEL RECYCLING, AND THE EVOLUTION OF 
THE FLEET AND ITS RECYCLING FORECAST ............................................. 107 

1. Detailed information about vessel recycling ......................................................... 107 

2. Detailed information about the fleet and recycling forecasts ................................ 116 

ANNEX IX REPORTING REQUIREMENTS UNDER ARTICLE 21 ........................ 121 

ANNEX X MAIN DIFFERENCES BETWEEN THE SRR AND THE HKC .............. 143 

ANNEX XI LIST OF REFERENCES ........................................................................... 149 

 
 
 
 
LIST OF TABLES AND FIGURES 

Table 1: Main requirements set out by the SRR................................................................. 7 
Table 2: Revenues and profitability of three European leading maritime transport 
companies in 2012, 2022 and 2023, not adjusted for inflation. ....................................... 11 
Table 3: Evolution of EU-flagged vessels scrapped in facilities on the European List 
between 2019-2023 compared to the scrapped vessels that still had an EU flag 1 year 
before being recycled (in absolute numbers and in LDT) ................................................ 31 
Table 4: Cumulated volume (GT) for 2021 and 2022 of EU-flagged vessels (including re-
flagged vessels) recycled in South Asia and the percentage it represents out of the total 
recycled for the flag state during that period. ................................................................... 31 
Table 5: Non compliances for inspections reported in THETIS EU carried out in 2021, 
2022 and 2023. ................................................................................................................. 39 
Table 6: Estimates of additional operational costs to meet SRR requirements for a SRF in 
South Asia. Costs are expressed in Euro per ton. ............................................................. 44 

Figure 1: Intervention logic. ............................................................................................... 8 
Figure 2: Number of vessels recycled worldwide and dismantling locations (2012-2023)
 .......................................................................................................................................... 15 
Figure 3: Light displacement tonnage (LDT) recycled worldwide and dismantling 
locations (2012-2023) ....................................................................................................... 16 
Figure 4: Rates for recycling vessels in Bangladesh, India, Pakistan, and Türkiye for the 
period 2011-2023 (in EUR per LDT) ............................................................................... 17 
Figure 5: Percentage of EU-flagged vessels recycled from the total recycled worldwide in 
LDT. ................................................................................................................................. 18 
Figure 6: Comparative visualisation of Light Displacement Tonnage of scrapped EU-
flagged ships (falling within the scope of the SRR) that changed flag less than 1 year 
before being recycled and of ships recycled under an EU flag. ....................................... 19 
Figure 7: EU-flagged ships that changed flag in the last year before being recycled: new 
flag and dismantling locations (2013-2022). .................................................................... 20 
Figure 8: Different capacity measurements of the European List and EU-flagged vessels 
falling within the scope of the SRR recycled worldwide (including those that changed 
flag 1 year or less before being recycled) (2018-2023) .................................................... 34 

1 

 
 
 
 
 
 
 
Acronym 

DONA 

DWT 

EEA 

EC  

ECSA  

EMSA  

EU 

ESM 

ESG 

FTE  

GT  

HBCDD  

HKC  

IHM  

IMO  

ISRA  

LDT  

NGO  

OECD  

OPC  

PFOS  

PSC  

RFRC  

RO  

SoC  

SRF 

SRR  

SWD  

WSR 

GLOSSARY 

Meaning or definition 

The Dynamic Overview of National Authorities (DONA), is a stand-alone maritime 
application, developed, maintained, and enhanced by EMSA which became operational in 
June 2022.  One of its functionalities is to provide a single-entry portal with restricted 
access, through which Member States could, if they opt to do so, fulfil their reporting 
obligations under EU maritime legislation. The SRR is one of the three legal acts covered 
by the portal in its initial phase. 
Dead weight tonnage (DWT) measures the total weight that a ship can safely carry, 
including cargo, fuel, passengers and crew, and thus reflects the operational capacity of 
the ship and, indirectly, its size.  
European Economic Area 

European Commission  

European Community Shipowners’ Association  

European Maritime Safety Agency  

European Union 

Environmentally sound management 

Environmental social governance 

Full time equivalent  

‘Gross (registered) tonnage’ (GT or GRT) is the measurement of total volume of all 
enclosed spaces in a ship. 1 GRT = 100 cubic feet ≈ 2.83 cubic metres feet. It is used to 
refer to the overall size of a ship mainly during the operational life of a ship. Gross 
tonnage forms the basis for manning regulations, safety rules, registration fees and is also 
used to calculate port dues and fees for the transit of canals.  
Hexabromocyclododecane (brominated flame retardant) 

Hong Kong Convention  

Inventory of hazardous materials  

International Maritime Organisation  

International Ship Recycling Association  

Light Displacement Tonnage (LDT) is used to measure the scrap metal content of a ship 
destined to be recycled. It is the weight (of the ship’s hull and machinery, excluding 
cargo, fuel, water, ballast, stores, passengers, crew). LDT is mostly used by ship recycling 
facilities and for transactions at recycling stage. Displacement is measured in units of 
tonnes (also known as metric ton (t)) or long tons (LT). 1 Long Ton (LT) is 1.016 metric 
ton (t).   
Non-governmental organisation  

Organisation for Economic Cooperation and Development  

Online public consultation  

Perfluorooctane sulfonic acid  

Port State Control  

Ready for recycling certificate  

Recognised organisation  

Statement of completion  

Ship recycling facility 

Ship recycling Regulation  

Staff working document  

Waste shipment regulation 

2 

 
 
1. 

INTRODUCTION 

1.1.  Purpose and scope of the evaluation 

The  aim  of  the  EU  Ship  Recycling  Regulation  (the  SRR  or  the  Regulation)1  is  to  prevent, 
reduce and eliminate the adverse effects on human health and the environment of the recycling 
of  ships  flying  the  flag  of  a  Member  State.  The  Regulation  covers  ships  above  500  gross 
tonnage (GT)2 and applies to shipowners and to ship recycling facilities.  

The SRR also aims to facilitate the ratification of the International Maritime Organisation’s 
(IMO)  2009  Hong  Kong  International  Convention  for  the  Safe  and  Environmentally  Sound 
Recycling of Ships (the Honk Kong Convention) by applying proportionate controls to ships 
and ship recycling facilities on the basis of that Convention. The Honk Kong Convention sets 
out minimum ship recycling requirements. The SRR also contains provisions that go beyond 
the Honk Kong Convention, including a requirement for owners of EU-flagged ships to ensure 
their ships are only recycled in facilities listed by the Commission as meeting requirements for 
the protection of the environmental and human health.  

The Regulation contains a review clause requiring the Commission, 5 years after the date of 
application of this Regulation3, to  ‘“submit a report to the European Parliament  and to  the 
Council  on  the  application  of  this  Regulation,  accompanied,  if  appropriate,  by  legislative 
proposals to ensure that its objectives are being met and its impact is ensured and justified”4.’   

In  line  with  this  provision,  the  Commission  launched  a  process  to  evaluate  the  SRR5.  This 
report providing an evaluation of the SRR is the result of this process. 

In  line  with  the  Commission’s  better  regulation  guidelines,  this  report  assesses  whether  the 
SRR  is  still  fit  for  purpose  (Chapter  4)  using  the  following  five  established  criteria  for 
Commission evaluations. 

•  Effectiveness: looking at the extent to which the objectives of the Regulation have been 

achieved by the actions linked it. 

•  Efficiency: assessing the costs and proportionality of the Regulation in relation to its 
benefits.  Any  potential  for  simplifying  matters  and  reducing  unnecessary  regulatory 
costs should be identified. 

•  Coherence:  assessing  internal  coherence,  between  the  different  articles  of  the 
Regulation, and external coherence, with other EU policy instruments  (including the 
Waste Shipment Regulation, the Waste Framework Directive, the Port State Control 

1  https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=CELEX:32013R1257  
2 The  only exceptions are warships, other vessels on  non-commercial government service and ships operating 
throughout their life only in waters subject to the jurisdiction of the Member State whose flag the ship is flying. 
The 500 GT threshold is the one used for IMO conventions in order to regulate large commercial vessels, which 
are the most active in international shipping and therefore pose cross-border challenges that warrant international 
intervention. This is also the case for the HKC. The SRR’s scope is the same as the HKC’s (also for exceptions), 
on the basis of the assessment of the costs and benefits of alternative options in its impact assessment.   

3 The general date of application of the SRR is 31.12.2018, as Article 32(1) point (b) of it specifies. This means 

by 31.12.2023. 

4 A possible future revision of the SRR has been announced in the sustainable and smart mobility strategy and in 

the sustainable blue economy communication. 

5https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/13377-EU-Ship-Recycling-Regulation-

evaluation_en  

3 

 
 
 
Directive  and  the  Flag  State  Requirements  Directive)  or  international  agreements 
(including the the Honk Kong Convention and the Basel Convention). 

•  Relevance: assessing whether the Regulation’s original objectives and provisions are 
still in line with current and emerging needs (including those set out in, for example, 
the  European  Green  Deal6,  the  Circular  Economy  Action  Plan7,  the  Zero  Pollution 
Action  Plan8,  the  EU  strategy  on  adaptation  to  climate  change9,  the  EU’s  strategic 
autonomy, its industrial strategy10 and Communication on long-term competitiveness11). 

•  EU added value: assessing whether the Regulation gives added value to ship recycling 

compared to what Member States could have done on their own. 

The evaluation covers all the Regulation’s provisions of and its implementing acts. It covers 
the  Member  States  and  EEA  countries12,  as  well  as  the  Regulation’s  impact  on  ship 
recycling practices in non-EU countries.  

The  evaluation  period  covers  January  2013  to  December  2023.  However,  most  of  the 
requirements effectively entered into force from 31 December 2018 onwards. This affects the 
points of comparison presented in Section 2.2. 

If appropriate,  any proposal  for  a revision  of the SRR  will be tabled at  a subsequent  stage, 
supported by an impact assessment in accordance with the  Commission’s Better Regulation 
Guidelines and Toolbox13. 

1.2.  Methodology, robustness and limitations 

This  report  is  based  on  extensive  consultation  with  stakeholders  and  the  gathering  of 
information and expertise. The main research tools and consultations processes included the 
following.  

•  A review of relevant documents (including studies, legal texts and statistics). 
•  Consultation of stakeholders on the implementation of the SRR. This included a public 
consultation,  targeted  surveys  and  interviews  (with  expert  stakeholders  and  with 
Member States)14, a stakeholder workshop15 and discussion in the Commission expert 
group on ship recycling. A wide range of stakeholders contributed, including Member 
State  authorities,  NGOs  and  research  organisations,  industry  stakeholders  and  their 
associations  (e.g.  shipowners  and  ship  management  companies,  ship  recycling 

6  COM(2019 640 final 
7  COM(2020) 98 final 
8  COM(2021) 400 final 
9  COM(2021) 82 final 
10 COM(2020) 102 final. 
11 COM(2023) 168 final 
12  The SRR is marked ‘text with EEA relevance’, meaning it applies in the EEA.  The EEA links the Member 

States and Iceland, Liechtenstein and Norway. EEA countries are therefore covered by the evaluation. 

13  https://commission.europa.eu/law/law-making-process/planning-and-proposing-law/better-regulation/better-

regulation-guidelines-and-toolbox_en. 

14  A  total  of  48  interviews  including  interviews  with  representatives  of  the  steel  industry  (1  company  +  1 
association), recycling facilities (5 + 1 association), other businesses (5), various competent authorities in 4 
EU countries, NGOs (2), shipowners (4 + 3 associations), workers (1 association). See support study. 

15  On the ‘capacity of the European list’ with representatives from ISRA, ECSA and BIMCO. 

4 

 
 
 
facilities,  steel  industries),  classification  societies,  consultancy  firms  and  financial 
institutions.   

•  An evaluation support study carried out by external consultants between October 2022 

and January 2024. 

•  Member State input through reports in line with the reporting obligations under Article 
21(2)  of  the  SRR.  Annex  IX  to  this  evaluation  makes  available  the  content  of  this 
reporting and summarises it. 

This evaluation is a response to evaluation questions, triangulating all available (quantitative 
and  qualitative)  information,  while  accounting  for  stakeholder  vested  interests  and  gaps  of 
evidence and limitations to the extent to which impacts on ship recycling can be attributed to 
the Regulation.  

The main limitation in the analysis is the few quantitative data available on the impact of the 
SRR on the health of workers and the pollution of the coastal and marine environment. Data 
on both aspects is poor due to a lack of transparency, the unavailability of data or of a robust 
monitoring  methodology,  making  it  difficult  to  know  for  sure  if  the  Regulation’s  expected 
benefits  (improvements  in  environmental  and  safety  performance)  have  really  materialised. 
When data is available, it is not always possible to link it directly to the impact of the SRR 
given  the  external  factors  (such  as  the  entry  into  force  of  the  Basel  Ban  Amendment16,  the 
increasing attention being paid to environmental social and corporate governance), pollution 
from other sources and the decrease in ship recycling activities over the evaluation period. Nor 
is it easy to calculate economic impacts as there is limited data available on the economics of 
ship recycling, due to business secrecy on the one hand, and the fluctuating character of the 
market on the other hand. Due to sector’s small size, the absolute number of respondents to the 
public consultation was relatively limited. However, the stakeholders most affected by the SRR 
(individual  shipping  companies,  ship  recycling,  the  steel  industry  and  the  associations 
representing  it  at  EU  level)  gave  their  views  during  the  public  consultation  and  targeted 
surveys.  When  the  contributions  from  the  consultation  were  limited,  triangulating  the 
information from multiple data sources made possible to produce sufficiently robust findings 
for the evaluation of the SRR. Where there is uncertainty over the reliability of information, 
this is made clear in this document. If quantitative data was not available, a qualitative approach 
was adopted.  

More details on how the evaluation was done are available in Annex II on the methodology, 
in Annex III on the evaluation matrix, and in Annex IV, the synopsis summarising the results 
of all the consultation activities carried out for this evaluation, of this report. 

2.  WHAT WAS THE EXPECTED OUTCOME OF THE INTERVENTION? 

2.1   Description of the intervention and its objectives 

When  the  SRR  was  adopted  in  2013,  more  than  1,000  large  seagoing  vessels  were  being 
dismantled worldwide every year17. Ship dismantling can provide an important contribution to 
the circular economy as it leads to reuse, preparing for re-use and recycling of large amounts 

16 https://www.basel.int/Implementation/LegalMatters/BanAmendment/tabid/1484/Default.aspx 
17 SWD(2012)47 Impact assessment, 2012 refers to 744 for 2008, 1299 for 2009. It is a fluctuating market. EMSA 
(based on Marninfo) refers to almost 1400 vessels dismantled in 2013 when the SRR was adopted. For 2013-
2022 a downwards trend can be noted with less than 500 vessels dismantled in 2022. 

5 

 
 
 
 
of valuable resources (in particular high-quality steel, which typically represent between 75% 
and 85% of a vessel’s weight, as well as other metals and equipment)18. But ships also contain 
large  amounts  of  hazardous  materials  such  as  asbestos,  Polychlorinated  biphenyls  (PCB), 
heavy metals, oil, mercury, ozone depleting substances (ODS) which, if not handled, removed 
and disposed of in a safe and environmentally sound manner generate significant risks for both 
human  health  and  the  environment.  The  International  Labour  Organisation  considers 
shipbreaking as one of the most dangerous of occupations, with very high levels of fatalities, 
injuries and work-related diseases19.  

On the basis of the Waste Shipment Regulation (WSR)20, applicable also to EU-flagged vessels 
before the SRR, ships going for dismantling were classified as hazardous waste. As such, they 
should  only  be  dismantled  in  OECD  countries.  However,  this  legislation  was  almost 
systematically circumvented by choosing a non-EU jurisdiction for their vessels at the end of 
the life of the ships, thereby rendering international rules and Union legislation ineffective (see 
Annex  VI  for  the  international  and  EU  legal  frameworks  applicable  to  the  transboundary 
movements of end-of-life vessels).   
Member States and companies in the EU play a major role in international shipping21. However, 
before the adoption of the SRR, 95 % of the volume of large EU-flagged and EU owned ships 
were dismantled outside the OECD22, mostly in South Asia (India, Bangladesh and Pakistan) 
through the so-called ‘beaching method’ (see p.12) and with significant costs in the short and 
in the long term for human health and the environment. This was first explained23 by the lack 
of  recycling  capacity  available  within  the  OECD  resulting  from  the  re-localisation  of  ship 
dismantling  to  South  Asia  for  economic  reasons  (demand  for  steel,  low  labour  costs,  no 
internalisation of environmental costs). Second, at that time the legislation was not adapted 
to the specificities of ships, making it difficult to identify when a ship becomes waste and easy 
to take the decision to send ships for recycling while the ship is in international waters. 

To improve the situation at the global level, the Hong Kong International Convention for 
the Safe and Environmentally Sound Recycling of Ships (the Hong Kong Convention) was 
adopted in May 2009 under the umbrella of the International Maritime Organization (IMO). It 
will enter into force in 2025. At the time of the adoption of the SRR, the perspective of its entry 
into force was however unclear and not expected before 2020. 

The SRR was adopted in 2013 to address the above problems and with the general objective to 
‘prevent, reduce, minimise and, to the extent practicable, eliminate accidents, injuries and other 
adverse effects on human health and the environment caused by recycling EU-flagged ships’. 
The legal base of the SRR is Article 192(1) of the Treaty on the Functioning of the European 
Union  (Union  policy  on  the  Environment).  The  SRR  pursues  the  three  following  specific 
objectives: 

18 A ship can be recycled up to 95–98% of its gross weight. See Hossain K.A., Calculation of yearly output of 
reusable materials of ship recycling industry in Bangladesh, Recent Adv. Petrochem. Sci., 5 (3) (2018). See also 
Annex VIII for a table with recycled materials and percentage of the recycled weight (LDT) by type of vessel. 

19 https://www.ilo.org/resource/ship-breaking-hazardous-work-0  
20 Regulation (EC) No 1013/2006 of the European Parliament and of the Council of 14 June 2006 on shipments 

of waste. 

21 17% of the international merchant fleet tonnage flying EU flags and about 37% of the tonnage belonging to 

EU owners, SWD(2012)47 Impact assessment, 2012. 

22 Impact Assessment 2012. 74% in India, Pakistan and Bangladesh, 22% in China, data from 2009. GT based. 
23 See Explanatory Memorandum in COM (2012) 118,Commission proposal for a Regulation on ship recycling. 

6 

 
 
 
•  Ensure EU-flagged ships are dismantled in safe and environmentally sound facilities.  
•  Ensure the proper management of hazardous materials on ships. 
•  Facilitate the ratification of the Hong Kong Convention. 

As a result, the Regulation also aims to reduce disparities between the ship recycling facilities 
in the EU and in relevant third countries in terms of health and safety at the workplace and 
environmental standards. 

Through these objectives the SRR contributes to UN the Sustainable Development Goals: SDG 
12  and  particularly  SDG  12.4  target  ‘sound  management  of  all  wastes  throughout  their 
lifecycle’, SDG 3 ‘Promoting good health and well-being’, while also ‘protecting the marine 
environment’ (SDG 14).  

Table 1: Main requirements set out by the SRR.  

Article  Who 

is 

Scope 

Description of requirements 

mainly 
affected 
Shipowners  All ships  Prohibition/restrictions  of  the  installation  or  use  on  ships  of 
hazardous materials listed in Annex I.  

Flag states 
Shipowners 

Shipowners  All ships  Ships must have a properly maintained inventory of hazardous 
materials (IHM Part I) which identifies the hazardous materials 
listed in Annex II24. 
Administrations25 or recognised organisations (RO) must carry 
out surveys for issuance and renewal of inventory certificates26. 
The latter is valid for maximum 5 years. 
Third  countries  issue  equivalent  document  to  inventory 
certificate (statement of compliance). 

Shipowners must recycle their ships in ship recycling facilities 
(SRFs) that  are included  in  the  European  List  and notify  the 
Administration of the intention to recycle the ship in a specific 
SRF.  
A ship recycling plan (SRP) mut be prepared by the SRF based 
on  information  provided  by  the  shipowner.  Competent 
authority approves SRP (tacitly or explicitly), and SRFs send 
SRP to Administration and shipowner 
Before the ship being taken out of service, the administration 
(or RO) performs a final survey and issue a ready for recycling 
certificate (RFRC). The latter is valid for maximum 3 months. 
It is supplemented by IHM Parts I, II and III and the SRP. 

Port states 
Shipowners   

All ships  Member  States  apply  Port  State  (as  relevant)  control  on 

inventory certificates, statements of compliance and RFRC. 

4,12 

5,12 

9 

12 

6 

7, 13 

8-9 

11 

EU  
flagged 
ships 
Non-
EU-
flagged 
ships 
EU  
flagged 
ships 

Flag  states/ 
third 
countries 

Shipowners
SRFs 

Shipowners
SRFs 
Recycling 
state 
Shipowners 
Flag state 

EU  
flagged 
ships 

EU  
flagged 
ships 

24  In addition, prior to recycling, EU-flagged ships must incorporate operationally generated waste as Part 2 of 

the IHM and stores as Part 3. 

25    Under  the  SRR  ‘administrations’  means  a  governmental authority  designated  by  a  Member  State  as  being  

responsible for duties related to ships flying its flag or to ships operating under its authority. 

26  The inventory certificate is issued after verification of the IHM that supplement the inventory certificate. 

7 

 
 
  
 
 
13 

SRFs 

13,15 

SRFs 

MS 
competent 
authorities 

COM 
SRFs 

COM 
SRFs 
MS 

MS 

COM 

14 

15 

16 

21 

22 

5,7,9, 
12,13, 
16 

EU  
flagged 
ships 
All 
SRFs 

EU 

Third 
countries 

All 
SRFs 
EU 

EU 

- 

SRF  notifies  the  readiness  to  start  the  recycling  and  the 
completion of the recycling to the administration for each EU-
flagged ship  
For SRFs to be included in the European List, they must meet 
requirements  related  to  safe  and  environmentally  sound 
management  
Member  States  authorise  SRFs  located  on  their  territory  that 
meet requirements for a maximum period of 5 years and notify 
the European Commission for inclusion in the European List.  
They can be renewed. 
The  EC  assesses  applications  by  SRFs  to  join  the  European 
List,  including  via  site  inspections,  and  monitor  SRFs 
authorised and located in third countries. Facilities are included 
for a period of 5 years and may apply for renewal.   
The EC establishes and updates the European List to include, 
renew or remove SRFs through implementing acts 
Member States report every 3 years on issued RFRC, received 
statement of completion and illegal ship recycling 
Member States lay down provisions on penalties applicable to 
infringements, cooperate with one another for enforcement  
Adoption of delegated acts for updating Annex I and II, SRP 
must  be  developed  in  accordance  with  the  Honk  Kong 
Convention, adoption of implementing acts to adopt formats 
consistent  with  corresponding  ones  under  the  Honk  Kong 
Convention, requirements for SRFs included 

The  intervention  logic  of  the  SRR  is  presented  below.  It  shows  the  intended  functioning, 
desired  results  and  overall  rationale  of  the  SRR27.  It  sets  out  the  pathway  from  the  general 
objectives to specific objectives, and the inputs required to deliver these objectives (in terms 
of the human and financial resources of actors) to undertake activities, which in turn should 
lead to certain outputs and ultimately impacts.  

Figure 1: Intervention logic. 

27   A detailed intervention logic had not been elaborated in the context of the impact assessment that accompanied 
the proposal for a Regulation on ship recycling in 2012. One has been derived from the Regulation for the 
purpose of this evaluation. 

8 

 
 
 
 
 
 
 
 
9 

                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      
 
 
 
2.2 Point of comparison  

The evaluation period for this evaluation starts in 2013 with the adoption of the SRR. However, 
most of the SRR requirements started to apply on 31 December 2018. For the purposes of this 
evaluation, 31 December 2018 is therefore being used as a static point of comparison. Where 
possible relevant information is provided also for 2013, as the start of the evaluation period, 
which  therefore  acts  as  a  secondary  point  of  comparison.  In  some  cases,  where  data  is  not 
available on an annual basis, other years are used. 

The  indicators  related  to  the  key  objectives  of  the  SRR,  which  are  used  for  before/after 
comparisons, are: 

•  The  number  and  percentage  of  EU-flagged  ships  dismantled  in  facilities  on  the 
European  List  compared  to  the  worldwide  number  of  ships  recycled,  as  well  as 
compared to the EU fleet, and the location of dismantling;  

•  The number of EU-flagged ships changing flag before being recycled; 
•  Accidents/occupational diseases/pollution (facilities that are on the European List and 

those that are not / before and after EU listing); 

•  The state of ratification of the Hong Kong Convention by the major flag and recycling 

states; Number of countries that ratified the Honk Kong Convention; 

•  Number/capacity of ship recycling facilities on the European List; 
•  Number of completed IHMs including whether they are properly completed. 

The  analysis  of  these  indicators  is  presented  mainly  in  section  4.1.1.  Section  3.  It  provides 
information on basic trends in ship recycling, data on the share of the EU fleet and re-flagging, 
which feeds into the analysis in Section 4. 

External  factors  (including  the  Basel  ban  amendment,  China’s  import  ban,  Covid-19 
pandemic) and their role in influencing the key results and impact variables are also presented 
in section 3. 

3.  HOW HAS THE SITUATION EVOLVED OVER THE EVALUATION PERIOD?  

This  section  presents  the  state  of  play  relating  to  the  ship  recycling  market  and  the 
implementation of the SRR over the evaluation period. 

Economics of ship recycling 

There have not been major structural changes in the economics of ship recycling, compared 
to the general situation described in the impact assessment in 2012.  

The  maritime  transport  sector  is  a  major  operator  in  the  ship  recycling  sector.  The  EU 
maritime transport sector is also a key economic operator for the EU economy. The turnover 
of this sector was estimated to reach around EUR176 billion in 202128, with a new significant 

28 European Commission (2024). The EU Blue Economy Report. 2024.Publications Office of the European Union. 
Luxembourg,  accessible  at  https://op.europa.eu/en/publication-detail/-/publication/ef90077b-1e82-11ef-a251-
01aa75ed71a1/language-en 

10 

 
 
 
 
increase in 2022, where it reached a record level of nearly EUR 270 billion29. This increase is 
linked to the vigorous growth rate in international trade in the post-Covid and supply chain 
adjustments. The EU maritime sector, contributing to around 15% of global Gross domestic 
product30, is  composed of  very large companies operating worldwide, as well as smaller 
ones but shipowners operating ships under the scope of the SRR are generally large companies. 
Shipowners operating merchant ships (cargo or passenger) are generally not SMEs. The overall 
revenues  and  profit  margin  heavily  depend  on  the  fluctuations  in  global  economic  growth, 
trends  in  international  trade  and  freight  rates.  They  also  depend  on  the  types  of  the  ships 
considered  (ie  container  ships,  tankers,  bulk  carriers,  roll-on/roll-off  ships,  passenger  ships, 
offshore supply vessels…). The impact assessment for the SRR used the ClarkSea Index31 as 
an indicator for the overall profitability of the shipping sector at the global level. This index 
shows that the average earnings per vessel have more than doubled in the past 10 years (from 
USD 9,539 per day in 2013, up to USD 23,629/day in 202332).  

As  an  example,  the  revenues  and  profitability  of  three  EU  leading  maritime  transport 
companies reached very high levels in 2022 (see Table below).  

Table 2: Revenues and profitability of three European leading maritime transport companies in 2012, 
2022 and 202333, not adjusted for inflation. 

Name of Company 

Revenues 

Earnings before interest, taxes, depreciation, 
and amortization (EBITDA) 

CMA-CGM 
group34 - 

A.P.  Moller 
Maersk35 

- 

Hapag Lloyd36 

15.9 billion USD (2012) 
74.5 billion USD (2022) 
47 billion USD (2023) 
59.0 billion USD (2012) 
81.5 billion USD (2022)  
51 billion USD (2023) 
6.8 billion USD (2012) 
34.5 billion € (2022)  
17.9 billion € (2023) 

1.3 billion USD (2012) 
33 billion USD (2022)  
9 billion USD (2023) 
8.1 billion USD (2012) 
36.8 billion USD (2022)  
9.6 billion USD (2023) 
0.3 billion USD (2012) 
19.4 billion € (2022) 
4.5 billion € (2023) 

29 Calculations made on the basis of Eurostat data, compiling data from the following NACE categories:  

1.  Passenger  transport:  sea  and  coastal  passenger  water  transport  and  inland  passenger water  transport:  H 

502+H504 

2. Freight transport: sea and coastal freight water transport and inland freight water transport: H 503+H505 
3. Services for transport: renting and leasing of water transport equipment: N 7734 

30  EMSA 

(2020) 

see  https://emsa.europa.eu/eumaritimeprofile/section-1-overview-on-the-eu-maritime-

economy.html 

31 The ClarkSea Index is a weighted average index of earnings for the main vessel types where the weighting is 
based on the number of vessels in each fleet sector. It comprises the ‘average vessel earnings across the major 
shipping sectors, including tankers, bulkers, containerships and gas carriers, weighted by the number of ships 
in each segment.’ 

32See 

Clarkson 

Research 

Services 

Limited 

for 

2013 

and 

maritime.com/containers/clarksons-index-falls-back-2023-remains-33-above-long-term-trend 
https://www.clarksons.com/home/news-and-insights/2023/2022-a-clarksea-record-against-a-disrupted-
backdrop/  for 2023. 

33 Figures for 2012 are not necessarily directly comparable because of changes in market and company structures, 

such as divestments of different business units.  

34 cmacgm-group.com/en/news-media/2023-annual-financial-results 
35 APMM Annual Report 2023 ( see https://ml-eu.globenewswire.com/Resource/Download/51b09aae-ecd3-4553-

bbc9-e400896c6efe)  

36 https://hlag-2023.corporate-report.net/en/home.html  

11 

https://www.seatrade-
and 

 
 
 
End-of-life vessels destined for recycling represent a source of revenues for shipowners. The 
decision  for  shipowners  to  sell  a  ship  for  dismantling  is  usually  based  on  a  comparison 
between the costs and benefits of maintaining an ageing ship in operating condition and 
the  benefits  of  sending  it  for  dismantling.  Besides  the  age  of  the  vessel37,  this  decision 
therefore  significantly  depends  on  the  fluctuations  in  the  conditions  and  rates  of  freight 
transport (which themselves depend on the growth in worldwide trade), regulations leading to 
the phase-out of specific types38 of ships, entry of new ships into the fleet and also largely on 
the price being paid to recycle ships (which fluctuates depending on the steel market dynamics 
and dollar exchange rate).  

Instead of negotiating directly with ship dismantling facilities, many shipowners prefer to sell 
their ships to ‘cash buyers’ (companies that specialize in trading end-of-life ships), sometimes 
through  the  intermediary  of  brokers  that  represent  and  advise  the  seller  during  the  sale 
negotiations39. Cash buyers mediate around 80% of end-of-life sales40. They have become an 
integral part of the ship recycling industry. After taking ownership of a ship, they either launch 
a bid towards different ship dismantlers for the sale of the ship in question, or directly sell it to 
a  ship  dismantling  company  linked  to  its  own  business.  The  last  voyage  of  a  vessel  to  a 
dismantling yard is then organised under the responsibility of the cash buyer, without direct 
involvement of the original shipowner. Cash buyers purchase ships and then sell them to the 
recycler, who normally pays the cash buyer with a bank letter of credit41. Using an intermediary 
presents advantage for recyclers who do not have to directly take care of the trading and export 
procedures of end-of-life vessels.  In the same way, they bring expertise and reduce shipowners' 
risk; and they pay shipowners in cash a sizeable advance on signing of the sale contract and the 
balance on delivery (as opposed to payment by letter of credit from recyclers).  Delivery takes 
place  at  the  anchorage  of  the  recycling  yard  or,  at  an  agreed  port  or  anchorage  in  another 
country. If the ship is delivered by the initial owner at the recycling yard, the ship is not re-
flagged. If the final voyage, from the port or anchorage where the ship was delivered to the 
cash buyer to the place of recycling, is an international one, the ship is usually registered under 
a new flag. A number of open registers facilitate such short-term registrations42.  When there is 
an intention to render the identification of the ship and of its destination to a recycling yard 
more difficult, the name of the ship can be changed at the time of re-flagging and a couple of 
months may elapse between the acquisition of the ship by the cash buyer and its delivery to the 
recycling yard.  

The dismantling of ships is operated by specialised recycling facilities. This market has been 
dominated  in  the  last  decade  by  India,  Bangladesh  and  Pakistan,  while  Türkiye  has  also  a 
smaller  but  very  active  ship  recycling  sector.  There  are  facilities  in  the  EU  operating  ship 

37 The median lifetime for vessels recycled over the period 2012-2022 is between 19 and 48 years, depending on 

the type and size of the vessel. See Annex VIII and support study. 

38  Eg  phasing-out  may  result  from  IMO  International  Convention  for  the  Control  and  Management  of  Ships' 
Ballast Water and Sediments setting requirements performance standards for ballast water treatment systems or 
IMO regulations to cut emissions from ships. 

39 However, the broker does not own the ship at any time (contrary to the cash buyer). 
40  Alcaidea,  J.  I.,  Piniella,  F.,    Rodríguez-Díaza,  E.  The  ‘Mirror  Flags’:  Ship  registration  in  globalised  ship 
breaking 
industry.  Transportation  Research  Part  D:  Transport  and  Environment,  48,  378–392. 
https://doi.org/10.1016/j.trd.2016.08.020 (2016). Mikelis, N., The recycling of ships (2019) refers to ‘nearly all 
merchant ships’ sold for recycling via cash buyers.   

41 It has the advantage for the recycler to pay it back to the bank after the sale of scraps. 
42 Mikelis, N., The recycling of ships (2019). 

12 

 
 
 
recycling, often alongside other activities (like repair).  In a volatile scrap steel market, ship 
recycling  facilities  in  Bangladesh,  India,  and  Pakistan  have  been  constantly  offering 
significantly higher prices per LDT43 for recycling end-of-life vessels than facilities located 
in other countries. In 2023, the price range offered in South Asia for bulk carriers and tankers 
was constantly above EUR 500 per LDT, while EUR 280-340 was offered in Türkiye and EUR 
84-102 in the EU44.  

The price difference is mainly explained by (i) the use of the so-called ‘beaching method’ in 
ship  recycling  facilities  in  South  Asia  and  (ii)  the  high  demand  for  steel  scrap  which  is 
reprocessed through the re-rolling method for the construction industry, at a lower cost than in 
the EU.  

‘Beaching’ means that the ships are driven — usually under their own steam — onto sandy 
beaches  and,  most  of  the  time,  broken  up  without  heavy  machinery  and  without  other 
containment than the hull of the ship itself. Compared to other ship dismantling methods, it 
often results in lower labour, operational, and infrastructure costs, as well as reduced expenses 
related to handling hazardous materials on board of vessels45.  It can be noted however that a 
few  ship  recycling  facilities  in  India  have  demonstrated  they  improved  their  method  of 
dismantling  through  significant  investments46.  In  the  US  and  Europe,  direct  labour  costs 
account  for  approximately  30%  of  the  total  recycling  costs  and  similar  percentage  may  be 
observed  for  costs  due  to  compliance  with  environmental  and  worker  safety  regulations.  In 
facilities using the beaching method these costs are often negligible, and the majority of the 
costs is related the ship purchase price.47  

Globally, the health and environmental record of South Asian ship recycling facilities remains 
of concern. The Shipbreaking Platform documented 449 deaths and 3412 injuries in Southeast 
Asian shipbreaking yards between since 200948. Particularly Bangladesh’s record of fatalities 
and  injuries  remain  high:  78  deaths  and  127  injuries  in  the  period  2018-2022.  Moreover, 
concerns are regularly raised about effective compliance with the requirements set by the laws 
of these countries for the management of the waste resulting from recycling49. 

The domestic market demand for steel scrap and goods present on board ships is another 
determining factor for the prices offered by recycling facilities, as it may represent up to 90% 

43   Light Displacement Tonnage (LDT) is used to measure the scrap metal content of a ship destined to be recycled. 
It is a measure of weight (of the ship’s hull and machinery). It is the unit that is mostly used by ship recycling 
facilities and for transactions at recycling stage. 

44   Support study based on (https://www.gmsinc.net/) and Survey inputs. 
45   Barua, et al. (2018), Environmental hazards associated with open-beach breaking of end-of-life ships: a review, 
Resources,  Conservation  and  Recycling,  Volume  107,  February  2016,  Pages  82-91.  Choi,  et  al.  (2016), 
Economic  and  environmental  perspectives  of  end-of-life  ship  management,  Resources,  Conservation  and 
Recycling, Volume 107, February 2016, Pages 82-91. Du, et al. (2017),  Challenges and solutions for ship 
recycling in China, Ocean Eng, 2017;137:429-439. 

46  Resulting in adequate measures to protect the intertidal zone during cutting operations – see section 4.1.1. 
47   See support study. Note that percentages may vary substantially depending on the characteristics of the vessels 
and  countries.    Also  Mikelis,  N.,  (2019)  estimates  that  financial  costs,  insurance  costs,  rental  costs,  taxes, 
investment  costs,  consumables  and  labour  costs  account  for  15-20%  of  the  purchase  price  of  the  ship  in 
beaching facilities.  Some illustrative examples collected during the evaluation show results in the range of 
10-30%.  In Europe, some examples show similar costs for the ship and for the other costs. 

48   Figures from October 2024. https://shipbreakingplatform.org/ 
49   Support study on the basis of Shipbreaking platform data and for Bangladesh see also Trading Lives for profit, 

Human Rights Watch (2023). 

13 

 
 
 
of their revenue generated by recycling vessels.50 Steel scrap is a valuable commodity used by 
the steel industry to produce new steel. The demand for such scrap is particularly important in 
some South Asian countries, where it represents a non-negligible supply for the steel industry, 
which  are  heavily  relied  upon  by  downstream  industrial  supply  chains,  especially  the 
construction sector. One important reason why ship recycling facilities in South Asia are able 
to propose higher prices for steel scrap from end-of-life vessels is that steel scrap is commonly 
recycled ‘cold’ in re-rolling mills, without energy-intensive and thus expensive remelting in 
furnaces51. In South Asia, re-rollable steel constitutes the majority of the recycled ship's light 
displacement tonnage52. The ‘re-rolling’ method is less commonly used in the EU, as it does 
not allow to produce steel products complying with industry standards and specifications for 
high quality applications.  

Overall, the determining factor for the choice of a dismantling location is the price that a ship 
recycling facility is ready to pay. For the period between 2014 and 2023, the price offered 
by ship recycling facilities using the beaching method was from 30% to 90%53 higher than 
the  price  offered  by  recycling  facilities  located  in Türkiye54. As  a  result,  countries  like 
Türkiye and even more Member States only account for a small fraction of the market as 
they are typically priced out of the market55.  

The difference between the prices that can be offered by a yard in South Asia and a yard 
in Europe can amount to over EUR 1.5 million for an average ship subject to the SRR (ie 
sea-going  vessel  over  500GT).  This  is  an  important  factor  for  the  shipping  industry  when 
deciding  on  the  choice  of  the  dismantling  location  and  methods  for  their  end-of-life  ships, 
including re-flagging, depending on the choice made. The EU shipping industry underlines it 
is operating in a competitive global market. In that context, the difference in prices for ship 
dismantling is one factor taken into consideration to maintain its competitiveness. It should be 
underlined though that the difference in prices mentioned above represents around 2.5% of the 
value of a new ship and indicatively between 0.0020 and 0.0050% of some shipping companies' 
annual revenues.56 It can be noted that a number of shipowners prefer managing a young fleet 
and sell their ships before having to bear the costs and to manage the difficulties inherent to 
older ships (including ultimately their end-of-life). 

Recycling trends over the evaluation period 

In  general,  ship  recycling  volumes  increase  during  economic  recession,  when  global  fleet 
utilisation rate tends to be lower, and decrease in moments of economic growth57. There was a 

50   Besides scrap steel, other sources of revenues  could be, for example, 0.50 % non-ferrous, 0.50% spare & 
stores, 1% electrical cables, motors and panels, 3% equipment & machineries, 5% weight loss. Based on data 
received from ship recyclers in South Asia. Percentages vary depending on the regions, type and condition of 
vessels and market conditions. 

51   SWD(2012) 47 final.  
52  A minimum 72% in Choi et al., 2016 ; around 60% in India for Mikelis (2019). The author notes that in recent 
years, India has imposed some limits on the use of rerolled steel for making bars and consequently lost part of 
its competitiveness compared to Bangladesh and Pakistan. 

53   Support study, p.60. 
54   Using the ‘landing’ method. 
55   SWD(2012) 47 final.  p.17. 
56   Support study, p.64. 
57   OECD (2017) See: https://one.oecd.org/document/C/WP6(2017)14/en/pdf. 

14 

 
 
 
noticeable decrease in recycling vessels worldwide over the evaluation period58, as illustrated 
by Figure 2 below.  

Figure 2: Number of vessels recycled worldwide and dismantling locations (2012-2023)59 

Source: Support study based on data of NGO Shipbreaking Platform and EMSA 

The significant drop in terms of the number of ships scrapped in 2022 appears to be due to 
banks’ shortages in providing credits to companies for the purchase of end-of-life assets and 
high  ocean  freight  rates  that  made  it  profitable  to  continue  operating  older  ships60.  Ship 
recycling of bulkers, tankers and container ships has dropped to its lowest level in 20 years. A 
combination  of  strong  demand  following  a  series  of  market  shocks  (changed  consumer 
behaviours during the COVID pandemic and sanctions on Russian oil and coal export) and low 
orderbooks have kept older ships operating for longer than usual61.  

58   See https://unctadstat.unctad.org/wds/TableViewer/tableView.aspx?ReportId=89492&IF_Language=eng. 
59  Note that the figure does not include vessels with unknown location of dismantling. 
60   See also https://shipbreakingplatform.org/platform-publishes-list-2022/.  
61  This includes, for example, some of the 600 tankers worldwide that make Russia’s ‘shadow fleet’ and which 
consist of old ships which would in other conditions have been sent for dismantling. See European Parliament 
Resolution of 14 November 2024 (2024/2885(RSP)). See also Demand shocks drive ship recycling to lowest 
level in 20 years (bimco.org). 

15 

 
 
 
 
Figure 3: Light displacement tonnage (LDT) recycled worldwide and dismantling locations (2012-2023)62 

Source: Support study based on data of NGO Shipbreaking Platform and EMSA 

Over  the  evaluation  period  the  tonnage  recycled  worldwide  has  dropped  from  9,219,887  in 
2013 to 2,601,322 LDT in 2023. Figures 2 and 3 also shows that the proportion of vessels 
recycled in South Asia increased between 2013 and 2023. When considering the LDT, the 
proportion of vessels recycled in South Asia represents around 80% of the recycled vessels 
since 2018 and 87% in 2023.  Over the evaluation period, the proportion taken up by India has 
fluctuated between 30% and 40% (40% in 2023). Bangladesh has significantly increased its 
share of the market to also reach 40% in 2023 and a positive trend is also observed in Türkiye 
which had in 2023 7.6% of the market63.  An important change is that China ceased to be one 
of the key players in the global ship recycling market64, further to its decision in 2017 to stop 
the import of waste.  

The market share of the ship recycling facilities located in the EU has remained very small 
over the considered period. It has evolved from 4.5% in 2013 to 5.3% of worldwide recycling 
when taking into account the number of vessels and from 1.5% in 2013 to 1% when size of the 
vessels and therefore their weight at scrap (LDT)). Unlike recycling facilities in South Asia and 
Türkiye, most recycling facilities in the EU are not exclusively recycling large vessels. Most 
of them are also dismantling vessels which do not fall within the scope of the SRR, especially 
smaller vessels (below 500 GT), as well as warships. A few new ship recycling facilities started 
their activities in the last 5 years in Denmark and Norway, which are particularly designed to 
dismantle floating oil platforms, in anticipation of the expected de-commissioning of a large 
number currently in  use in  the North  Sea.  Some ship  recycling facilities  in  the EU are also 
carrying out other activities than dismantling, especially repair of vessels. The ship recycling 
facilities in the EU are most of the time SMEs, but some of them are also associated with larger 
companies active in waste management activities. These  recycling facilities have to comply 
with the requirements of the SRR in terms of environmental and public health requirements.  

62 Note that the figure does not include vessels with unknown location of dismantling. 
63  Elaboration based on data of NGO Shipbreaking Platform and EMSA 
64  For a relatively long periods China had recycled 25% to 30% of the world’s tonnage. Mikelis, N., (2019). 

16 

 
 
 
 
More data on the volume of ship recycled and locations can be found in Annex VIII.   

In terms of costs and revenues from the actual demolitions, the period from 2018 to 2023 shows 
a recovery and growth trend for demolition/scrap prices per LDT for shipbreaking in South 
Asia and Türkiye, as shown in the figure below.  

Figure 4: Rates for recycling vessels in Bangladesh, India, Pakistan, and Türkiye for the period 2011-2023 
(in EUR per LDT) 

Source: Support study based on (Sustainable Shipping Initiative, 2021), (Developed by 2BHonest based on (Mikelis, 2020)), (ISL, 
2021), (Izmir Development Agency, 2022) and GMS website ((*) average value until 31 December 2023). 

Recycling of EU fleet 

The  world  merchant  fleet  was  composed  in  the  1st  quarter  of  2023  of  131,185  vessels 
representing a gross tonnage of 1,596 million GT and a deadweight of 2,332 million tonnes65. 
European companies owned approximately 21,000 ships, representing around 16% of the world 
commercial fleet in terms of number of vessels but 30% of the world commercial fleet in 
GT, and almost 40% of the world’s dead weight tonnage capacity.66 Around 60% of these 
ships were flying a Member State flag67.  

In 2023, the proportion of the world fleet above 500 GT represented by the EU-flagged 
vessels68 was around 13% in number of vessels. However, the percentage of end-of-life vessels 
with an EU flag when sent to dismantling equalled 6.7% of the worldwide number of vessels 
recycled69. Over the evaluation period, there was a significant decrease, in the proportion of 
the  vessels  flying  the  flag  of  a  Member  State  recycled,  compared  to  the  total  volume 

65   EMSA  https://www.emsa.europa.eu/eumaritimeprofile/section-2-the-eu-maritime-cluster.html.  The  dead 
weight tonnage (DWT) is used to indicate the cargo carrying capacity of a ship, while the gross tonnage (GT) 
reflects its size. Figures are for ships of 100 GT and above. 

66   UNCTAD (2023), Clarkson Research including commercial ships of 1000 GT and above. Beginning-of-year 

figures. Greece ranked first with owned ship capacity exceeding 393 million DWT.  

67   EMSA https://www.emsa.europa.eu/eumaritimeprofile/section-2-the-eu-maritime-cluster.html 
68   ‘EU flag(ged)’ is to be understood in the text as ‘flying the flag of an EU/EEA Member State. EMSA and 

UNCTAD data. 

69   Support study based on EMSA and UNCTAD data. 

17 

 
 
 
 
 
recycled  worldwide,  especially  when  considering  the  weight  of  these  vessels  (LDT)  as  it 
dropped from 10.2 % in 2013 to a mere 3.6% in 2023, as shown in the figures below.  Less 
than 40 EU-flagged vessels in average were recycled each year between 2018 and 2023.  For 
these vessels, the main recycling destinations were Türkiye, Norway and Denmark70.  

Figure 5: Percentage of EU-flagged vessels recycled from the total recycled worldwide in LDT.  

12,0%

10,0%

10,2%

7,3%

6,6% 6,5%

4,4%

5,1%

3,6%

3,0% 2,6%

2,6% 2,8%

8,0%

6,0%

4,0%

2,0%

0,0%

Source: EMSA using MARINFO database sourced by IHS S&P. 

One  important  factor  explaining  the  low  number  of  EU-flagged  vessels  reaching  the 
dismantling stage is that shipping companies used the practice of re-flagging to their end-of-
life vessels. The significant discrepancy between the 25 largest flag states in general and the 
25 largest flag states for end-of-life ships (see Annex VIII), shows that the ship operators often 
change flags before disposal. Changing flag from a Member State to a third country is done 
either  directly  with  the  shipping  company  remaining  the  owner  of  the  vessel,  or,  when  re-
flagging occurs shortly before the dismantling stage, often through the sale of the vessel to a 
cash buyer which takes over the vessel and transfer it to a non-EU flag.  Between 2013 and 
2022, between 27% and 53% of vessels that still had an EU flag 1 year before being recycled 
changed for a non-EU flag before being  recycled71.   When taking  as  a reference  the weight 
(LDT) of end-of-life vessels recycled, the re-flagging phenomenon is even more pronounced. 
This  shows  that  vessels  keeping  an  EU  flag  at  the  dismantling  stage  were  predominantly 
smaller ships than those re-flagged to another flag72. As shown in the figure below, from 2016 
until  2023,  the  ships  flying  an  EU  flag  that  changed  flag  less  than  1  year  before  being 
recycled consistently represented a higher tonnage (in LDT) than the ships that still had 
an EU flag at the time of recycling. In 2019, a peak in re-flagging was reached as the ships 
that change their flag from an EU to a third country flag before being recycled was more than 
three times higher (in LDT) than the tonnage of ships that still had an EU flag at the time of 
dismantling.  

70 EMSA based on data derived from the MARINFO database (sourced to EMSA by IHS S&P). 
71  Support study Figure 3.17 p.69. based on EMSA data. In absolute terms it represents between 10 and 66 vessels 

yearly. 

72 The bigger the vessel the more profitable it is to have a last journey with South Asia as a destination.   

18 

 
 
 
 
 
 
 
 
 
 
 
 
Figure 6: Comparative visualisation of Light Displacement Tonnage of scrapped EU-flagged ships (falling 
within the scope of the SRR) that changed flag less than 1 year before being recycled and of ships recycled 
under an EU flag. 

d
e
l
c
y
c
e
r
T
D
L

l

a
t
o
T

 1.200.000

 1.000.000

 800.000

 600.000

 400.000

 200.000

 -

2013

2019

2013 2014 2015 2016 2017 2018 2019 2020 2021 2022 2023

2023

LDT volume of EU flagged ships recycled

LDT volume of EU reflagged ship (1 year before recycling)

Source: Based on EMSA data 

Though still significant, re-flagging before dismantling has been on a decreasing trend since 
2022; this trend would need to be confirmed on a longer term, especially for the biggest vessels.   

During the period 2013-2023, a total of 324 EU-flagged vessels were re-flagged less than 1 
year before being recycled, often to countries with an open register such as Palau, St Kitts and 
Nevis, or the Union of the Comoros, and dismantled mostly in South Asia73 (see figure below).   

73  The remaining (around 30%) of ships ended up in Türkiye. Of these, 65% were dismantled in facilities that are 
not  on  the  European  List,  22%  in  facilities  that  are  on  the  European  List  and  the  final  destination  of  the 
remaining is unknown. 

19 

 
 
 
 
 
 
 
 
 
 
 
 
 
Figure 7: EU-flagged ships that changed flag in the last year before being recycled: new flag and 
dismantling locations (2013-2022).74  

Source: Support study based on EMSA data. 

The key driver for re-flagging end-of-life vessels is the higher prices that can be offered by 
third country recycling facilities not on the European List for dismantling end-of-life vessels, 
as explained above. 

European List of ship recycling facilities 

Since 31 December 2018, the SRR has required  shipowners to only recycle large sea-going 
vessels sailing under a Member State flag in an approved ship recycling facility included in a 
dedicated European List.  

To be included in the European List, any ship recycling facility, irrespective of its location, has 
to comply with a number of safety and environmental requirements. For facilities located in 
the EU, competent national authorities must check that all the relevant conditions are met, and 
then inform the Commission that the facility should be listed. Ship recycling facilities located 

74  In  this  Sankey  the  leftmost  column  indicates  initial  ship  registrations  under  EU  flags.  The  central  column 
illustrates the flag changes these vessels undergo. The rightmost column denotes the final destinations for being 
scrapped.  The  flows  connecting  these  columns  are  represented  by  streams,  with  the  width  of  each  band 
corresponding to the volume of ships that have undergone the specific transition. 

20 

                                                                                                                                                                                                                                                                         
 
 
 
in third countries and intending to recycle ships flying a flag of a Member State have to apply 
to  the Commission  for inclusion in  the  European List. The Commission then evaluates  and 
checks  how  these  yards  comply  with  the  requirements,  including  through  inspections  and 
proposes their inclusion in the European List when these requirements are met. All inspection 
reports are publicly available75. 

The first European List of ship recycling facilities was adopted in December 2016. It included 
18 yards located in the EU. This List has been regularly updated by the Commission. The 12th 
edition  of the  list76  was  adopted in December 2023.  It contains  45 ship recycling facilities, 
including 35 yards in Europe (EU, Norway and UK), 9 yards in Türkiye and 1 yard in the USA. 
The yards report a combined maximum annual ship recycling output of 1,140,060 LDT and a 
theoretical recycling capacity of 2,703,423 LDT. 

Inventory of hazardous materials 

Since  12  December  2016  it  is  mandatory  for  EU-flagged  ships  going  for  recycling  to  have 
completed  an  inventory  of  hazardous  materials  (IHM)  and  have  it  on  board.    Since  31 
December  2018,  this  obligation  has  been  extended  to  new  EU-flagged  ships  and  since  31 
December 2020 to all existing EU-flagged ships and non-EU ships calling at an EU port or 
anchorage. 
In  October  2016,  EMSA  published  a  best  practice  guidance77  for  the  development  and 
maintenance of an IHM, as well as for conducting vessel inspections. This was complemented 
in 2019 by EMSA guidance on inspections of ships by the port States78.  

Ratification of Hong Kong Convention 

The Hong Kong Convention was adopted in 2009. It contains very specific conditions for its 
entry into force, linked to the minimum number of countries ratifying it and their respective 
shares as flag States in the global fleet and as recycling States compared to the overall recycling 
levels worldwide. This minimum number was reached in June 2023, triggering the entry into 
force of the Convention on 26 June 2025. 

As of December 2023, 23 countries had ratified the Convention (Ghana, Norway, the Republic 
of the Congo, France, Belgium, Panama, Denmark, Türkiye, the Netherlands, Malta, Serbia, 
Japan,  Estonia,  Germany,  India,  Croatia,  Spain,  Luxembourg,  Sao  Tome  and  Principe, 
Portugal, Bangladesh, Liberia and Pakistan).  

It should be noted the Honk Kong Convention’ s entry into force provides the opportunity to 
amend and strengthen its standards and catch up with development since its adoption in 2009. 

75 https://environment.ec.europa.eu/topics/waste-and-recycling/ships/site-inspection-reports_en  
76 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=OJ:L_202302726   
77http://www.emsa.europa.eu/we-do/sustainability/environment/150-ship-recycling/2874-emsa-s-best-practice-

guidance-on-the-inventory-of-hazardous-materials.html  

78http://www.emsa.europa.eu/we-do/sustainability/environment/150-ship-recycling/3721-guidance-on-

inspections-of-ships-by-the-port-states-in-accordance-with-regulation-eu-1257-2013-on-ship-recycling.html  

21 

 
 
 
Adoption of implementing and delegated acts 

The EC adopted in 2016 implementing decisions on the format of the IHM certificate, of the 
ready  for  recycling  certificate,  of  the  report  of  planned  start  of  ship  recycling  and  of  the 
statement  of  completion,  consistent  with  the  Honk  Kong  Convention’s  templates79.  No 
delegated acts were adopted as there was no need to amend the annexes to the SRR. 

Implementation and enforcement in Member States 

Member  States  have  designated competent  authorities,  the  contact  persons responsible  for 
responding  to  enquiries  as  well  as  members  of  their  permanent  staff  responsible  for  the 
cooperation  with  other  Member  States  for  the  prevention  and  detection  of  potential 
circumvention and breach of the SRR.  

They also reported penalties laid down for infringements of the rules80, which the Regulation 
requires  to  be  effective,  proportionate  and  dissuasive.  Administrative  penalties  differ 
significantly  between  Member  States  and  only  8  Member  States81  have  provided  for  the 
possibility to apply criminal sanctions for infringements of the SRR. There has been only few 
investigations and penalties imposed by Member States for breaches of the SRR, as reported 
under the first triannual report required from Member States under the Regulation (see more in 
section 4 on the effectiveness of enforcement in general). 

External factors that have significantly impacted the implementation of the SRR82 

As indicated above, China’s waste import ban introduced in 201783 led to the impossibility 
for  EU-flagged  vessels  to  be  dismantled  in  China.  Ship  recycling  facilities  in  China  do  not 
operate with the ‘beaching’ or ‘landing’ methods, but with drydock or alongside quays. Four 
ship recycling facilities had applied to join the European List and their application process was 
stopped because of the import ban. These facilities had substantial capacity to deal with the 
dismantling of large vessels84 at a lower price than in Europe and therefore were expected to be 
in a better position to compete with yards operating under the ‘beaching‘ method. 

79  Implementing  decision  on  the  on  the  format  of  the  certificate  on  the  inventory  of  hazardous  materials , 
Implementing  decision  on  the  format  of  the  ready  for  recycling  certificate ,Implementing  decision  on  the 
format  of  the  report  of  planned  start  of  ship  recycling   and  Implementing  decision  on  the  format  of  the 
statement of completion of ship recycling  

80  Information available under Ships - European Commission (europa.eu).  The last infringement opened against 

Member States for non-communication under that article was closed in 2023.  

81  These Member States are CY, DK, FR, FI, IS, EL and NO. State of play end of 2023. 
82  Besides those mentioned in this section, which have directly impacted some of the provisions of the SRR, other 
external factors linked to the market conditions (eg freight rates, steel market, exchange rate, Russian war in 
Ukraine) had also a significant impact on the implementation of the SRR.  

83  China’s waste import ban refers to a series of restrictions and bans implemented by the Chinese government 
on  the  import  of  various  types  of  waste  streams.  The  ban  was  introduced  with  the  aim  of  reducing 
environmental pollution and improving public health caused by the processing and disposal of large quantities 
of foreign waste Support study and Brooks et al., (2018). 

84    2012  Impact  Assessment    and  BIMCO,  Report  on  the  European  List  of  ship  recycling  facilities,  (2022) 

BIMCOReportontheEUList3rdEditionOCTOBER2022 (6).pdf 

22 

 
 
 
Another external factor that influenced, temporarily, the implementation of the SRR was the 
COVID-19 pandemic. The lockdown measures and travel restrictions linked to the pandemic 
led to delay on surveying of ships and the production of IHMs. In response to this situation, the 
Commission  published  guidelines  on  the  enforcement  obligations  related  to  the  IHM  in 
October 202085. Besides, the pandemic resulted in a significant increase of cruise ships sent to 
recycling, mainly to Türkiye, where the recycling facilities reached full capacity and created a 
backlog until 2022.86  

The  Ban  Amendment87  to  the  Basel  Convention,  adopted  in  1995,  entered  into  force  on 
5 December  2019,  establishing  a  ban  on  the  transboundary  movements  of  hazardous  waste 
from OECD countries to non-OECD countries. The consequence of this entry into force was 
that the export of end-of-life vessels from the EU to non-OECD counties would be in breach 
of international law. In practice, no such export could take place as no ship recycling facility 
located  outside  the  EU  had  been  included  in  the  European  List  at  the  time  when  the  Ban 
amendment entered into force. However, a number of such facilities (from India mainly) had 
applied to join the European List. The application process for these ship recycling facilities was 
put ‘on hold’ in December 202188. At the same period, the Commission proposed amendments 
to the WSR for the EU to meet its international obligations and at the same time to allow ship 
recycling  facilities  from  non-OECD  countries  in  the  European  List.    The  new  WSR, 
incorporating these amendments, entered into force in May 202489. It allows EU-flagged end-
of-life ships to be dismantled in ship recycling facilities located outside the OECD, when they 
have  become  waste  outside  the  EU.  There  are  therefore  no  legal  obstacles  any  longer  to 
continue the application process for the inclusion of facilities located outside the OECD.  

Finally, the growing attention to environmental social and corporate governance (ESG) also 
contribute positively to the general objective pursued by the SRR90 towards more sustainable 
ship recycling. A series of voluntary initiatives have been adopted by actors in the shipping 
sector in this sector, which make an explicit reference to the SRR91.  

4.  EVALUATION FINDINGS  

The Evaluation matrix in Annex III sets out the overall approach followed in this report for the 
evaluation  of  the  SRR,  including  all  relevant  evaluation  questions  and  sub-questions.  The 

85 See https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=OJ:JOC_2020_349_R_0001  
86 BIMCO, Report on the European List of ship recycling facilities, (2022)  
87 https://www.basel.int/Implementation/LegalMatters/BanAmendment/tabid/1484/Default.aspx  
88 Because the inclusion would have allowed exports of  EU-flagged ships for recycling to the concerned non-

OECD country, whereas the Ban Amendment generally prohibits such exports. See also Annex VI. 

89  OJ L, 2024/1157, 30.04.2024. See https://eur-lex.europa.eu/legal-

content/EN/TXT/?uri=CELEX%3A32024R1157   

90 Most voluntary market-driven initiatives to more responsible ship recycling practices  have also an industry-
wide level playing field as primary objective. As a result, over the evaluation period it cannot be concluded to a 
positive impact of these initiatives on having EU-flagged ships dismantled in facilities that are on the European 
List. 

91 See for example the Ship Recycling Transparency Initiative (https://www.shiprecyclingtransparency.org/) and 
(RSRS-

the 
Responsible_Ship_Recycling_Standards_March_2021.pdf (shiprecyclingtransparency.org) 

Responsible 

standards 

recycling 

banks’ 

ship 

for 

23 

 
 
 
 
questions are provided and answered below with sub-questions were considered necessary to 
outline findings. 

4.1.  To what extent was the intervention successful and why?  

This section looks at whether the SRR has been a success, based on an assessment of whether 
it is effective, efficient, and coherent.  

4.1.1.  To what extent was the SRR effective?  

The SRR is meant to deliver its general objective to reduce adverse effects on human health 
and the environment caused by recycling EU-flagged ships , through its contribution to its three 
specific objectives: 

•  Ensure EU-flagged ships are dismantled in safe and environmentally sound facilities.  
•  Ensure the proper management of hazardous materials on ships. 
•  Facilitate the ratification of the Hong Kong Convention. 

The section starts with a general assessment of impact on how successful the SRR has been in 
contributing to its general objective and then examine in more details the effectiveness of the 
measures related to the specific objectives.  

How successful has the SRR been in preventing, reducing, minimising and eliminating 
accidents, injuries, and other adverse effects on human health and the environment caused by 
ship recycling? 

The impact of SRR on health and environment has been  limited but  positive globally.  
Despite the lack of  robust  quantitative data, which is  developed  further  down, the tangible 
improvements in third country facilities carried out to be in conformity with the SRR, in 
combination with the feedback received during the consultation process, give reasonable 
reason to believe that the measures as designed have resulted in a positive impact for the 
improvements of health and the environment in the ship recycling sector.  

The evolution of the ship recycling sector in Türkiye, which represents today 7.6% of the 
LDT  dismantled  worldwide  and  the  destination  for  more  than  half  of  the  EU-flagged 
vessels,  is  a  useful  indicator  of  the  positive  developments  of  applicant  yards  in  third 
countries, as 18 out of the 22 facilities in Türkiye have applied to join the European List and, 
end of 2023, 9 facilities were included in the European List92. On the health impact, the average 
number of fatal accidents per year in Turkish ship recycling facilities shows a decrease from 
7.1 fatalities per year in  the period 2010-2018 to  1.7 in  the period 2020-202393. This  could 
reasonably be correlated to the application of Turkish ship recycling facilities to the European 
List.  Trends  should  however  be  observed  with  caution  as  the  positive  evolution  concerns  a 
relatively short period, characterised by a notable downwards trend in the volume recycled and 

92 And two more in the process of being included.  
93 Support Study and updated for 2023. On the basis of data from different sources. The authors note that data 

regarding accidents is often inconsistent and incomplete. 

24 

 
 
 
with irregular accident frequency rate for individual ship recycling facilities throughout that 
period.  

What is clearer is that the process of application and inclusion of ship recycling facilities in 
the  European  List  led  to  improved  working  conditions  and  important  investments  to 
mitigate  pollution,  changing  dismantling  practices  and  improving  the  treatment  of 
hazardous waste. In 2023 the report from NGO Shipbreaking platform on Türkiye highlighted 
the EU inspection reports’ pivotal role in driving yard improvements94. The reports95 from 
the  Commission  inspections  which  reflect  more  than  55  inspections  in  25  ship  recycling 
facilities worldwide including 16 ship recycling facilities in Türkiye represent a valuable and 
essential qualitative source of information for assessing the impact of the EU SRR. Mitigation 
of the externalities inherent  to  this industry that can be retrieved from  the reports  generally 
include, for examples, better containment of hazardous materials during the entire ship 
dismantling  process  to  prevent  spills  and  leakages,  use  of  impermeable  floors  with 
effective  drainage  systems,  improved  management,  storage  and  disposal  of  hazardous 
waste (such as asbestos), improved systems for safely pulling a ship further away from 
the  shore  line  (including  winching  gear  and  cables  and  their  periodical  control), 
availability and use of Personal Protective Equipment, better emergency preparedness 
and response evaluation, accident and incidents reporting and analysis, development of 
environmental monitoring on the basis of an improved methodology. 

The SRR also had an impact in India, which is the second biggest ship recycling nation in 
the world. Over the period 2016-2023, there is a general downwards trend in the number of 
fatalities in Alang, according to data from the Indian authorities. This could again be reasonably 
correlated to the application of Indian ship recycling facilities to the European List, with other 
contributing  factors.  27  ship  recycling  facilities,  representing  around  30%  of  the  overall 
recycling capacity of the country96, had applied for inclusion in the European List end of 2023. 
Like  in  Türkiye  most  of  these  ship  recycling  facilities  have  made  important  investments  to 
upgrade facilities and improve instructions, procedures and practices to meet the EU criteria. 
This  appears  most  predominantly  in  the  reports  of  the  6  ship  recycling  facilities  that  were 
subject to inspections by the Commission. Improvements vary according to the ship recycling 
facilities  but  generally  include,  for  example,  systematic  sampling  regime  to  identify 
hazardous  materials,  health  monitoring  plans97,  safety  trainings  and  monitoring, 

94 https://shipbreakingplatform.org/wp-content/uploads/2023/12/Turkey-Report-2023-NGOSBP.pdf.  
95 https://environment.ec.europa.eu/topics/waste-and-recycling/ships/site-inspection-reports_en   
96 131 plots are operational out of 153.  
97 The SRR requires to put in place a health monitoring system to reduce the health risks for the workers, based 
on  relevant  ILO  and  IMO  guidelines,  which  entail  (1)  establishing  an  Occupational  Safety  and  Health 
management systems and (2) make arrangements for the identification and periodic assessment of the hazards 
and risks to safety and health from hazardous ambient factors. This concerns for example adequate competence 
and training as well as medical surveillance. The ILO’s Safety and health in shipbreaking: Guidelines for Asian 
countries and Turkey consider that the following types of hazardous substances may require appropriate health 
surveillance: (a) substances (dusts, fibres, solids, liquids, fumes, gases) that have a recognized systemic toxicity 
(i.e. an insidious poisonous effect); (b) substances known to cause chronic effects; (c) substances known to be 
sensitizers, irritants or allergens; (d) substances that are known or suspected carcinogens, teratogens, mutagens 
or harmful to reproductive health. The inspection of yards by the Commission also comprises checks based on 
the methodology by the European agency for safety and health at work. When checking the health surveillance 
system in place in yards, the inspection evaluates if relevant parameters are included, such as x-ray of lungs 
(important for checking disease caused by asbestos), blood tests, (i.e. lead), liver, kidney and hearing tests. 

25 

 
 
 
environmental  monitoring,  leakage  control  in  the  intertidal  zone  and  handling  of 
hazardous materials only on impermeable floors with effective drainage systems.   

Implementation of the higher standards required by SRR in third countries is also reflected in 
the  cost  structure  with  significant  more  budget  allocated  to  labour  costs,  ship  cutting  costs, 
waste  disposal  and  other  environmental  compliance  costs  compared  to  yards  in  the  same 
country not meeting the same standards (see section 4.1.2 for illustrative example). 

The positive impact on the general situation can however be considered as limited by the 
fact that many ship recycling ship recycling facilities in South Asia have not applied to join the 
European List and continue to  operate under poor environmental  and health conditions. No 
applications were registered for ship recycling facilities located in Bangladesh and Pakistan.  
Only 46% of respondents in the public consultation had positive views on the contribution of 
the SRR to the reduction of disparities between EU and third country facilities. NGOs and 
academic and research institutions are generally of the opinion that the regulation had no effect, 
or  negative  effect  on  reducing  disparities.    Companies,  business  associations  and  public 
authorities are generally of the opinion that the SRR had an effect to some or a large extent. It 
can be noted that NGOs point to the general environmental and health record of South Asian 
beaching yards that remains of concern98 but also for the ship recycling sector in Türkiye99. On 
the other hand, shipowners and some Member States regret that the European List has not yet 
integrated some yards from India.  

Despite  these  mitigated  views  on  the  reduction  of  disparities,  82%  of    respondents  to  the 
targeted survey and 86% to the public consultation were of the opinion that the SRR has 
contributed to mitigating adverse impact on health caused by ship recycling. This figure 
rises to 89% when considering the Regulation's positive impact on the environment. This 
opinion was globally consistent across all stakeholder groups. The positive contribution is most 
often associated with the stringent criteria for ship recycling facilities and to the independent 
inspections in applicant and EU listed facilities in third countries. However, it is noteworthy 
that 67% of NGO respondents in the public consultation hold a different point of view, stating 
that the Regulation had no effect.  

The fact that the SRR has been in place and represents an indisputable benchmark for 
sustainable ship recycling has been recognized well beyond the EU. The SRR had helped 
maintaining  the  issue  of  ship  recycling  sustainability  on  the  international  agenda  and 
contributed to convince countries to ratify the Hong Kong Convention, as a recognition that 
sustainability requirements were needed for this sector. It has also provided incentives for the 
shipping  and  recycling  sectors  to  improve  their  practices.  One  indicator  for  the  overall 
amelioration in ship recycling practices is the fact that an important number of yards in India 
and some in Bangladesh have been certified by class societies in the last 5 years as ‘compliant’ 
with the requirements of the Hong Kong Convention.  Although this is far from the threshold 
set in the SRR, and this certification is not as stringent as inspection by the Commission, this 
still demonstrates a willingness to improve ship recycling conditions. This upgrade is, at least 
partly, inspired by the SRR and its European List, either because these yards see this as a first 

98  The Shipbreaking Platform points particularly to Bangladesh’s record of fatalities and injuries in the period 

2018-2022. See also Trading Lives for profit, Human Rights Watch (2023). 

99  See NGO Shipbreaking Platform, Ship Recycling in Turkey, Challenges and Future Direction (2023). 

26 

 
 
 
step  towards  the  European  List,  or  in  order  for  them  to  demonstrate  green  credentials  and 
compete with Facilities on the European List.   

As far as the impact on environmental and health of the SRR in the EU is concerned, it has 
been limited. Yards located in the EU have also to comply with the specific criteria, which 
were not in force before the SRR and are specific to ship recycling. The SRR has therefore also 
contributed  positively  to  raise  standards,  and  thereby  to  mitigate  environmental  and  health 
adverse effect of ship recycling in yards dismantling vessels within the scope of the EU SRR. 
The  impact  is  however  much  more  limited  than  in  third  countries  as  more  general  EU 
environmental and health standards were already applicable in yards located in the EU100.  

Among the key limitations regarding the general objective of the SRR is the fact that a large 
proportion of EU-flagged vessels has been re-flagged to other jurisdictions before dismantling 
and  hence  did  not  get  recycled  in  Facilities  on  the  European  List,  but  in  yards  with  less 
advanced standards.  This is further developed under the next question.   

The impacts of the SRR are mainly presented in a qualitative due to the limitations with respect 
to quantification.  Quantitative data on the impact are limited for a number of reasons.  

On the protection of the marine and coastal environment, it is often not possible to quantify 
the progress made, as the effect can only be observed on a medium term, especially considering 
the ship recycling sector is operating under very fluctuating market conditions.  There is also a 
lack of specific data covering the period before the beginning of the application process for 
individual yards. This can be explained by the fact that the ship recycling sector is composed 
of SMEs and is not always operating under very transparent conditions but also by the absence 
of proper environment monitoring in yards in third countries before the application process. 
The availability of data over a longer period should change in the future for Facilities on the 
European List, which have to carry out comprehensive environmental monitoring programmes 
at regular intervals. However, due to weaknesses in the sampling methodology, characterized 
by a high degree of uncertainty in the data collection and handling, it will remain challenging 
to  reliably  compare  pollutant  concentrations  across  different  years,  thereby  limiting  the 
assessment  of  temporal  trends  in  environmental  impact.  This  also  suggests  that  the  SRR 
requirement in relation to environmental monitoring could benefit from further clarification or 
guidance  to  meet  and  measure  the  intended  objective.  Another  limitation  which  is  more 
difficult to address is that most yards, having applied for inclusion in the European List or not, 
are located next to each other, in very industrialised bays, so that the environmental positive 
impact  of  more  sustainable  ship  recycling  practices  remain  difficult  to  isolate  and  identify, 
especially for some parameters101.   

Regarding the impact on human health, data have been used in the evaluation report when 
available.  This  is  the  case  for  example  for  fatality  rates.    The  analysis  of  data  on  accidents 

100 The data on this aspect are very limited as this was not seen as an objective of the Regulation, as also outlined 
in  the  20212  Impact  Assessment.  Limited  data  were  found  in  literature  or  received  from  yards  in  the  EU 
regarding  impact  on  environment  and  health.  The  European  Recycling  Industries’  Confederation  (EuRIC) 
nevertheless raised the difference of level of standards between EU yards dismantling vessels under the scope 
of the EU SRR and other EU yards as an issue, which also attest a positive impact in terms of standards of the 
EU SRR on the first group (see also section on relevance/scope). 

101 This is the case for Aliaga in Türkiye but also for applicants located in Alang, India, which is furthermore 
accentuated due to the high tides and monsoon which have also an impact on the movement of sediments. 

27 

 
 
 
 
 
received  from  yards  that  have  been  included  in  the  European  List  from  a  number  of  years 
(including accidents frequency and severity rates) is challenging, as the sample and the period 
covered is too limited to conclude to any trends.  It can be noted that whilst individual health 
monitoring is required by the SRR and carried out by the Facilities on the European List for all 
workers, in line with ILO and IMO guidelines, there also limitations regarding the use of health 
data as indicator of impact due to the sensitivity character of these personal data.    

The difficulty of having a quantified baseline given the dynamic nature of the sector, and the 
indicative non-comprehensive nature of the indicators, means that a full quantification (and 
hence monetization) of the SRR impacts is not possible.  

How successful has the SRR been in ensuring that EU-flagged ships are dismantled in safe and 
environmentally sound facilities worldwide? 

Meeting  this  objective  requires  that  the  European  List  of  ship  recycling  facilities  includes 
recycling yards that operate according to safe and environmentally sound standards, which is 
done  through  setting  clear  requirements,  ensuring  proper  compliance  assessment  and 
monitoring, including through inspections, and transparent management of the list. The latter 
should have sufficient capacity and be used by EU-flagged ships at their end-of-life.  

At  the  end  of  2023,  45  ship  recycling  facilities  were  included  in  the  European  List  of  ship 
recycling facilities.  Out of these 45 facilities, 33 facilities are located in 13 countries of EU, 
EEA and UK Northern Ireland102 and 12 facilities are located outside the EU, in Türkiye (9), 
United Kingdom (2) and USA (1).  Including these 12 facilities, the Commission has received 
a  total  of  57  applications  from  third  country  facilities,  including  27  from  India,  19  from 
Türkiye103, 3 from the UK, 2 from USA, 4 from China and 1 from Bahrein.  

The  positive  impact  of  the  SRR  is  often  linked  to  the  SRR  standards  associated  with 
independent,  transparent  and  professional  auditing  system  carried  out  by  the 
Commission in third country facilities. The answer to the previous question described the 
concrete  measures  and  investments  the  applicant  yards  have  taken  to  improve  working 
conditions  and  to  mitigate  pollution,  changing  dismantling  practices  and  improving  the 
treatment of hazardous waste. This was done with the view to comply with the SRR standards 
and be included in the European List. The compliance assessment is a thorough process which 
lasts several years and includes several inspections.104  

Once  in  the  European  List,  the  facilities  in  third  countries  are  also  subject  to  regular 
monitoring, including a mid-term review and an assessment for their renewal, as facilities are 
included in the European List for a period of 5 years. In that context, it should also be noted 
that most stakeholders, including the industry, reacted positively to the Commission's decision 
to  remove  two  yards  located  in  Türkiye  from  the  European  List  in  2022,  underlining  the 
importance of maintaining high standards, noting the effectiveness of the EU audit system, 

102 Harland and Wolff (Belfast) Ltd located in UK Northern Ireland remains included in ‘Section A – Member 
States’ of the European List, in accordance with the Protocol on Ireland/Northern Ireland (‘IE/NI Protocol’). 
See Article 185 of the Withdrawal Agreement. 

103 One yard that was removed from the European List in 2022 has applied again for inclusion (i.e 2 applications 

linked to 1 yard). 

104 Typically, these facilities undergo 2-3 inspections over 2-3 years before inclusion in the European List. 

28 

 
 
 
including  taking  remedial  action  where  necessary.  One  yard  was  de-listed  due  to  a  lack  of 
transparency on ship  dismantling  operations  and the  second because it failed to  sufficiently 
protect its employees’ working conditions.  These two yards were also subject to a request to 
the Commission to take action. This mechanism, provided by the Regulation for any natural 
or legal person affected or likely to be affected by a violation of the SRR, has been used by an 
NGO  and  proved  to  be  effective  to  request  to  investigate  the  compliance  of  the  facilities 
following fatal accidents. 

Literature and interviewees also point to a number of areas for improvements with respect to 
the  modalities  of  implementing  the  control  mechanism  provided  by  the  SRR.  The  first  one 
relates to the fact that conditions sighted during inspections often diverge from the day-to-day 
reality of ship recycling yards, when facilities in third countries are informed about inspections 
by  the  Commission.  To  address  this  challenge,  the  Commission  started  in  autumn  2023  to 
conduct unannounced inspections105. This is now seen as an essential tool for ensuring the 
effectiveness of the SRR.  Member States and NGOs have also requested to address in a more 
effective and transparent way the situations where non-compliance and/or deficiencies are 
detected during inspections of facilities located in third countries, considering for example the 
possibility to suspend the inclusion in the European List of a given yard.106  NGOs and ship 
recycling facilities located in the EU have also raised the need for further clarification of the 
standards for establishing compliance and inclusion in the European List to ensure a better 
level  playing  field,  in  particular  between  yards  located  in  the  EU  and  third  countries.  The 
standards and their effective implementation are considered not sufficiently aligned with the 
EU safety and environmental acquis relevant to ship recycling operations and downstream 
waste  management.  The  concerns  regularly  raised  relate  to  insufficient  criteria  to  evaluate 
waste management and steel recovery operations, for proper waste management and storage 
system by the yards, effective pollution control measures and use of cleaner technologies for 
dismantling and recycling activities. On the other hand, some other stakeholders consider as 
unbalanced  treatment  the  fact  that  the  SRR  does  not  provide  for  the  possibility  for  the 
Commission to carry out inspections also in yards located in the EU. Literature also highlights 
the  more  harmonised  and  transparent  process107  of  the  central  monitoring  of  non-EU 
facilities,  in  contrast  to  the  monitoring  of  EU  facilities  by  Member  States’  competent 
authorities108.  It  can  be  noted  that  the  SRR  does  not  set  any  specific  requirements  for 
monitoring, inspections and transparency for yards located in Member States. The authorisation 
procedures also vary among Member States.  These elements likely explain why only around 
40% of respondents to the public consultation considered the monitoring of facilities as very 
effective or effective, with similar result observed for the monitoring of facilities located in the 
EU and for facilities located in third countries. 

The active role taken by the Commission in the assessment and monitoring of facilities in third 
countries should still be linked to the fact that the certification from the independent verifiers 

105 At the time of the publication of the evaluation, 12 unannounced inspections had been organised in Türkiye. 
106 Article 14(4) provides for the possibility for Member States to suspend the authorisation of a yard located on 
their territory or require corrective actions, where a facility ceases to comply with the requirements of Article 
13.  An equivalent reference does not exist for facilities located in third countries. 

107 All inspections reports are published  https://environment.ec.europa.eu/topics/waste-and-recycling/ships/site-

inspection-reports_en.  

108  Hadjiyianni.  I,  and  Pouikli.,  K.,  The  Regulatory  Landscape  of  Ship  Recycling:  Justice,  Environmental 

Principles, and the European Union as Global Leader, 2024 

29 

 
 
 
attesting the compliance of the yard with the SRR appears not to fulfil the intended purpose. 
The consecutive inspections by the Commission of facilities which had already been subject to 
certification by an independent verifier often showed that this certification did not provide the 
expected results in terms of stringency in verifying compliance with SRR requirements. This 
led the Commission to reverse the initial balance envisaged in the SRR between the inspections 
carried out by independent verifiers (systematic) and the Commission (optional risk-based) to 
rely predominantly on its own inspections. 

To  assess  the  effectiveness  of  the  European  List  the  number  of  vessels  which  have  been 
dismantled in the yards included in that List must also be taken into consideration. 135 EU-
flagged vessels subject to the SRR were dismantled in facilities that are on the European List 
during the period 2019-2023. The EU SRR aims at dismantling 100% of EU-flagged ships in 
facilities  that  are  on  the  European  List.    All  vessels  flying  an  EU  flag  at  dismantling  were 
recycled  in  facilities  that  are  on  the  European  List,  with  only  very  limited  exemptions. 
However, 108 vessels which flew the flag of a Member State less than 1 year  before being 
recycled ended up in facilities that are not on the European List. While the formal objective of 
100% of EU-flagged vessels recycled in facilities on the European List was therefore formally 
achieved, the percentage of vessels flying an EU flag 1 year before dismantling that were 
recycled in facilities on the European List is a better indicator of effectiveness. As shown 
in the table below, there is a positive trend towards a higher proportion of EU-flagged vessels 
dismantled in facilities on the European List in the period 2019-2023. This percentage has 
increased from 33% to 86% if we consider the number of vessels and from 13% to 79% 
if we consider the weight of the ships concerned (in LDT). This increase might be explained 
by the regular extension  of the European List to  new ship  recycling facilities (especially  in 
Türkiye),  which  have  been  dismantling  a  large  share  of  EU-flagged  vessels,  as  well  as  an 
interest by shipowners to ensure that their ships are dismantled in facilities on the European 
List. The positive trend appears clearly in terms of absolute number of vessels but needs to be 
confirmed regarding the biggest vessels, as only 2023 shows a significant progress109.  Yet, in 
the period 2019-2023, in average, almost 45% of the vessels flying an EU flag 1 year before 
being  recycled  (representing  more  than  65%  in  scrap  weight)  were  not  dismantled  in 
facilities on the European List. To a very large extent, this gap is due to the practice of 
re-flagging described in section 3. 

109 Another reason to consider these numbers with caution is that the overall number of vessels concerned remains 

limited and the ship recycling market is heavily dependent on market fluctuations. 

30 

 
 
 
 
 
Table 3: Evolution of EU-flagged vessels scrapped in facilities on the European List between 2019-2023 compared 
to the scrapped vessels that still had an EU flag 1 year before being recycled (in absolute numbers and in LDT)110  

s
l
e
s
s
e
v

f
o

r
e
b
m
u
N

T
D
L

Number of vessels recycled in recycling 
facilities that are on the European List 
 Number of vessels recycled in facilities that 
are not on the European List 
 Percentage of vessels recycled in facilities 
on the European List 
Market share represented by EU-flagged 
vessels recycled in facilities on the European 
List out of the total number of vessels 
recycled worldwide 
LDT recycled in facilities that are on the 
European List  
LDT recycled in facilities that are not on the 
European List112   
Percentage of LDT recycled in facilities that 
are on the European List 
Market share represented by EU-flagged 
vessels recycled in facilities on the European 
List out of the total recycled worldwide in 
LDT 

Source: Support study based on EMSA data. 

2019111 
15 

30 

2020 
36 

33 

2021 
35 

29 

2022 
24 

12 

2023 
25 

4 

33% 

52% 

55% 

67% 

86% 

3.5% 

6.1% 

5.9% 

5.7% 

6.7% 

67,138 

257,655 

121,843 

96,284 

93,171 

443,735 

315,957 

362,156 

112,033 

24,694 

13% 

45% 

25% 

46% 

79% 

2.6% 

5.1% 

2.6% 

2.8% 

3.6% 

For 2021 and 2022, the majority of the vessels that were flying an EU flag 1 year before being 
recycled were dismantled, in order of largest volume to lowest volume, in Pakistan, Türkiye, 
and Bangladesh, with smaller shares being recycled in India and the EU.  

The table below  indicates for Member State  the  cumulated volume of vessels for 2021 and 
2022  that  were  registered  under  national  flag  1  year  before  being  recycled  per  dismantling 
destination in South Asia.  

Table 4: Cumulated volume (GT) for 2021 and 2022 of EU-flagged vessels (including re-flagged vessels) 
recycled in South Asia and the percentage it represents out of the total recycled for the flag state during 
that period. 

Vessel flag 
Croatia 
Cyprus 
Denmark 

Bangladesh 

India 

Pakistan 

- 

12,705 (6.68%) 
2,887 (5.72%) 

- 
51,049 (26.82%) 
- 

30,770 (92.69%) 
102,875 (54.05%) 
- 

110 Vessels for which the shipbreaker is unknown were excluded from the calculation. 
111 The requirement for shipowners to recycle EU-flagged ships in approved facilities included in the European 
List  started  to  apply  since  31.12.2018,  even  if  the  first  publication  of  the  European  List  took  place  in 
12.12.2016. 

112These numbers are very similar to the average figures on re-flagging. They however do not fully match due to 
the  following  reasons:  1)  some  vessels  were  excluded  from  these  calculations,  mainly  due  to  unknown  or 
uncertain scrapping locations; 2) certain vessels, despite being re-flagged, were recycled in Facilities on the 
European List; 3) some vessels, although not re-flagged, were recycled in non-Facilities on the European List. 

31 

 
 
 
 
 
 
 
 
 
 
 
 
Vessel flag 
Greece 
Italy 
Malta 
Norway 
Portugal 

Bangladesh 

India 

87,407 (26.87%) 
- 
135,401 (47.16%) 
- 
9,600 (27.89%) 

31,183 (9.59%) 
21,291 (15.78%) 
2,070 (0.72%) 
112,116 (28.32%) 
24,819 (72.11%) 

Pakistan 
197,631 (60.76%) 
- 
- 
- 
- 

Source: Elaboration by consortium that carried out the support study based on data of NGO Shipbreaking 
Platform and EMSA. 

The  above  figures  illustrate  that  the  effectiveness  of  the  EU  SRR  has  been  substantially 
undermined  by  the  practice  of  re-flagging  ships.    Though  it  could  be  considered  as  an 
unintended effect of the SRR, it should be noted that the Commission had identified the risk 
of  re-flagging  in  its  impact  assessment  and  included  related  measures  in  its  proposal  for  a 
regulation in 2012. The flag state, as defined by the United Nations Convention on the Law of 
the  Sea  (UNCLOS),  has  overall  responsibility  for  the  implementation  and  enforcement  of 
international maritime regulations for all ships granted the right to fly its flag. Changing flag 
allows the shipowners to change the legal regime for the ship.  Changing of flag is a common 
practice along a ship's life. While UNCLOS requires a ‘genuine link’ between the ship and the 
flag  under  which  the  ship  operates,  this  requirement  is  not  defined  and  therefore  often  not 
implemented. According to UNCTAD, more than 70 per cent of the fleet (tonnage) is registered 
under a flag which is different from the country where their owners are based113. The possibility 
to change flag represents however a well-known challenge for the effectiveness of a number of 
legislations at national, European and International level114. For ship recycling, there is a serious 
risk  of  non-compliance  as  long  as  two  recycling  markets  (one  compliant  with  higher 
requirements and one not) are co-existing and competing. Some interviewees point to the low 
ship recycling market in the EU as an indicator of the low effectiveness of the SRR.   

As  explained  in  section  3,  the  substantial  cost  differences  between  dry-dock,  alongside  or 
landing methods and beaching methods remain a challenge to achieve the SRR objective, as 
recycling facilities on the European List face competition from facilities with a distinct cost 
structure.115   The  competitive  advantage  of  facilities  operating  under  the  ‘beaching  method’ 
was expected to decrease with the listing of compliant facilities in China and, to address the 
residual  risk,  the  Commission  proposal  included  a  provision  to  impose  penalties  to  the 
penultimate  owner  of  an  EU-flagged  ship  if  this  ship  is  not  flying  anymore  the  flag  of  an 
European Member State within less than six months after the selling and sent for recycling in 
a facility which is not included in the European list. The proposal was however not retained by 
the co-legislators, notably due to opposition by some Member States. The SRR therefore does 
not contain any provision designed to prevent the practice of re-flagging a vessel, when such 
re-flagging is done for the purpose of circumventing the obligation for a shipowner to dismantle 
the vessel in an EU-listed yard.   

113 UNCTAD, Review of Maritime Transport (2019). 
114 See Setting the course for a sustainable blue planet, Joint Communication on the EU’s International Ocean 

Governance agenda. It includes in Annex specific measures  aimed at promoting the fulfilment of flag States 
responsibilities by those acting as open registers 

115 Solakivi et al. (2021): The European Ship Recycling Regulation and its market implications: Ship-recycling 

capacity and market potential, Journal of Cleaner Production, Vol.294, 20 April 2021. 

32 

 
 
 
 
 
If the incentive to have a ship dismantled outside Facilities on the European List is primarily 
financial, a contrario, the incentive to have a ship dismantled in an EU-listed yard, beyond the 
legislative obligation under the SRR, is  reflecting a preference of  shipowners to reduce the 
environmental and safety risks associated with  the dismantling  of vessels.  The  fact that the 
European  List  provides  for  legal  recycling  destinations  for  EU-flagged  ships  and  is 
underpinned  by  a  unique  monitoring  and  inspection  scheme  for  facilities  located  in  third 
countries,  allows  owners  to  send  their  ships  for  recycling  in  confidence  that  the  EU  partly 
shoulders  transactional  costs  and  reputational  risks.  Furthermore,  shipowners  can  avoid  the 
potential  consequences  of  non-compliance  such  as  penalties  imposed  by  the  competent 
authorities or negative campaigns by civil society or media.   

The obligation requiring EU-flagged ships to undergo recycling in certified facilities poses the 
question about the adequate capacity of these facilities to meet the demand from the shipping 
industry for recycling EU-flagged ships.  The insufficient  capacity of the  European List is  a 
concern which has regularly been raised by the shipping industry, arguing that the capacity is 
theoretical, used for other activities or other vessels than those covered by the SRR and not 
able to deal with large vessels116. The evaluation has however shown that the European List, 
featuring  45  yards  across  16  countries117  within  and  outside  the  EU,  has  ensured  so  far 
sufficient capacity for EU-flagged ships (including those re-flagged before being dismantled) 
to  be  recycled  in  safe  and  environmentally  sound  facilities. The  number  of  facilities  on  the 
European List has nearly doubled since 2018, with all facilities located in the EU that dismantle 
vessels in the scope of the SRR being in the European List.  In 2023, the list recorded an annual 
output in LDT of 1.3 million and a theoretical recycling capacity of around 2.6 million LDT 
for  facilities  active  in  ship  recycling.  Since  2018,  the  highest  annual  LDT,  combining  EU-
flagged and EU reflagged vessels, amounted to 0.6 million LDT only.  

116 See BIMCO, Report on the European List of Ship Recycling Facilities,  (2022) 
117 Figures based on the 10th edition of the European List of ship recycling facilities adopted in December 2022. 

33 

 
 
 
Figure 8: Different capacity measurements118 of the European List and EU-flagged vessels falling within 
the scope of the SRR recycled worldwide (including those that changed flag 1 year or less before being 
recycled) (2018-2023) 

 3.000.000

 2.500.000

 2.000.000

 1.500.000

 1.000.000

 500.000

 -

2018

2019

2020

2021

2022

2023

LDT volume of EU flagged ships recycled

Maximum annual ship recycling output (1)

Active recycling facilities (3)

LDT volume of EU reflagged ship (1 year before recycling)

Theoretical recycling capacity of European List SRF (2)

Source: Support study analysis based on different sources, including the European Lists of ship recycling facilities and EMSA 
data on re-flagging. 

The list also shows a diversified capacity in terms of size, with 10 yards119 capable of recycling 
in principle the largest vessels that have been re-flagged and dismantled in the past decade.120 
The capacity needs however to keep growing to face the forecasted demand  expected to 
peak in 2032 to almost 2.5 million LDT for EU-flagged vessels.121 The expected pressure on 
recycling capacity is the result of the large expansion of the merchant fleet in the 2000s that is 
starting to age and will likely be recycled with a decade.122  The expected demand will be more 

118 The European List refers to two different types of recycling capacity: (1) the Maximum Annual Ship Recycling 
output,  determined  by  selecting  the  highest  value  occurring  in  the  preceding  10-year  period  for  each  ship 
recycling  facility  expressed  in  LDT  and  (2)  the  Theoretical  Maximum  Annual  Ship  Recycling  Capacity, 
determined according to the facility's permit or data submitted. The actual recycling capacity is likely to lie 
between these two specified reference values. The ‘Active Recycling Capacity’ (3), concept introduced by the 
support study, considers only the yards that are operational and actively recycling ships, as opposed to those 
yards that may have capacity but are not currently recycling ships. The three metrics exceed existing recycling 
needs for the period analysed. 

119 Situation end of 2022 (10th edition of the European List). 
120  Over the past decade, 5 ‘very large vessels have been re-flagged and dismantled in South Asia. The two biggest 
had  a  length  of  332m  and  335m  and  both  a  width  of  58m.  Ecorys  on  the  basis  of  data  from  EMSA  and 
VesselFinder.  

121 Support study, p.51. It can be noted that the forecast trends may vary depending on the predictive models used, 
resulting in differences regarding the magnitude of the capacity gap and in the time of the peak for the demand. 
See also Tola .F, al, Demolition of the European ships fleet: A scenario analysis, Marine Policy, Volume 166, 
August 2024. 

122 Support study, p.51. Globally recycling is expected to grow from around 19 million LDT today to a peak of 
almost 25 million by 2032. Similarly Sustainable Shipping Initiative  2021, Exploring shipping transition’s 
transition  to  a  circular  industry  (Based  on  UNCTAD  2020),  indicates  that  tonnage  due  for  ship  recycling 
capacity is projected to double by 2028 and nearly quadruple by 2033. 

34 

 
 
 
 
than the theoretical recycling capacity of the facilities active in ship recycling at the end of the 
evaluation period and more than the double of their maximum annual ship recycling output. In 
time  of  general  high  demand  for  ship  recycling,  it  may  also  be  expected  that  a  number  of 
recycling facilities on the European List prefer not to recycle the biggest vessels, which will 
become  more  numerous  though.  The  capacity  of  the  European  List  remains  therefore  a 
significant concern expressed by the shipping industry. 

What  factors  have  affected  (positively  or  negatively)  progress  towards  ensuring  that  EU-
flagged ships are dismantled in safe and environmentally sound facilities worldwide? How was 
the Regulation enforced in that respect?  

In addition to the external factors presented in section 3 (Basel Ban Amendment, Covid-19 and 
China’s waste import ban), there are other factors that have affected negatively the progress 
towards  the  objectives  of  the  Regulation,  especially  linked  to  its  enforcement.    The  main 
challenges identified in relation to enforcement are the following123: 

-  Differences  in  costs  and  benefits  for  the  shipping  sector  between  EU  and  non 
Facilities  on  the  European  List:  as  illustrated  in  section  3  (‘economics  of  ship 
recycling’), an important reason for shipowners to send their ships for dismantling to 
non Facilities on the European List is that the prices offered by these yards for their 
ships  is  much  higher  than  in  facilities  on  the  European  List,  due  to  the  lack  of 
internalisation of the environmental and social costs linked to ship recycling practices 
and the higher prices for steel scrap; 

-  De-registering  and  re-flagging:  The  implementation  of  the  provisions  of  the  SRR 
related to the recycling stage and enforcement in relation to illegal ship recycling taking 
place in facilities that are not on the European List is often just not possible due to the 
re-flagging practice outlined in the previous sections and authorised under international 
maritime law. It should be noted that the SRR does not contain specific provisions on 
enforcement designed to avoid that ship owners circumvent the obligation to recycle 
EU-flagged end-of-life vessels in Facilities on the European List. Enforcement might 
be  pursued  in  some  cases  under  the  WSR  that  has  reportedly  offered  so  far,  a  more 
effective  basis  for  enforcement,  with  a  clearer  definition  of  ‘waste’  and  a  path  to 
investigate  and  address  violations  compared  to  the  SRR,  though  it  has  its  own 
challenges as referred to in section 2.1.   

The practice of re-flagging often covers cases of circumvention of the SRR but not only.  
The selling of the vessel to a cash buyer, frequently resulting in the de-registering of 
the vessel from its flag state and then also often followed by a re-flagging, creates a 
complicated and suspicious context for enforcement authorities, even when a ready for 
recycling certificate has been issued under the SRR for a dismantling in a facility that 
is  not  on  the  European  List.  Some  enforcement  authorities  have  expressed  concerns 
that, further to the re-flagging of the vessel, this vessel will not be dismantled in a EU-
listed yard, as it will not be under the control of the Member State any longer and not 
subject to the SRR. On the other hand, for some Facilities on the European List, the use 

123 See Study on enforcement Rambol, Ecorys, Grimaldi Studio Legale, ABS (2024) – to be published. 

35 

 
 
 
of a cash-buyer and the possible re-flagging of a vessel are part of normal commercial 
operations, with no intention to circumvent the SRR obligations.   

-  Complex  and 

legal 

intertwined 

framework: 

Implementing  and  detecting 
infringements  of  the  SRR  provisions  is  challenging  due  to  the  global  nature  of  ship 
operation and  recycling, a complex supply  chain involving  various stakeholders and 
limited transparency124. In addition to the difficulty to identify a vessel that is destined 
to be recycled and to trace its journey, cooperation between Member States and with 
third countries is challenging due to jurisdictional complexities. Determining which set 
of regulations applies due to the dual legal status of an end-of-life vessel as hazardous 
waste  and  ship  can  be  problematic  (See  Annex  VI).  This  is  even  more  complicated 
when a third country is involved and depending on whether or not he is a Party to the 
relevant Conventions. As a result, identifying the authoritative body responsible for 
enforcement is often problematic too. Obviously, the cooperation between different 
authorities in this context is also not easy to develop, considering distinct authorities 
are  responsible  for  matters  related  to  environment,  shipping,  and  judicial  affairs. 
Difficulty in cooperating with other competent authorities may be encountered within 
a  Member  State,  among  Member  States  and  with  third  country  authorities, 
although  much  needed  at  all  levels  with  the  view  to  prevent,  detect  and  take  action 
against suspected illegal ship recycling. 

-  Lack  of  specific  provision/definition  in  SRR:  The  lack  of  a  definition of  ‘End-of-
Life’ vessels in particular is reported as an issue for enforcement authorities to identify 
ships ready for recycling and detecting breaches of the obligation to recycle in Facilities 
on the European List, since the obligation for the shipowner to notify the flag state of 
the  intention  to  recycle  the  ship  seems  not  effective.  This  lack  of  clarity  makes  it 
challenging for enforcers to apply fundamental legal principles, such as the requirement 
to prove guilt beyond a reasonable doubt and the necessity to establish the defendant's 
intent.  Also,  the  definition  of  ‘shipowner’  is  often  reported  by  those  responsible  for 
enforcement and NGOs as too restrictive to allow investigation and prosecution of those 
that really took the decision about the illegal recycling of the ship. 

-  Lack  of  dedicated  national  provisions  implementing  the  SRR:  To  secure  the 
enforcement of its obligations, Article 22(1) of the SRR requires Member States to lay 
down  provisions  on  penalties  applicable  to  infringements  and  take  all  the  measures 
necessary to ensure that they are applied. The penalties must be effective, proportionate 
and  dissuasive.  The  evaluation  found  that  less  than  half  of  the  Member  States  have 
adopted all necessary measures to cover the possible infringements of SRR provisions. 
Most Member States have only adopted measures concerning some aspects of the SRR 
and  seven  have  not  adopted  any  specific  measures  on  the  basis  of  the  SRR.  These 
Member States rely on more general rules designed for addressing non-compliance with 
national environmental regulations on the handling of waste and shipment of waste125, 

124 For instance, when a ship is owned by a company domiciled in one country, flagged in a second, located in a 

third and then recycled in a fourth. 

125 11 out of 30 EU/EEA States have administrative or civil measures that are applicable specifically to all of the 
infringements of the SRR provisions. These MS includes BE, CZ, EL, FR, IS, IT, MT, NL, NO, PT and SI). 
12 EU/EEA States (BG, CY, DK, ES, FI, HR, IE, LT, PL, SK, RO and SE) have adopted some measures and 

36 

 
 
 
 
which undermines the effectiveness of the SRR.  When present, the level and typology 
of  sanctions  in  place  vary  significantly.  The  sanctions  are  often  too  low  and  not 
effectively discouraging non-compliance. In Belgium the maximum fine could however 
reach EUR 16 million126; in Spain, illegal ship recycling could result in disqualification 
from exercising any of the activities for a period of no less than 1 year and no more than 
ten years and in Denmark, France and Netherlands infringement could be punishable 
up  to  two  years  of  imprisonment.  It  can  be  noted  that  only  8  Member  States  have 
introduced  the  possibility  to  apply  criminal  sanctions  for  some  infringements  of  the 
SRR127.    In  some  Member  States  the  penalty  for  illegal  ship  recycling  is  only  a  few 
thousand euros.  

A problem of a different nature has also been reported, at least in one Member State, 
where several stakeholders indicated that the national or subnational legal frameworks 
did not allow them to obtain a permit for carrying ship recycling activities in line with 
the  SRR.  This  legal  obstacle  acted  as  market  barrier  for  them,  discouraging  the 
development of ship recycling activities in the country concerned.128 

-  Lack of expertise and training: Even though EMSA provides regular trainings, it has 
been reported that Port State Control Officers and officers in competent authorities and 
administrations often lack knowledge in environmental and technical aspects, as well 
as investigation tools to carry out investigation.  

- 

Insufficient  data  for  continuous  monitoring:  The  THETIS-EU129  platform  which 
records SRR related port state controls, is not used by all Member States as it is used 
only on a voluntary basis. Without sufficient information in THETIS-EU, it becomes 
challenging to generate alerts, initiated by either Member States or inspectors, which is 
a  key  support  for  selecting  vessels  for  inspection  and  identifying  potential  non-
compliance with SRR requirements. 

These  numerous  challenges  potentially  result  in  a  scenario  where  non-compliance  goes 
unnoticed.  

For the first Member States' triannual reports under Article 21 covering the period from 
January 2019 to 31 December 2021, almost all Member States (26 MS and Norway130) reported 
via  the  Dynamic  Overview  of  National  Authorities  (DONA)131.  Ten  Member  States132  and 

7 EU/EEA States have not adopted specific measures based on SRR and rely on waste and waste shipments 
legislation (AT, DE, EE, HU, LIE, LU and LV). Support study, p.76. 

126  In  BE,  minimum  level  of  penalty  is  EUR  500.  In  ES,  penalties  range  between  EUR  45,000  and  EUR  1.7 
million; in IT between EUR 5,000 and 0.3million; NL between EUR 25,750 to EUR 1.03 million; in IE up to 
0.3 million 

127 BE, EL, FR, MT, NO, CY, DK, FI, IS, NL, SE and SI 
128 See DMZ | German Maritime Centre, Sustainable ship recycling in Germany - a market study (dmz-maritim.de) 
129 THETIS-EU is used by 16 Member States and Norway for monitoring compliance. As its use is not mandatory 
it provides an incomplete picture in terms of inspections data. https://www.emsa.europa.eu/thetis-eu.html. 

130 Czech Republic and Iceland did not submit a report. 
131 The Dynamic Overview of National Authorities (DONA), is a stand-alone maritime application, developed, 
maintained and enhanced by EMSA which became operational in June 2022.  One of its functionalities is to 
provide a single-entry portal with restricted access, through which Member States could, if they opt to do so, 
fulfil their reporting obligations under EU maritime legislation. The SRR is one of the three legal acts covered 
by the portal in its initial phase. 

132 Belgium, Croatia, Cyprus, Denmark, Greece, Italy, Malta, The Netherlands, Spain and Sweden 

37 

 
 
 
Norway identified 90 ships to whom they have issued a Ready for Recycling Certificate and 
provided specific details though often incomplete (e.g. 41% of the cases did not include the 
issue date of the certificate). A comparison with the MARINFO database shows that there are 
at least 9 ships that have not been reported by Member States, though falling under the scope 
of the reporting133. Only two Member States reported information on cases related to illegal 
ship recycling in non listed facilities.134 The limited dataset does not allow to draw trends and 
conclusion on the enforcement by Member States, on the basis of this first triannual reporting 
only. 

In light of the elements presented above (complex legal framework; absence of detailed and 
specific provisions on enforcement; insufficient  expertise), the enforcement  of the SRR has 
been uneven in the Member States, depending to a large extent on the commitments or interests 
by the relevant competent authorities to act in this field (see in that respect the question below 
relating to the involvement of Member States in the enforcement of the SRR).  It can also be 
noted  that  due  to  the  fact  that  the  SRR  is  still  relatively  new  and  due  to  the  difficulties  in 
enforcing the legislation, there is no case law related to the SRR. The case law in the field of 
ship recycling is still exclusively related to the Wate Shipment Regulation. 

How successful has the SRR been in ensuring the proper management of hazardous materials 
on ships? What factors have affected progress towards this objective and its enforcement? 

78% of respondents to the public consultation think that the SRR obligation to develop and 
maintain  an  inventory  of  hazardous  materials  (IHM)  is  ‘very  effective’  or  ‘effective’  in 
contributing to the objective. At the same time, only 49% have the same opinion on the control 
and enforcement.  

The EU requirements to prohibit/restrict the presence of specific hazardous materials on board 
vessels and to keep on board an inventory of hazardous materials are stemming from the Honk 
Kong Convention (even if the SRR contains additional materials). The aim of these provisions 
is  to  reduce  the  presence  of  toxic  materials,  as  well  as  to  inform  about  the  location  and 
quantities of hazardous materials present on board ships. This information is useful both during 
the operational life of the ship during any repairs and maintenance, as well as for ship recycling 
facilities  for  developing  the  ship  recycling  plan  for  the  vessel  concerned.  It  is  therefore  an 
important  instrument,  whose  quality  and  completeness  are  essential  to  ensure  safe  and 
sustainable dismantling practices.   

The SRR has triggered many efforts by the Commission and EMSA aimed at standardising the 
development and maintenance of IHM and providing standard procedures and trainings for port 
state control inspections135, based on relevant IMO Guidelines. However, data reported on a 
voluntary basis over the period 2021-2023 on SRR related port state control inspections that 
verified the inventory of hazardous materials show that 45% of inspections136 found instances 
of  non-compliance  with  the  SRR  and  that,  in  2023  in  54%  of  the  cases  of  non-compliance 

133 These concern only countries that have reported RFRC. 
134 Greece (1) and Italy (2). BE also reported an infringement case related to a vessel flagged out without notifying 
the Belgian Flag State of their intent to recycle the vessel. The vessel was heading towards a facility that was 
on the European List. 

135 EMSA trained 119 inspectors over the last 4 years on the implementation of the SRR. 
136  761 out of 1,707 inspections, EMSA data based on THETIS EU.  

38 

 
 
 
 
concerning both the Inventory certificates and Statements of Compliance137, those documents 
were  just  missing.  At  the  same  time,  a  positive  trend  can  be  noticed  from  the  table  below 
regarding non-compliance rate and missing certificates.  

      5: Non compliances for inspections reported in THETIS EU carried out in 2021, 2022 and 
2023. 

Total inspections carried out 

Total inspections reported with non-compliances 

Non-compliance rate  

Missing certificate among the non-compliance issues 
which relate to the inventory certificates  

Missing statement among the non-compliance issues 
which relate to the statement of compliance 

Source: EMSA data (THETIS EU). 

2021 

950 

515 

54% 

90% 

78% 

2022 

472 

173 

37% 

52% 

66% 

2023 

285 

73 

26% 

42% 

59% 

For Member States to issue the ready for recycling certificates, the administration or recognised 
organisation  authorised  by  it  must  verify  the  IHM,  which  ultimately  will  supplement  the 
certificate.  While  IHMs  are  present  at  recycling  stage138,  there  is  a  general  call  for  more 
qualitative and reliable IHMs. The certification scheme does not seem to be a satisfactory 
indicator for the quality of IHM. The competitive context of survey services, the qualification 
of  the  persons  in  charge  of  preparing  the  initial  IHM  and  the  obtention  of  proper  Material 
Declarations and Suppliers Declaration of Conformity necessary for the development and 
maintenance of the IHM have been raised among underlying problems affecting the quality. 
IHM-Maintenance  is  also  often  reported  as  a  formal  exercise,  downgrading  the  quality  of 
IHMs, or not done at all. This remains largely undetected due to the absence of structured 
control and insufficient enforcement activities but also, as underlined by Member States, the 
lack of proper guidance for PSC Officers on how to check adequacy of IHM maintenance and 
take samples,139 and need for adequate tools for carrying out the investigations. (e.g. protective 
equipment and instruments for laboratory analysis).  Several interviewees underlined that the 
generally light penalties for not having an IHM on board140, combined with the fact that the 
document is not always checked for its quality or even presence, have led many shipowners to 
forgo the IHM as a cost-saving measure141.  Literature also notes that the lack of obligations 
for shipowners for pre-cleaning142  and decontamination from hazardous waste shifts ultimately 
the burden of handling the most hazardous materials often to those less equipped to do so143. 

137 The inventory certificate is the name of the certificate that includes the IHM issued  by Member States; the 

statement of compliance is the corresponding document to be issued by third countries. 

138 In facilities that on the European List and applicants, as sighted in inspections carried out by the Commission. 
139 2019 EMSA Guidance on ship recycling inspections do not refer only to paper checks but to controls that 
require specialised knowledge from inspectors that are not traditional Port State  Control Officers checking 
international conventions (as so far HKC is not in force). 

140 The administrative penalties differ significantly between countries. 
141 See also p.34 and Annex IV.  
142 The pre-cleaning refers to the initial process of cleaning before ship dismantling. It involves removing toxic 

substances, such as oils, fuels, and other hazardous liquids from the ship’s tanks and systems. 

143 Hadjiyianni. I, and Pouikli., K.(2024). 

39 

 
 
 
 
How successful has the SRR been in facilitating the ratification of the Hong Kong Convention? 

A significant increase in the number of ratifications can be noted in 2019 after the SRR became 
applicable.  The  European  Commission  encouraged  Member  States  to  prioritise  ratification, 
based on a Council Decision of 2014.144 Almost 50% of the countries that have ratified the 
Honk Kong Convention are Member states145.  While the EU has promoted the ratification of 
the Honk Kong Convention by Member States, it remains a prerogative of each government. 
The fact that the Honk Kong Convention has not been ratified by a number of Member States 
yet can be explained by a lack of priority in the Member State concerned or by the relationship 
between the second (minimum tonnage) and third (minimum recycling capacity) conditions for 
triggering the entry into force of the Honk Kong Convention  which created ‘the unintended 
effect’ of restraining large flag states from acceding to the Convention. Now that the conditions 
for the entry into force of the Honk Kong Convention have been met, other Member States are 
in the process of ratifying the Honk Kong Convention.  

It is difficult to assess to which extent the SRR also contributed to the ratifications of the Honk 
Kong Convention by non-EU Parties. What is clear is that the SRR had been since 2013 the 
only legal regime setting out specific requirements on ship recycling and that it was considered 
as an important benchmark by many stakeholders and authorities outside the EU. This made 
sure that the need for regulating ship recycling remained on the agenda of stakeholders in the 
maritime industry, and in turn pushed some of them to promote a global solution through the 
entry into force of the Honk Kong Convention.  After the criteria for entry into force of the 
Honk Kong Convention were met, most stakeholders agreed that the EC and the SRR played a 
role  in  facilitating  the  ratification,  though  the  opinion  was  more  negative  when  the  same 
question was asked earlier in the evaluation process. 

Are there unexpected or unintended effects that have occurred? 

Though the risk of circumvention of the SRR due to re-flagging had been anticipated (see also 
section 4.1.1.), the scale of the phenomenon had maybe been underestimated by the EU co-
legislator.  Another  effect  which  may  be  qualified  as  unintended  resulting  from  the 
implementation of the SRR is that the Turkish yards represented at the end of the evaluation 
period  more  than  half  of  the  capacity  of  the  European  List  and  Türkiye  being  the  first 
destination for dismantling EU-flagged vessels. 

To what extent have Member States and stakeholders been engaged in the process of improving 
implementation and enforcement of the SRR? 

Member States' commitment to the process of improving enforcement of the SRR has differed 
from  country  to  country.  While  some  have  actively  participated  in  meetings,  enforcement 

144 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32014D0241 
145  The  Member  States  that  ratified  the  HKC  are:  France  in  2014,  Belgium  in  2016,  Denmark  in  2017,  the 
Netherlands, Malta, Estonia, and Germany in 2019, Spain and Croatia in 2021, and Portugal in 2023. It can be 
noted that the ratification of some MS, could have led to compromising at some point the combined targets set 
by the criteria for the entry into force due to their significant share in world's merchant shipping. 

40 

 
 
 
network  and  reporting,  as  well  as  in  initiating  investigations,  some  others  have  been  more 
passive.  

Interviews highlighted the scarcity of human, technical, and financial resources allocated for 
SRR enforcement as an issue. When considering the associated costs, this had an impact on the 
low number of enforcement actions (including detentions and prosecutions) linked to possible 
breaches of the SRR. Belgium, France, Netherlands and Norway have been noted as having 
developed good legal framework and practices regarding enforcement of the SRR146. Italy as 
well has been particularly active in checking SRR under port state controls, detaining vessels 
until  compliance  is  demonstrated  and  carrying  out  investigations  against  potential  cases  of 
illegal ship recycling. 

Different channels, including the meetings of the Commission expert group on ship recycling, 
are actively used to share data and perspectives on possible improvements of the SRR147.  The 
participation of Member States in the Commission expert group has generally been high, with 
an average attendance rate of around 75% of Member States present in the period 2018-2022. 
Two important flag states, namely Cyprus and Greece, used to have a very low attendance rate, 
which triggered the European Commission in 2020 to send letters to invite these Member States 
to intensify efforts to ensure an effective and successful implementation of the SRR. This had 
at least the effect to increase their participation to the meetings. Several Member States are also 
engaged  in  the  European  Union  Network  for  the  Implementation  and  Enforcement  of 
Environmental Law (IMPEL)148 Ship Recycling Project. The main objective of this network is 
to  exchange  information  and  best  practices  between  the  various  authorities  involved  in  the 
implementation and enforcement of the regulations on ship recycling.149 In 2023, it has also 
issued Guidance for relevant stakeholders on the EU’s Ship Recycling Regulation and Waste 
Shipment Regulation. Besides, bilateral cooperation takes place between countries within and 
outside the EU, which is however generally considered as limited and insufficient. 

The NGO shipbreaking platform has been very active in monitoring ship recycling activities 
and alerting enforcement authorities on possible illegal activities linked to ship recycling or 
fatal accident in the yards. They also regularly  publish valuable information and data about 
shipbreaking in South Asia and Türkiye and work on the promotion of innovative techniques.   

Stakeholders  were  also  very  active  during  the  evaluation  process,  which  shows  their 
commitment to improving the SRR implementation and enforcement.  

146 Study on enforcement, Rambol, Ecorys, Grimaldi studio legale, ABS, 2024 (not published). 
147 The expert group is composed of EU/EEA Member States and invited stakeholders (usually ISRA, ECSA and 

NGO Shipbreaking platform). 

148 IMPEL is an international non-profit association of the environmental authorities of the European Union 
Member States, acceding and candidate countries of the EU, EEA and EFTA countries and potential 
candidate countries. The project 2022-2024 aims at increasing the collaboration between environmental and 
maritime authorities involved in ship recycling, developing guidance material for better understanding of the 
WSR and SRR, share experience and knowledge and extend collaboration with European bodies, networks 
and NGOs.  https://www.impel.eu/srp/projects/ship-recycling 

149 The project is working with a core group with representatives from Norway, Sweden, Germany, UK 

(England and Scotland), Malta and Netherlands. Other active project members are coming from Albania, 
Belgium, Bulgaria, Denmark, Estonia, France, Iceland, Poland and Portugal. 

41 

 
 
 
4.1.2. To what extent was the SRR efficient? 

Are  the  costs  related  to  the  SRR  proportionate  to  the  benefits  (overall  and  for  different 
stakeholder  groups)?  Are  there  significant  differences  in  terms  of  costs  (or  benefits)  for 
Member States and different stakeholder groups, and if so, what are the underlying causes? 

Based on the opinions and data received from the surveys and interviews, the costs entailed by 
the SRR requirements are considered to have generally been low to moderate for implementing 
the requirements set by the SRR over the evaluation period. The compliance costs are difficult 
to isolate for the yards that were also seeking to comply with the Honk Kong Convention, as 
the  majority  of  the  requirements  from  the  EU  SRR  are  stemming  from  the  Honk  Kong 
Convention.  On  the  other  hand,  tangible  improvements  in  the  facilities  carried  out  to  be  in 
conformity  with  the  specific  requirements  of  the  SRR,  in  combination  with  the  feedback 
received during the consultation process, give reasonable reason to believe that the measures 
as  designed  have  resulted  in  a  positive  impact  on  the  health  and  environment.  It  was  also 
acknowledged  that  this  could  not  be  quantified  in  a  granular  manner,  and  monetised.  The 
assessment  on  costs  and  benefits  therefore  needs  to  take  account  of  limited  data 
availability, as well as a lack of a clear baseline of what would have happened in the absence 
of the SRR. Besides, the absolute value of the costs and benefits remains low, due to the limited 
overall impact of the core measures during the evaluation period, notably due to the effect of 
external factors (see section 4.1.1) but also by the fact the effectiveness of the core measures is 
hampered by a number of other factors (as re-flagging for objective 1 or weak enforcement for 
objective 2).  The combination of all these elements does not make it possible to perform a 
fully quantified cost benefit analysis but allows to draw overall prudent general conclusion 
on efficiency, largely based on qualitative data.  

From  the  stakeholders’  consultation,  it  came  out  that  more  than  70%  of  respondents  to  the 
targeted  survey,  including  national  competent  authorities,  recycling  yards  and  classification 
societies, consider the costs of the SRR to be proportionate – if not outweighed - by the 
benefits.  The  fourth  of  respondents  that  consider  the  SRR  is  inefficient  are  coming  from 
academics and civil society, shipowners and some ship recycling facilities150.  

Responses from the public consultation also indicate that a majority of stakeholders (46 out 
of 63 replies) recognise the brand value and increased reputation for the facilities included on 
the European List, bringing more commercial benefits to listed facilities.  Half of the 
recycling yards surveyed, seconded by shipowners and the steel industry, stressed this 
reputational benefits that results (all other things being equal) in positive evolution of 
revenues and investments.  No quantitative data on revenues, turnover and jobs were received 
to back up this qualitative feedback received in consultation. 

The positive impacts referred to under the previous section on workers health and safety as 
well as on the environment are also to be considered as benefits of the SRR for all stakeholder’s 
categories and for the society but as these were not quantifiable, they can’t be monetised either.  

150  Academic, research and civil society: 2 out of 3 responses; shipowners: 2 out of 4 responses and recyclers: 4 

out of 15 responses. 

42 

 
 
 
The costs entailed by the SRR requirements  are  generally  considered  low to moderate for 
implementing the requirements set by the SRR (See also Annex IV for an overview of benefits 
and costs). 

There was no mention of disproportionate costs for ship recycling facilities, which are mainly 
SMEs.  The most important compliance costs for this stakeholder group are the costs of putting 
in  place  systems  to  ensure  the  sound  management  of  recycling,  and  the  proper  response  to 
safety  and  environmental  risks.  These  costs  vary  considerably  depending  on  the  initial 
situation of each facility, and how much changes it needs to operate to meet the requirements 
to get on the European List, as well of the size of the yard. In addition to the investment costs, 
there  are  compliance  costs,  in  particular  for  yards  not  located  in  the  EU,  linked  to  the 
maintenance  and  repair  of  the  equipment  and  infrastructure  necessary  to  meet  the  EU 
requirements, as well as to operate on a daily basis in accordance with these rules. A longer 
period for dismantling vessels is also needed and represents indirect costs.   

For most of the yards located in the EU, the feedback provided during the consultation process 
for this evaluation is that compliance costs are limited. Recurrent compliance costs for listed 
facilities located in the EU are mainly linked to the development of a ship recycling plan for 
each vessel to be recycled, since general EU environmental and health standards were already 
applicable151.  The reported costs vary significantly between yards. Although the compliance 
costs are generally reported as limited, as evoked. under section 4.1.1. the European Recycling 
Industries’ Confederation (EuRIC) raised the difference of level of standards between EU yards 
dismantling vessels under the scope of the EU SRR and other EU yards as an issue affecting 
the level  of playing field within the EU. Insufficient quantitative data on further significant 
compliance  costs  were  however  communicated  by  facilities  in  the  EU  for  a  comprehensive 
monetization of these costs.  What is clearer is that the practice of re-flagging and significant 
difference  in  cost  structure  and  revenues  with  Asian  facilities,  and  to  a  lesser  extent  with 
Turkish  facilities,  did  not  remediate  their  competitive  disadvantages  (see  section  5).    The 
direct benefits of the SRR have therefore remained limited for these facilities. 

For yards located in third countries, which have to operate higher investments to upgrade their 
technologies,  machinery  (eg  purchase  cranes),  infrastructures  (eg  impermeabilize  floor, 
establishment of a proper drainage system) and procedures (eg ensure outer hull of vessels are 
only dismantled in impermeable floor) the compliance costs are more substantial. Investments 
are  nevertheless  lower  in  countries  like  the  USA  than  in  India.  In  India,  some  yards  have 
reported investments costs specifically attributed to the SRR of EUR 2.3 and 6 million.   Only 
limited data could be made available by the yards on compliance costs. The example below for 
a  20,000  LDT  container  vessel  dismantled  in  India  in  2023  aims  to  estimate  the  SRR 
compliance costs for a yard in that region through a comparison with a yard having sought only 
for Honk Kong Convention certification. This example has an illustrative character only and 
figures  are  to  be  considered  as  estimates  which  may  vary  based  on  the  vessel  individual 
characteristics,  and  market  conditions.152  For  yards  working  with  standards  to  obtain  EU 

151  Note that the requirement for a ship recycling plan will also be required under the HKC after its entry into 

force. 

152 Source not to be disclosed. Similar estimates have been received from different sources. 

43 

 
 
 
certification, the example below in Table 6 shows a lower cost for purchase of the end-of-life 
vessel and higher operational costs, resulting overall in additional profit for those yards.  

Table 6: Estimates of additional operational costs to meet SRR requirements for a SRF in South 
Asia. Costs are expressed in Euro per ton.  

Costs 

Ship Purchase Price 
Other dismantling costs (excluding investments and 
taxes on profit) 

Finance Cost 
Labor cost and other ship dismantling expenditure 
Waste disposal and other environment compliance costs 

Consumables 
Fixed Overheads 
Other Expenses 

Total dismantling costs 
Total costs 

Honk Kong 
Convention  
€ 490 

EU SRR 

€ 390 

€ 18 
€ 22 
€ 8 

€ 3 
€5 
€5 
€ 61 
€ 551 

€ 29 
€ 41 
€ 13 

€ 5 
€ 12 
€ 15 
€ 115 
€ 505 

For the shipping industry, the main costs and benefits linked to the  implementation of the 
SRR  are  firstly  relating  to  the  revenues  generated  by  the  sale  of  end-of-life  vessels  for 
dismantling. As indicated in section 3, these revenues are lower when the vessels are sent to 
Facilities on the European List, compared to  other yards. The difference  in  revenues  for an 
average vessel falling within the scope of the SRR is estimated at EUR 1.5 million. The number 
of vessels dismantled in Facilities on the European List has remained limited due notably to re-
flagging but there is no indication that the shipping companies which sent their vessels to these 
yards  suffered  from  any  substantial  competitiveness  disadvantages.  For  shipowners,  the 
expected  negative  economic  impacts  of  the  SRR153  on  their  operating  costs  in  the  short, 
medium  and  long  term  therefore  did  not materialise.  The  aggregated  additional  costs  paid 
over period 2019-2023 by the shipowners that sent their end-of-life vessels to facilities that are 
on the European List compared to dismantling costs in facilities that are not on the European 
List has been estimated to  a maximum  EUR 178  million 154.  The IHM-related costs can be 
considered as marginal for shipowners. The reported price for the preparation of an IHM by 
hazmat experts is usually between EUR 4,000-8,000. It varies depending on the type/size of 
the ship and the quality of the inventory provided.  The issuance of inventory certificate, 
which  is  often  done  by Recognized  Organisations  and  charged  to  shipowners,  costs  around 
EUR 5,500 for approval and EUR 2,100 for the survey. Direct regulatory costs for shipowners 
to elaborate and maintain a list of hazardous materials are also considered low to moderate by 
most shipowners who responded to the targeted survey155. However, the process of establishing 

153 As reflected in SWD(2012)47 Impact assessment, 2012. 
154 These ‘‘costs’’ are actually additional revenues that shipowners would have made by beaching the vessels in 
South Asia.  Elaboration based on the LDT of the vessels dismantled in facilities on the European List over 
the period 2019-2023, considering the respective market share EU and Turkish yards and respective price gap 
for selling vessels compared to rates for recycling in South Asia. 

155 Only 5 shipowners responded to the targeted survey but the result was confirmed in interviews. 

44 

 
 
 
 
 
 
and maintaining the inventory can be time-consuming and administratively complex, resulting 
in shipowners outsourcing these tasks to external suppliers. Maintenance costs are reportedly 
ranging  roughly  between  EUR  500-1,500  per  ship  per  year,  depending  on  the  amount  and 
complexity  of  the  service.  The  administrative  burden  of  providing  recycling  facilities  with 
necessary  information  to  recycle  the  ship  and  of  notifying  the  relevant  authority  is  also 
considered minimal by shipowners156.  

Costs  for  Member  States  (direct  compliance  costs,  enforcement  costs  and  administrative 
costs) are reportedly  low to  moderate.  It  should be recalled that for ship  recycling facilities 
located in the EU, the requirements of the SRR regarding approval and monitoring of facilities 
is  facilitated  by  the  fact  it  relies  mainly  on  national  permitting  procedures.    Competent 
authorities that provided data indicate mobilising on average 2 Full Time Equivalent (FTE) per 
country  working  on  issues  related  to  the  SRR  (excluding  Port  State  control  inspections). 
Reflecting this, an upper limit estimate of the costs for all Member States would be EUR 1.6 
million157. These are mostly used for conducting research on potential cases of violation and to 
perform checks and inspections of ship  recycling facilities.  Moderate costs are attributed to 
authorisations of ship recycling facilities on their territory (approximately 5-20% of total time 
dedicated by MS for the SRR) and to performing surveys of ships (equivalent to approximately 
30%, typically outsourced to recognised organisations). Costs associated with port state control 
and inspection of IHM, Ready for recycling certificates and statements of compliance are also 
considered low (approx. 5% of the inspection costs during Port State control), depending on 
the type/size of the ship and the quality  of the inventory provided.  Obviously, the more in-
depth an inspection is, the more expensive it is, but also the more effective it is for a proper 
management of hazardous materials. Inspectors implementing 2019 EMSA Guidance on ship 
recycling  inspections  are  not  traditional  Port  State  Control  officers  checking  international 
conventions. For these controls to be effective, several Member States in expert group meeting 
expressed the need for more training, resources, and investigation tools which has a cost, which 
should  also  be  considered.  General  enforcement  costs  (under  Article  22)  vary  substantially 
depending  on  the  type  of  administration  and  country  (from  3%  to  50%).  Finally,  costs  for 
reporting to the Commission are considered low, with still room for further rationalisation as 
suggested under the next question. The costs for cooperation with other national authorities 
are  also  considered  low,  which  however  may  also  suggest  a  relatively  limited  number  of 
initiatives  and  activities  conducted  in  this  regard.  Costs  incurred,  however,  vary  across 
Member  States  depending  first  on  the  importance  of  shipping  and  ship  recycling  for  the 
Member States but also largely on different implementation practices, enforcement powers of 
competent authorities (i.e. Port State, Flag State and environmental authorities) and resources 
allocated to implement and enforce the SRR. 

For  the  EU  budget,  compliance  costs  represented  around  0.75  FTE  and  EUR  3  million 
between 2016 and end of 2023, in order to cover the implementation of the SRR, with a special 
focus  on  the  daily  management  and  regular  updates  of  the  European  List  of  ship  recycling 
facilities  (including desk  assessments and inspections  of facilities  applying to  the European 
List and located in third countries). The budget for the latter has nevertheless been less than 
planned due to the putting on hold for more than 2 years of the applications from the facilities 

156 4 respondents to the targeted survey considered these costs as ‘low’ and 1 respondent as ‘moderate’. 
157 Based on 2 FTE for 20 most relevant Member States and a cost of EUR 40,000 per FTE.  

45 

 
 
 
located  in  non-OECD  countries.  This  budget  is  therefore  expected  to  increase  with  the 
constantly increasing number of active applications and facilities that are on the European List 
for which compliance assessment and monitoring have to be ensured. The lack of effectiveness 
of  the  independent  verifiers’  inspections  and  certifications,  combined  with  the  need  for 
monitoring by the Commission through unannounced inspections, have increased the tasks of 
the Commission and costs to be born by the EU. Impact on the longer term should be further 
assessed, including, for example, envisaging delegation of tasks to EMSA, yards bearing more 
costs related to inspections and increasing efficiency of controls by independent verifiers.   

Are  there  opportunities  to  simplify  the  legislation  or  reduce  unnecessary  regulatory 
costs/burdens without undermining the intended objectives of the intervention? 

Two thirds of respondents to the targeted survey see opportunities to simplify the legislation or 
reduce unnecessary regulatory burdens. No specific issue was raised regarding the relevance 
of  some  standards  and/or  procedure.  Digitalisation  was  suggested  by  a  limited  number  of 
respondents for making available ship recycling plans as well as for submitting documents for 
issuing  Inventory  certificates.  A  number  of  ship  recycling  facilities  outside  the  EU  suggest 
reducing the time to include recycling facilities in the European List as the process often takes 
years  and  several  inspections  before  compliance  can  be  confirmed158.  EU  ship  recycling 
facilities would like to see the update the European List more dynamic to reflect the approval 
of the permit at national level159. Both EU and non-EU ship recycling facilities also suggest 
decreasing the administrative burden by extending  the period of validity of inclusion in  the 
European List that is limited to 5 years160.  

As the effectiveness of the certification by the independent verifiers required for applications 
and  renewals  of  facilities  located  in  third  countries  shows  its  limit,  it  could  be  considered 
waiving that requirement for the renewals if the yard was subject to a recent inspection by the 
Commission. 

Regarding the Member States tri-annual reporting obligations required under Article 21 of the 
SRR, they are considered relevant as they are also included in the annual reporting obligation 
under the Honk Kong Convention and proportionate as  their scope and  frequency  are more 
limited  than  under  the  Honk  Kong  Convention  161.  Several  Member  States  have  however 
requested  the  Commission  to  consider  a  data  flow  between  the  reporting  portal  Dynamic 
Overview of National Authorities (DONA) and the future dedicating module on ship recycling 
of  the  IMO  Global  Integrated  Shipping  Information  System  (GISIS)  to  prevent  double 
reporting. 

158 The situation is different for each yard, but the quality of the initial application and the ability for a yard to 
respond quickly and comprehensively to the observations by the Commission are often key elements for the 
duration of the application process. 

159  The European List is updated twice a year by a Commission decision under the examination procedure and 
including a 4 weeks period for public feedback. Several interviewees also suggested to  extend from 5 to 10 
the validity of the inclusion in the list. 

160 Before its expiry the procedure for the renewal should be completed to secure the inclusion in the list. Several 

interviewees suggested to extend from 5 to 10 the validity of the inclusion in the list. 

161  See Article 12 of the Hong Kong Convention. 

46 

 
 
 
Another opportunity  for possible simplification  (raised by national  authorities and industry) 
relates to the need to ensure a smooth articulation between the regimes applying under the SRR 
and under the Honk Kong Convention related requirements, after the entry into force of the 
latter in June 2025 (i.e. recognition of certificates, reporting, tasks and role of port State control 
authorities…) (see as well section 4.1.3).  

4.1.3.  To what extent is the SRR coherent? 

To what extent is the SRR internally consistent and coherent? 

 Overall, the SRR is internally coherent and consistent, as supported by positive views of 
stakeholders. At the same time, it was mentioned in section 4.1.1.  that some concerns are 
raised regarding the clarity/scope of the definitions for ‘shipowner’ and ‘waste’. The latter 
relates  to  the  lack  of  a  definition  for  ‘End-of-Life’  vessels.  This  poses  a  challenge  for 
enforcement authorities in identifying ships ready for recycling and detecting breaches of the 
obligation to recycle in Facilities on the European List since the obligation for the shipowner 
to notify the flag state of the intention to recycle the ship appears not to be effective.  

Also, to  ensure coherence with  respect  to  the objectives pursued by the SRR,  the need was 
expressed  to  clarify  that  no  double  standards  should  apply  in  facilities  that  are  on  the 
European  List  for  recycling  vessels  falling  within  the  scope  of  the  SRR  and  vessels  falling 
outside its scope. 

In addition, the fact that there is no possibility to suspend the inclusion in the European List 
of a ship recycling facility located in a third  country, as  also  mentioned in  section 4.1.1 
(p.24), can also be considered as a lack of coherence as the SRR provides for this possibility 
for ship recycling facilities located in the EU under its Article 14.  

Finally, the coherence of Article 30(2) that relates to the review of the SRR 18 months before 
the entry into force of the Honk Kong Convention is questioned, both in terms of timeline and 
substance. Several stakeholders, specifically international associations, believe the article may 
need to be revised considering the disparities and lack of a comparable system in authorising 
ship recycling facilities between the SRR and the Honk Kong Convention 

To  what  extent  is  the  SRR  coherent  with  other  existing  EU  environmental  and  maritime 
legislation? 

The  coherence  with  other  existing  related  EU  environmental  and  maritime  legislation  was 
positively  assessed  to  a  large  extent  by  stakeholders.  This  applies  to  the  Port  State  Control 
Directive designed to establish common criteria for the control of ships by port States and the 
Flag162 that ensures that Member States effectively and consistently discharge their obligations 
as flag States. This was confirmed by the support study. Increased synergy163is underlined as 

162  Directive 2009/21/EC of the European Parliament and of the Council of 23 April 2009 on compliance with 

flag State requirements 

163   Directive (EU) 2024/1203 of the European Parliament and of the Council of 11 April 2024 on the protection 

of the environment through criminal law and replacing Directives 2008/99/EC and 2009/123/EC 

47 

 
 
 
it requires Member States to ensure that illegal ship recycling under SRR constitutes a criminal 
offence.  

The SRR only covers EU-flagged vessels within the limits defined by its scope. Other vessels 
which become waste in European waters are covered by the WSR (see Annex VI). While this 
was intended to avoid overlaps, it is also sometimes considered as not coherent and a source of 
confusion, since end-of-life vessels located in the EU are covered under different regulations 
based on their flag state. Stakeholders have also highlighted the different approach between the 
SRR and the WSR, pointing mainly to the differences in some definitions, and to the export 
ban.  On the latter point, the amendments adopted by the co-legislator in 2024 (see section 3) 
increases the coherence between the two legislations. 

To what extent is the SRR coherent with other relevant international policies and instruments, 
such as the Basel Convention and the IMO Hong Kong Convention? 

The SRR is largely consistent with the Honk Kong Convention, as it implements it in EU 
law: most of the provisions of the SRR therefore stem from the Honk Kong Convention. The 
SRR contains nevertheless additional and more stringent requirements. These relate in the 
first place to the European List and its criteria for inclusion, including requirements for yards 
to have impermeable floors and effective drainage systems, set up rapid emergency response 
systems  and  make  sure  that  waste  leaving  their  premises  are  managed  properly  afterwards. 
Besides, the SRR provides for  an independent  third-party certification and auditing  of third 
country facilities, as well as the possibility for natural or legal person affected or likely to be 
affected  to  request  the  Commission  to  take  action  vis-à-vis  facilities.    With  the  new  WSR, 
another  significant  difference  with  the  Honk  Kong  Convention  is  the  fact  that  all  vessels 
becoming waste in the EU cannot be exported outside the OECD. Finally, the SRR differs from 
the Honk Kong Convention in  that it has  expanded the list  of hazardous material  within its 
annexes  compared  to  the  Honk  Kong  Convention.  The  SRR  prohibits  the  use  of  Perfluoro 
octane sulfonic acid (PFOS) in new installations on ships (Annex I) and require this material 
and Brominated Flame Retardant (HBCDD) to be listed in the inventory of hazardous materials 
(Annex II).  Among the inconsistencies frequently reported, the notifications by the yards to 
the flag state authority (instead of the competent authority responsible for the ship recycling 
facilities under the Honk Kong Convention) before and after recycling has been reported as an 
issue by a few stakeholders. A more detailed overview of the differences between the Honk 
Kong Convention and the SRR is included in Annex X. 

The consequences of the entry into force of the Honk Kong Convention in 2025 can be assessed 
from different perspectives.  From a legal perspective, the two instruments are consistent. The 
Honk  Kong  Convention  provides  explicitly  for  its  Parties  to  take  more  stringent  measures 
consistent with international law, with respect to the safe and environmentally sound recycling 
of ships, in order to prevent, reduce or minimise any adverse effects on human health and the 
environment. The SRR also requires that consistency is ensured with relevant Appendix of the 
Honk  Kong  Convention  for  the  formats  of  certificates  established  to  implement  the  SRR.  
While seeing an added value to the higher standards, several stakeholders expressed concerns 
about the implementation difficulties that will emerge when both frameworks will be in force. 
Two Member States brought forward the risk of double certification and double regime under 
port state controls. There are small differences in some procedural or reporting aspects between 

48 

 
 
the  two  instruments.  If  this  proves  needed,  this  could  be  addressed  either  through  minor 
adjustments  of  the  SRR or  through  technical  guidance.  The  policy  perspective  is  addressed 
under the next evaluation question (see section 4.2) which concerns the EU added value.  

 Concerning the coherence with the  Basel Convention, with the new WSR amending the 
SRR,  the  EU  ensured  legal  compatibility  of  the  Union’s  legal  regime  with  its  international 
obligations under the Basel Convention, notably to take account of the entry into force of the 
Basel  ban  amendment  which  prohibits  the  export  of  hazardous  waste  from  OECD  to  non-
OECD countries.  This what done through ensuring that the ships covered by the scope of the 
SRR that are considered waste and are exported from the Union are made subject to the Ban 
Amendment. On the other hand, the export ban does not apply to those EU-flagged ships that 
have become waste outside the jurisdiction of a Member State. These ships can therefore get 
recycled in facilities located outside the OECD, as long as these facilities are included in the 
European List set out by the SRR. 

As a result, the SRR ensures that the legal regimes from the Basel and Hong Kong Conventions 
are applied together in a consistent manner in the EU and to EU-flagged vessels164. 

4.2.  How did the EU intervention make a difference and to whom? 

This section examines the evidence in relation to two evaluation questions focused on the EU 
value-added of the SRR. 

What has been the EU added value of the SRR compared to what could have been reasonably 
achieved by Member States acting alone? 

In the absence of an operational dedicated global instrument addressing the problems related 
to  ship  recycling  at  international  level,  a  large  majority  of  participants  to  the  consultation 
activities considered that SRR has provided a needed instrument at EU level to implement the 
Honk  Kong  Convention  provisions  within  the  EU.  87%  of  respondents  in  the  public 
consultation  answered  positively  to  the  question  on  whether  they  consider  the  SRR  to  be  a 
relevant piece of legislation, and better than if Member States were acting alone165.  

In  the  absence  of  the  SRR,  rules  related  to  ship  recycling  would  have  only  been  addressed 
through the WSR, which does not fully take account of the specificities of ships, making it 
therefore, challenging to tackle ship recycling issues. This, therefore, raises doubts that in the 
absence  of  the  SRR,  the  objective  of  reducing  adverse  effects  on  human  health  and  the 
environment caused by recycling EU-flagged ships could have been better achieved. 

By setting requirements to ships and ship recycling facilities on the basis of the Honk Kong 
Convention, the SRR provides at the same time the legal framework required from the Member 
States by the upcoming entry into force of the Convention. 

164 The issue of the interplay between the HKC and the Basel Convention is out of the scope of the evaluation and 

being addressed in the relevant international fora. 

165  59  out  of  63  replies.  The  opinion  is  shared  across  the  different  stakeholder  groups.  Note  that  the  public 
consultation on the evaluation took place before the numbers of ratifications necessary for the entry into force 
of the Honk Kong Convention  was reached. 

49 

 
 
 
To what extent do the needs/problems addressed by the SRR continue to require action at EU 
level? Should they be better addressed at global level? 

Arguments on the most appropriate level of legislation (EU or international) to address ship 
recycling  issues  differ  across  stakeholders166.    Stakeholders  from  the  shipping  industry  and 
some Member States consider that the issue of sustainable recycling would be better addressed 
globally through the Honk Kong Convention, underlining also the need for a level playing field 
at  the  global  level  and  the  fact  that  its  scope  would  be  sufficiently  broad  to  avoid 
circumventions through reflagging167.   

On the other hand, arguments in favour of continuing efforts at the EU level point out the higher 
level of ambition and scrutiny set by the SRR compared to the Honk Kong Convention. These 
are notably supported by NGOs, trade unions and ship recycling associations.  

Where the two groups meet is when evoking a possible revision of the Honk Kong Convention 
after its entry into force, where the EU should promote its higher standards at IMO level.  

Over  two-thirds  of  respondents  to  the  public  consultation  consider  that  the  European  List 
should  not  automatically  include  ship  recycling  facilities  having  received  a  Honk  Kong 
Convention certification, considering the stricter  requirements of the EU regulation168. Only 
3% of respondents to the public consultation think that the European List should be removed 
when  HKC  enters  into  force.  These  opinions  were  shared  across  the  different  stakeholder 
groups. 

The SRR reflects the EU’s recognition that it is necessary to go beyond the requirements of the 
Honk Kong Convention, to ensure that EU-flagged ships are only dismantled in yards which 
achieve  a  high  level  of  protection  of  human  health  and  of  the  environment  that  is  broadly 
equivalent to that in the Union. This is the justification for the additional provisions in the SRR 
on (i)  additional  criteria  on sustainable  recycling  in  Facilities on the European List  and  (ii) 
regular scrutiny by the Commission of the compliance of yards authorised to dismantle ships, 
to ensure that they effectively meet the criteria. A political decision would be needed to decide 
if the justification for keeping these provisions remains valid. This goes beyond the remits of 
the evaluation process.  

However, without prejudice to an upcoming political choice, it seems clear that the provisions 
of the Honk Kong Convention still fall short of what is required under the SRR on sustainable 
criteria for ship recycling. It is also too early to assess how the implementation of the HKC 
would work in practice, and especially if and how its Parties will take the necessary actions to 
ensure  that  shipowners,  recyclers  and  certifiers  effectively  comply  with  its  provisions.  The 
current  situation  in  many  yards  outside  the  European  List  (especially  in  South  Asia,  which 
remains the largest region for ship recycling) is far less advanced than for those in the European 
List and substantial progress will be needed for these yards to get to the level of Facilities on 
the European List. At the same time, other, more modern yards are being built and represent a 

166 Support study, p.97 on the basis of interviews and 14th meeting of Commission expert group on ship recycling, 

January 2024. 

167 The Honk Kong Convention has been ratified by the main recycling states (India, Bangladesh, Pakistan and 

Türkiye). 

168 This was also underlined in Commission expert group Meetings, including the International Ship Recycling 

Association in January 2024.   

50 

 
 
 
departure from ‘traditional’ ship recycling practices used in many parts of the world. It seems 
unreasonable to rely solely on the current Honk Kong Convention’s standards to ensure a real 
progress towards sustainable ship recycling.   

In absence of SRR and reliance only on the Honk Kong Convention, there is for example a 
serious risk that a significant number of yards which perform under poor conditions manage to 
obtain HKC certificates and become eligible for dismantling EU-flagged vessels. Many ship 
recycling yards have been certified as ‘Hong Kong compliant’ by classification societies in the 
last years, while it is clear that, for a number of them at least, they were operating under poor 
environmental  and  safety  conditions169.  It  is  currently  unclear  how  such  situations  could  be 
avoided,  once  the  Honk  Kong  Convention  enters  into  force.  This  is  a  serious  possible 
shortcoming  in  the  implementation  of  the  Convention,  which  should  be  addressed  in  that 
context. In the meantime, it does not seem sound to set aside the EU SRR and rely only on the 
Honk Kong Convention framework. 

The EU approach can continue to operate in conjunction with efforts to promote an ambitious 
approach to improve the criteria under the Honk Kong Convention and ensure that it is properly 
enforced. 

4.3. 

Is the intervention still relevant? 

Is the scope of the SRR still appropriate? 

The  need  to  ensure  EU-flagged  ships  are  dismantled  in  safe  and  environmentally  sound 
facilities and to ensure proper management of hazardous materials remains highly relevant, as 
shown in previous sections. The growing forecasts for the ship recycling market170 could be 
interpreted as indications that the SRR will become even increasingly relevant in the future. 
The  fact  that  the  Honk  Kong  Convention  will  enter  into  force  in  2025  does  not  affect  the 
relevance of the objectives set in SRR. It can be noted that an entry into force of the Honk 
Kong Convention in 2020 was part of the baseline scenario when the SRR was adopted171. 

60% of the participants to the targeted survey see a need for extending the scope of the SRR to 
non-EU-flagged vessels in order to harmonise the applicability of the legislation in the EU172 
or to address the issue of reflagging. Simply extending the SRR to non-EU-flagged ship has 
some  jurisdictional  limits,  especially  if  the  end-of-life  vessels  are  not  located  in  the  EU. 
Applying the concept  of  ‘beneficial owner’173 is  regularly  evoked  as a potential  solution  by 
NGOs and EU ship recycling facilities.  At the same time serious concerns are expressed by 

169  Situation  in  October  2024:  In  India  114  plots  (i.e  86%)  were  certified  compliant  with  the  Hong  Kong 
Convention, as reported by Indian authorities. Bangladesh had five certified yards with 15 more in the process 
of  approval.  The  Business  Standard  Towards  Green  Shipyards.  In  2024  a  tragic  explosion  in  one  of  the 
certified yards, killed six people including three workers and several safety officers. 

170  See also Annex VIII for estimates of recycling forecast. 
171   SWD(2012) 47 final. 
172 Eg. to include in the scope non-EU-flagged ships that become waste and/or recycled in the EU U 
173 The ‘Beneficial Owner’ is the ultimate beneficiary of any monetary gain from the use or sale of a ship and 
to 
scrapping  or 

often  makes 
the 
https://shipbreakingplatform.org/our-
work/glossary/#:~:text=The%20Beneficial%20Owner%20(BO)%20is,sell%20a%20vessel%20for%20scrap. 

final  decision  on 

recycling.  Support 

referring 

study 

51 

 
 
 
various stakeholders, including shipowners and some Member States about the complexity and 
effectiveness  of  such  a  measure.  One  reason  put  forward  is  the  difficulty  to  define  the 
‘beneficial owner’ in the sphere of the SRR, especially since the term has been used and defined 
differently in other pieces of EU and International legislation. Another argument is that it would 
be very difficult to identify the natural or legal persons corresponding to the beneficial owners, 
and therefore  to  avoid  legal  challenges when fine applied or  prosecutions launched,   as the 
entities  may  be  hidden  behind  shell  companies,  offshore  companies  or  ship  management 
companies. This is especially so as all maritime legislation rely primarily on the natural or legal 
person registered as the owner of the ship.  Besides stakeholders’ opinion, it could not be found 
any literature elaborating on this subject matter.  Full assessment of the feasibility, costs and 
benefits  of  implementing  such  a  concept  under  the  SRR  would  therefore  be  needed  in  a 
potential impact assessment. 

Another scope related measure regularly raised by NGO and EU ship recyclers to address the 
issue of circumvention is a financial instrument such as the ship recycling licence applying to 
all vessels calling at an EU port bridging the revenue gap between dismantling in facilities 
that are on the European List and in facilities not operating in a safe and environmentally sound 
manner. The possibility of such a financial incentive was referred to in Article 29 of the SRR 
and subject of one study in 2016 and a report of the Commission in 2017174.  All shipowners 
that participated to the consultation, oppose to the introduction of such instrument, arguing it 
would affect negatively the EU shipping sector as it would be applied only on a regional scale.  
Again, the evaluation, as a backward-looking exercise, is not meant to elaborate on measures 
destined to address the problems outlined in the evaluation. A dedicated study will cover that 
matter175. 

Finally,  the  extension  of  the  scope  to  smaller  vessels,  and  naval  vessels  is  also  regularly 
mentioned,  especially  by  EU  ship  recyclers  and  NGOs.    However,  stakeholders  provided 
limited evidence of a problem supporting their request. Stakeholders at the workshop discussed 
the recycling of ships of less than 500 GT and noted that smaller ships are often recycled within 
the EU. These observations are supported by data on ship recycling and reflagging, where the 
majority  of  reflagged  ships  are  larger  vessels.  The  European  Recycling  Industries 
Confederation (EuRIC) reported however the development of facilities within the EU that are 
not on the European List and only look for vessels out of the SRR. As these yards do not have 
to comply with the SRR, Member States would generally be laxer about the requirements and 
controls applying to them, creating an unlevel playing field within the EU and higher risks for 
pollution and workers health.  

Views on extending the scope therefore differ according to the stakeholder group. While almost 
all recycling yards, NGOs and environmental authorities that responded to the survey are in 
favour of extending the scope of the SRR, almost all shipowners and representatives of flag 
states and Port States expressed negative views. 

174 2016 study (Ecorys, DNV-GL), 2024 study (not available yet), COM(2017)420.  
175 An update of the 2016 study, carried out by the same consortium as the support study for the evaluation,  is 

planned to be published early 2025. 

52 

 
 
 
.How well adapted is the SRR to technical and scientific progress and EU and global market 
developments? 

New technologies for cutting (e.g. abrasive water jet cutting, pulsed laser), cleaning and coat 
stripping but also innovative systems relying on robotics to improve automation have recently 
been developed, mainly in Europe176. These could significantly reduce environmental hazards 
and improve worker safety linked to ship recycling. These measures have also the potential to 
improve efficiency of ship recycling in the EU177. Vessels using alternative fuels and authorities 
exploiting  satellite  images  for  monitoring  pollution  or  illegal  shipping  is  emerging.  Some 
studies highlight possible techniques to decontaminate seawater, whereas others focus on the 
ship-design stage to decrease cost and increase safety during dismantling operations178.  

Considering the fact that the level of uptake of most of these innovations, in particular at large-
scale, remains unclear to date, it cannot be concluded that the SRR accelerate innovations. The 
SRR however does not hamper these developments. It can be noted that the requirement of the 
SRR for certification as ‘safe-for-hot work’ are however interpreted by some ship recycling 
facilities as a difficulty for a ship to be ‘safe-for-hot-work’ even if it is being disassembled in 
a facility that would not use hot work179.  

Regarding the global market  developments,  the forecasts  for the ship  recycling market  (see 
section 4.1.1.), could be interpreted as indications that the objective of sustainability pursued 
by the SRR Regulation will become even increasingly relevant in the future. 

To what extent is the SRR still relevant and does it correspond to the needs within the EU, in 
particular as regards the new policy ambitions? 

Since the adoption of the SRR, both the policy and regulatory landscapes have considerably 
evolved.  It  is  therefore  opportune  to  assess  the  coherence  of  the  SRR  with  the  new  policy 
agenda.  

By  the  fact  it  focuses  on  the  environmentally  sound  management  and  storage  of  hazardous 
materials and waste, and that it increases energy and resource efficiency through the recycling 
of material (in particular scrap steel), the SRR corresponds to the objectives set out in the EU 
Green  Deal,  the  Circular  Economy  Action  Plan,  the  Zero  Pollution  Action  Plan,  the 
Sustainable Blue Economy Communication, the green transition under the EU taxonomy.180 

On  the  other  hand,  interviewees  underlined  the  potential  for  the  SRR  to  have  a  key  role  in 
supplying large amounts of high-quality scrap steel, which is needed for the decarbonisation 

176 In Türkiye, one applicant facility has recently started to operate with cold cutting method (shear) in the zone 

above the drainage. 

177 Shipbreaking Platform (2022) Breaking out – Anchoring circular innovation for ship recycling. 
178 Dey, A. (2021) Sustainability challenges and enablers in resource recovery industries: A systematic review of 

the ship-recycling studies and future directions. 

179 This certification would not be needed for yards using only cold cutting techniques and automated technologies. 

This is not the case yet for any of the facilities on the European List. 

180   COMMISSION DELEGATED REGULATION (EU) 2023/2486. Annex II of the Regulation refers to the 
facilities that are on the European List as substantial contribution to the transition to a circular economy. 

53 

 
 
 
of  the  industry  and  meeting  EU  climate  objectives.  Also,  recent  literature  points  to  ship 
recycling as a potential future source for secondary steel in green transformations181.  

Respondents to the consultations also generally believe that the SRR does not contribute to the 
EU's  industrial  strategy182. They  commented  that  certain  aspects  of  the  strategy,  including 
ensuring  a  competitive  EU  steel  industry  and  supply  of  raw  materials,  is  not  fully 
championed by the SRR due to the majority of EU ships being dismantled in non-EU recycling 
facilities, particularly Türkiye, allowing valuable EU scrap metals to leave the EU. Neither the 
SRR nor the Honk Kong Convention indeed specifically target steel recovery.  

EU steel market and ship recycling 

- EU production of crude steel: 126 million tonnes 

- EU consumption of steel: 138 million tonnes 

- EU consumption of scrap: 75 million tonnes 

- EU Imports of scrap of good quality: 3.9 million tonnes183 

The amount of steel scrap made available worldwide through ship recycling in the past 
years has been estimated to reach between 2.3 and 6.4 million tonnes on a yearly basis184.  
For the reasons mentioned in section 3, that steel scrap is not ending up on the EU market.  As 
explained in section 4.1.1., over the last years, the world fleet has been growing and ageing; it 
is likely that the number of end-of-life ships sent for recycling will therefore go up significantly 
in the next ten years, with a corresponding growth in the volume of steel scrap from end-of-
life vessels being made available on the market. At the same time, the demand for steel scrap 
is  also  expected  to  increase  considerably,  as  steel  scrap  is  an  essential  component  for  the 
decarbonisation of the steel industry, both in the EU and in the rest of the world185.  The steel 
scrap  stemming  from  EU-flagged  vessels  sent  to  recycling  over  the  evaluation  period 
represents around 0.65 million tonnes/year in average186. This represents a small proportion of 
the volume of steel scrap used in the EU every year but steel scrap from ship recycling is of 
very high quality, with low contamination levels compared to most steel scrap stemming from 
other industries. It can meet stringent specifications required for many industrial applications 
in the EU and hence represents a valuable resource. Around 4 million tonnes of high quality 
steel scrap are currently imported into the EU every year. Increased ship recycling in the EU, 
with a corresponding higher uptake of steel scrap from ship recycling, could provide the steel 
industry with a steady supply of quality scrap and reduce its import, especially important in a 
context where the demand for such scrap is expected to increase to meet the EU decarbonisation 
targets in the steel industry. Scrap from ship recycling could also be a good supplier for the 0.8 

181  Bleischwitz, R., Höller J., Kriegl M., (2023). Ship recycling – estimating future stocks and readiness for green 

steel transformation. Environmental Research Letters, November 2023. 

182  COM(2020)102 final. 
183  Eurofer, European Steel in Figures (2024), for the year 2023, crossed checked with some datasets of the market 

analysis of ESPR-steel. 

184  Bleischwitz, R., Höller J., Kriegl M., Ship recycling – estimating future stocks and readiness for green steel 
transformation. Environmental Research Letters, November 2023. Note that the global end-of-life scrap steel 
supply per year was estimated to 445 million tonnes in the IEA Steel Technology Roadmap.   

185  And steel demand is growing at a faster rate than scrap is being released from the pool of ‘steel in use’ See 

Worldsteel Association, Fact sheet, scrap use in the steel industry (2021). 

186  Based on Table 3. 

54 

 
 
 
to  1  million  of  steel  plate  consumed  annually  for  ship  buildings  in  the  EU.  An  even  more 
interesting use might be related to its dilution potential: diluting one tonne of high quality of 
scrap  from  ships  with  scrap of less good quality  could  result in 2  to  2.5 tonnes of scrap  of 
sufficient quality to be used in the EU187. It is also important to mention again in this context 
that the number of end-of-life ships sent to recycling is expected to go up significantly in the 
next  ten  years,  with  a  corresponding  growth  in  the  volume  of  steel  scrap  from  end-of-life 
vessels being made available on the market (estimated to 7 to 10 million tonnes of secondary 
steel coming from EU-flagged vessels to be dismantled over the next ten years188). 

Also,  the  SRR  does  not  set  GHG  emissions  targets  for  ship  recycling  companies.  Some 
participants to the consultation mentioned that in most cases the dismantling of EU-flagged 
ships  still  use  carbon-intensive  methods  per  ton  of  recycled  steel  compared  to  low-carbon 
methods available189. 

Acknowledging the contribution of the SRR to the transition to a circular economy, several 
respondents to the consultation consider nevertheless that the definition of ‘ship recycling’ in 
the SRR is too narrow to align with broader sustainability goals190. More generally, there are 
voices in literature and in the sector that underline that the SRR does not sufficiently consider 
the  life  cycle  approach  of  the  vessel,  through  cradle-to-cradle  design. The  inventory  of 
hazardous materials represents a first materialisation of such a life cycle approach  but the need 
for traceability of all materials  through a breakdown of materials, including their weight and 
location was underlined.  This would facilitate both the planning and operation of the recycling 
process.191  

5.  WHAT ARE THE CONCLUSIONS AND LESSONS LEARNED? 

The evaluation results show that the SRR has to a large extent achieved all its objectives 
compared to what could have been achieved has the EU not intervened. The effectiveness 
of the Regulation has however been significantly hampered by its circumvention through 
the practice of re-flagging, and to a lesser extent through weak enforcement of IHM related 
measures. This section outlines the evaluation’s main conclusions, highlighting the main areas 
where challenges have been identified and suggesting improvements. 

187 Estimations based on the Commission Joint Research Center, Preparatory study on iron and steel – ecodesign 

measures under the EU Ecodesign for Sustainable Products Regulation, draft report, 2024. 

188  Elaboration based on the 100-150 million tonnes of secondary steel from dismantled vessels over the next 10 

years estimated in Bleischwitz R., Höller J., Kriegl M., (2023). 

189  Although currently the percentage of lifecycle CO2 emissions emitted during shipbuilding and recycling is 
negligeable compared to that emitted during a ship’s operational life, the shift towards ships that operate on 
zero or low emission fuels and technologies will affect these percentages significantly, increasing the need to 
tackle the problem of and reduce CO2 emissions at other stages of the lifecycle See SSI (2021). 

190 The SRR defines ship recycling as ‘the activity of complete or partial dismantling of a ship at a ship recycling 
facility in order to recover components and materials for reprocessing, for preparation for re-use or for re-use, 
whilst ensuring the management of hazardous and other materials, and includes associated operations such as 
storage  and  treatment  of  components  and  materials  on  site,  but  not  their  further  processing  or  disposal  in 
separate facilities’. It has been suggested to expand the definition of ship recycling beyond a ship recycling 
facility’s activities, by including the entire lifecycle of materials to better fit the definition to circular economy 
goals. 

191  Jain,  Pruyn  and  Hopman,  2016;  Soares  and  Santos,  2014;  NGO  Shipbreaking  platform  2023;  Sustainable 
Shipping Initiatives, 2013. Some refer to a ‘Material Flow Analysis’, a ‘Material Passport’ or ‘cradle to cradle 
passport’. 

55 

 
 
 
Re-flagging 

The effectiveness of the first and main operational objective of the SRR to have EU-flagged 
ships dismantled in facilities approved by virtue of being included in the European List, has 
been significantly undermined by the practice of re-flagging ships. After re-flagging, these 
ships  often  reach  the  end  of  their  service  life  in  Bangladesh,  India  or  Pakistan,  effectively 
circumventing the obligations imposed by the SRR. Between 2016 and 2023, ships flying an 
EU flag that changed flag less than 1 year before being recycled represented a higher tonnage 
than  ships  that  still  flew  an  EU  flag  at  the  time  of  recycling  (based  on  the  weight  of  those 
ships/LDT).  

Despite  the  increased  recognition  by  many  economic  operators  of  their  social  and 
environmental responsibility and  the fact  that the  European List  has  had sufficient  capacity 
over the evaluation period, the possibility to easily change flag has been widely used by EU 
shipowners for end-of-life ships. These ships get dismantled in recycling facilities that are not 
on  the  European  List,  generating  higher  revenues  for  the  shipowners  than  the  revenues 
generated  for  dismantling  in  facilities  that  are  not  on  the  European  List.  These  additional 
revenues are presented by the shipping sector as an important factor in maintaining their global 
competitiveness. The price range for South Asian countries (determined mainly by the price of 
scrap steel, labour costs and compliance costs related to social and environmental standards) 
was consistently above EUR 500 per LDT in 2023, and around EUR 300 per LDT in Türkiye, 
while in the EU they were reported to be around EUR 100 per LDT. This difference amounts 
to over EUR 1.5 million more for an average-sized ship to be recycled in South Asia than for 
it to be recycled in a recycling facility in Europe. Most cases of the re-flagging of end-of-life 
EU-flagged ships can therefore be seen as the result of the lack of an economic incentive to 
recycle in facilities that are not on the European List, due partly to the market failure of not 
internalising the environmental and social costs of recycling in South Asia and the regulatory 
failure  of  providing  adequate  mechanisms  to  prevent  circumvention  of  the  rules.  Given  the 
practice of re-flagging shortly prior dismantling, it is often just not possible to enforce the SRR 
provisions  related  to  a  shipowner’s  obligation  to  have  an  EU-  flagged  ship  dismantled  in  a 
recycling facility that is on the European List. Consideration should therefore be given to how 
to  ensure  that  the  SRR  remains  applicable  to  EU-flagged  ships  until  dismantling.  Both  the 
situation of the de-registering of a ship after a ready-for-recycling certificate has been issued 
and sold to an intermediary for the ship to be recycled in a facility that is on the European List, 
and the situation of re-flagging in order to circumvent EU law, should be addressed.   

The relevance of basing the scope of the SRR on a ship’s flag, as in the case of the Honk Kong 
Convention, plays a pivotal role in the circumvention of the SRR, by making it possible for 
EU  shipowners  to  avoid  discharging  their  responsibility  for  ensuring  the  safe  and 
environmentally sound dismantling of their end-of-life ships. To address the matter, EU ship 
recycling facilities and NGOs in particular are calling for the scope of the SRR to be changed 
so that the responsibility for implementing it lies a ship’s beneficial owner, instead of with the 
registered  owner  linked  to  the  country  whose  flag  the  ship  is  flying.  This  option  has  been 
criticised by various other groups of stakeholders arguing that it is difficult to put into practice 
and that it complicates matters. It follows from this that no clear conclusion can be drawn at 
this stage based solely on stakeholders’ opinions on this sensitive matter, and that the impact 
of such a measure under the SRR required careful analysis.   

56 

 
 
Another way of dealing with the matter of circumvention worth exploring further, is a financial 
instrument such as a ship recycling licence’s applying to all ships calling at an EU port, to 
bridge the revenue gap between dismantling in facilities that are on the European List and 
dismantling  in  facilities  that  do  not  operate  in  a  safe  and  environmentally  sound  way.  The 
possibility of a financial incentive was referred to in Article 29 of the SRR and subject of one 
study in 2016 and of a 2017 Commission report192. Views on this matter are also polarised.  
Again, the evaluation, as a ‘backward-looking’ exercise, is not supposed to go into detail on 
measures to address the problems outlined in it. An ongoing study will constitute a preliminary 
step towards a possible detailed impact assessment study. 

The shipping industry frequently questions the obligation of dismantling EU-flagged ships in 
facilities on the European List given these facilities do not have enough capacity to meet the 
demand for them. The evaluation showed that with its 45 recycling facilities, the SRR and its 
European List so far managed to ensure sufficient capacity for the dismantling of ships in 
its  scope  (including  ships  re-flagged  in  the  year  before  they  are  dismantled).  However,  the 
evaluation has also shown that capacity needs to keep growing to be able to meet the increasing 
demand for recycling EU-flagged vessels  expected, expected to  peak in  2032 to  almost  2.5 
million LDT. Capacity needs would be even greater if the SRR’s scope were extended to the 
beneficial owners of ships or also covered the recycling of non-EU-flagged vessels frequently 
calling at EU ports.  

The European List and level of standards  

Despite re-flagging and the entry into force of the Basel Ban Amendment which resulted, for 
over  2  years,  in  applications  from  facilities  in  non-OECD  countries  to  be  put  on  hold, 
stakeholders  are  largely  of  the  view  that  the  SRR  for  the  most  part  achieved  its  general 
objective of mitigating the adverse impacts of ship recycling on workers’ health and on the 
environment193. This can in the first place be attributed to its stringent criteria for ship recycling 
facilities that apply both to facilities in the EU and in third countries, and to its independent 
assessment and inspections that have so far concerned 56 applications and over 55 inspections 
in 23 ship recycling facilities. Both the additional criteria for being put on the European List 
and  the  SRR’s  its  audit  mechanisms  are  considered  an  EU  added  value,  resulting  also  in  a 
reputational benefit for the companies on the list. Unannounced inspections carried out since 
2023 are considered a key way of ensuring effective monitoring and compliance.  

The evaluation has nevertheless shown there is room for improvement in the implementation 
of the European List. For example, consideration could be given to clarifying the criteria 
for establishing compliance with the SRR and for being put on the European List to ensure a 
more level playing field. In this respect further consideration could be given to assessing the 
need  for  additional  and/or  more  specific  criteria  to  evaluate  waste  management  and  steel 
recovery operations, effective pollution control measures and the use of cleaner dismantling 
and recycling technologies and methods. The request from the Commission expert group on 
ship  recycling,  to  clarify  the  application  of  corrective  and  punitive  actions  in  case  of 
deficiencies identified during inspections, is being followed up on by the Commission.  

192 2016 study (Ecorys, DNV-GL), 2024 study (not available yet), COM(2017)420.  
193 Over 80% of respondents to the public consultation and survey – see page 27. 

57 

 
 
 
The  costs  of  fulfilling  the  SRR  requirements  are  generally  considered  low  to  moderate194. 
Opportunities  to  reduce  unnecessary  administrative  burdens  without  undermining  the 
achievement  of  the  SRR’s  objectives  still  exist.  Ship  recycling  facilities  suggested,  for 
example, extending the period of validity of inclusion in the European List.  Recycling facilities 
in the EU are also looking for a more dynamic way to reflect on the European List the nationally 
granted recycling permits. Given the costs for the EU budget of managing the European List, 
the  impact  of  having  some  costs  linked  to  compliance  assessments  and  inspections  of  third 
country facilities borne by the facilities themselves could be assessed in a possible revision of 
the SRR to increase efficiency, as could the possibility of the EMSA’s doing the inspections. 
How to increase the use of independent verifiers could also be assessed, by ensuring adequate 
safeguards are in place to ensure the reliability of doing so. 

The  evaluation’s  findings  are  mainly  the  result  of  a  qualitative  approach  given  the  lack  of 
comprehensive quantitative data on benefits and costs. Quantitative data on the SRR’s impact 
on the health of workers and the pollution of the coastal and marine environments are limited 
due to the lack of transparency of the ship recycling sector.  There is also often a lack of specific 
data  on  individual  facilities  covering  the  period  before  to  the  beginning  of  the  application 
process, as well as a difficulty isolating the impact of the SRR from the impact of multiple 
external factors. More effective reporting and measuring tools are therefore needed, for a more 
quantified evaluation of the SRR using meaningful indicators.  

Impact of the SRR on the competitiveness of EU economic operators 

While increasing the competitiveness of EU economic operators involved in ship recycling was 
not an explicit objective of the SRR, the expectations at the time of its adoption were that it 
would  benefit  the  EU  ship  recycling  sector,  but  could  have  a  negative  impact  on  the 
competitiveness of the EU shipping industry. 

The evaluation shows that the SRR has had a very modest impact on the competitiveness of 
the EU shipping sector  (all EU-based companies involved in shipping and using both EU-
flagged  and  non-EU-flagged  ships).  It  shows  that  the  costs  of  and  revenues  from 
implementing the SRR (dismantling a vessel and the requirement to establish and maintain 
an  IHM)  are  low  compared  to  the  overall  turnover  of  shipping  companies,  which  are 
mostly  large  companies.  During  the  SRR  implementation  period,  the  shipping  sector’s 
competitiveness  has  been  affected  by  other  factors,  linked  to  the  fluctuations  of  the  world 
economy and the resulting freight rates associated. The expectations that the SRR would affect 
their costs and revenues were based on the assumption that more ships owned by EU companies 
would be recycled in EU-listed facilities operating under higher standards, thereby reducing 
the shipping sector’s revenues from the sales of end-of-life vessels. In practice however, the 
shipping companies did not make the shift they were expected to make towards dismantling 
their ships in facilities on the European List. This is mainly due to the practice of re-flagging 
shortly before dismantling. At the same time, for shipowners who changed their behaviour by 
opting to send their ships to facilities on the European List, the loss of revenue remains minimal 
compared to their overall economic performance.  

During  the  evaluation  period,  the  EU  ship  recycling  sector  operated  according  to 
environmental and safety standards close to those required to be on the European List even 

194  See Annex IV for an overview of benefits and costs. 

58 

 
 
 
before the SRR entered into force. The additional regulatory costs linked to the SRR were 
moderate.  They  consisted  mostly,  for  the  ship  recycling  sector,  bringing  its  practices  and 
procedures into line with the SRR’s requirements, specific to ship recycling activities, while 
the  requirements  that  applied  before  the  SRR  were  mostly  general  in  nature  195.   There  are 
therefore no material concerns about the direct cost of implementing the SRR on the EU ship 
recycling sector’s competitiveness. At the same time, the benefits were also quite limited 
for most of the sector. Contrary to expectations when the SRR was adopted, most of the 
ship recycling facilities in the EU did not report an increase in turnover resulting from 
the  SRR  as  they  did  not  receive  more  ships  for  dismantling  than  before  the  SRR.  The 
proportion  of  EU  recycling  facilities  has  remained  small  over  the  evaluation  period, 
representing 5.3% of the number of ships recycled worldwide in 2023 (and 1% in LDT), while 
the proportion of the ships recycled in South Asia and Türkiye increased. Due to the difference 
in revenues and cost structure, the competitive disadvantage of EU facilities can be observed 
compared to the facilities in Türkiye that are on the European List but also, due to re-flagging, 
compared to facilities worldwide that are not on the European List196. As a result, the number 
of ships in the scope of the SRR and dismantled by facilities in the EU has not increased as 
expected. A few facilities have not asked for their national permit to be renewed, resulting in 
their being taken off the European List. However, the trend of inclusion or renewal of facilities 
remained largely positive over the evaluation period. 

Unlike  facilities  in  South  Asia  and  Türkiye,  most  facilities  in  the  EU  are  not  exclusively 
recycling large ships. The ship recycling facilities in the EU are most often SMEs, but some 
are associated with larger waste management companies. Most of them also dismantle ships 
that are not in the SRR’s scope, especially smaller ships (below 500 GT), and warships. A few 
new facilities have started operating in the last 5  years in Denmark and Norway, which are 
particularly  designed to  dismantle floating oil platforms,  in  anticipation of the expected de-
commissioning of a large number of platforms currently in use in the North Sea. Some facilities 
in  the  EU  are  also  carrying  out  activities  other  than  dismantling,  especially  repairing 
ships. Some  EU  facilities  are  waiting  for  the  ship  recycling  market  to  show  clear  signs  of 
growth, while others have made investments to upgrade their facilities or practices. There are 
also  projects  underway  to  develop  new  types  of  ship  recycling  facilities,  using  automated, 
innovative, low-carbon technologies. However, the uncertain prospects for these facilities of 
generating  a  sufficient  level  of  economic  activity,  sometimes  combined  with  complicated 
national  and  sub-national  requirements,  have  considerably  hindered  their  development.  The 
EU ship  recycling sector has expressed concerns  that  facilities in  the EU did  not  benefit as 
much from the SRR as facilities outside the EU (especially in Türkiye), while the requirements 
and their effective implementation are considered to not be sufficiently aligned with the body 
of EU law on safety and the environment relevant to ship recycling operations and downstream 
waste management. 

The EU steel sector has only been marginally affected by the SRR. The volume of steel 
recycled from ships subject to the SRR and used by the EU steel industry has remained low. 
This is seen by the sector as a lost opportunity, as steel scrap from end-of-life vessels is of high 

195 ie stemming from regulations on waste management, industrial activities or health and safety. 
196  Competition  comes  both  from  facilities  operating  with  the  lowest  possible  costs  and  from  applicants  for 
inclusion on the European List building a relationship with EU shipowners based on compliance with SRR 
requirements without however being on the European List. 

59 

 
 
 
 
quality, with huge potential for being recycled into high quality applications, and a key asset 
for  the  decarbonisation  of  the  steel  industry.  The  sector  expects  demand  for  green  steel  to 
increase in the future, while the EU currently exports around 20% of steel scrap, making the 
need to increase domestic supply all the more pressing.  

Inventory of hazardous materials 

With regard to the SRR’s second objective, the evaluation concludes that the requirement 
to establish and maintain an IHM is seen as a good way of properly managing hazardous 
materials on ships and appreciated by all stakeholders. Despite the efforts to standardise the 
development and maintenance of IHM and provide standard ship inspection procedures and 
training courses, compliance with and enforcement of IHM-related requirements remain 
insufficient. Available data show that 45% of reported inspections carried out in the period 
2021-2023 found instances of non-compliance with the SRR. Non-compliance findings largely 
involved missing or incomplete IHM-related certificates. However, the situation has improved 
over the evaluation period. There is also a clear need for more qualitative and reliable IHMs. 
To  address  this,  the  whole  chain  of  responsibilities  should  be  looked  at  and  strengthened, 
including the qualifications of experts drawing up IHMs, the way the Material Declarations 
and  Supplier’s  Declaration  of  Conformity  are  obtained,  attendance  to  training  courses  and 
guidance  and  investigation  tools  necessary  for  carrying  out  effective  inspections  under  the 
SRR.  

Enforcement 

The evaluation has identified multiple challenges related to the enforcement of the SRR.  It is 
first  a  necessary  to  clarify  some  concepts  in  the  SRR  that  are  crucial  for  enforcement  by 
determining  effectively  when  a  ship  is  destined  to  be  recycled  or  become  a  waste  and  by 
identifying the responsible owner in case of infringement, given the practice of re-flagging and 
the role cash buyers play. 

Stakeholders also emphasised the need to clarify how to address situations where several legal 
frameworks apply and called for more specific guidance and training. They also highlighted 
the importance of improving cooperation and information exchange (between environmental 
and maritime authorities, between Member State’ authorities and with relevant third countries), 
and of developing adequate monitoring and investigation tools. In that context, the potential of 
technology-based approaches could be further explored. The evaluation has also shown that 
there is room for improvement in data reporting for it to become an effective monitoring tool.  
This  is  the  case  for  tri-annual  reporting  under  Article  21,  which  lacked  data,  but  also  for 
THETIS  EU,  used  to  report  on  SRR-related  port  state  controls,  but  only  voluntarily  and 
therefore not giving the full picture. Finally, the evaluation found that less than half of Member 
States  have  adopted  all  the  measures  necessary  to  cover  possible  SRR  infringements.  Most 
Member States have only adopted measures concerning some aspects of the SRR and  some 
have not adopted any specific measures on the basis of the SRR. These Member States rely on 
more  general  rules  designed  for  addressing  non-compliance  with  national  environmental 
regulations on the handling and shipment of waste. When they are in place, the level and type 
of penalties vary significantly. Consideration should be given to how to ensure that penalties 
are sufficiently dissuasive in all Member States to discourage non-compliance. The entry 
into force of the new Directive on Environmental Crime, which includes illegal ship recycling 

60 

 
 
under the SRR among the criminal offences it covers, will certainly help matters, but it does 
not address other types of non-compliance under the SRR. 

The SRR and the Honk Kong Convention 

Regarding the SRR’s third and last operational objective, namely the ratification of the 
Honk  Kong  Convention,  the  evaluation  finds  that  the  Regulation  has  been  effective.  
Beyond the analysis of the figures on ratification, what is clear is that the SRR had been for 
many  years  the  only  international  legal  instrument  setting  out  specific  ship  recycling 
requirements  and that many stakeholders and authorities outside the EU  considered it as  an 
important benchmark. This made sure that the need to regulate ship recycling remained on the 
agenda of stakeholders in the maritime industry, and  prompting some of them to promote a 
global solution through the entry into force of the Honk Kong Convention.   

Many people who responded to the consultation believe that the SRR keeps its added value 
and relevance, even after the entry into force of the Honk Kong Convention. The evaluation 
shows how its more stringent health and environmental requirements and strong monitoring 
and control mechanisms are also relevant in a global context and could be promoted in the 
IMO context. Ship recycling volumes are expected to grow significantly in the coming years, 
due  to  the  ageing  of  the  current  fleet,  so  it  is  more  important  than  ever  that  this  be  done 
sustainably. Shipowners’ associations and some Member States seeking primarily to ensure a 
level playing field consider high global standards to be the best way to address the problem of 
reflagging. 

The  entry  into  force  of  the  Honk  Kong  Convention  also  raises  some  questions  about  the 
relationship between the Honk Kong Convention and the SRR and between the HKC and the 
Basel  Convention,  with  shipowners  and  public  authorities  pointing  out  legal  and 
implementation  uncertainties  that  need  to  be  addressed  in  good  time  in  the  relevant 
international  fora.  In  this  context,  considerations  should  also  be  given  to  how  to  avoid 
unnecessary administrative burden in terms of reporting or certification resulting from the co-
existence of the SRR and the Honk Kong Convention. 

Coherence with other EU policy ambitions 

Not only the global context has significantly changed since the adoption of the SRR, especially 
with the entry into force of the Basel Ban amendment and the perspective of the entry into force 
of the Honk Kong Convention. The EU policy agenda has also changed. By the focusing on 
the  environmentally  sound  management  and  storage  of  hazardous  materials  and  waste,  and 
increasing energy and resource efficiency through the recycling of materials (in particular steel 
scrap), the SRR serves the needs identified in many EU policy goals set during the evaluation 
period, in particular the EU Green Deal, the Circular Economy Action Plan, the Zero Pollution 
Action  Plan,  the  Sustainable  Blue  Economy  Communication,  the  Sustainable  and  Smart 
Mobility  Strategy  and  the  green  transition  under  the  EU  taxonomy.  However,  stakeholders 
generally  believe  that  the  SRR  does  not  sufficiently  address  the  needs  of  certain  policy 
ambitions. In particular, a possible revision could further assess if there is a need to strengthen 
the SRR and if it is advisable and opportune for the SRR play a role in making ship recycling 
a key supplier for the EU green steel supply chain, as part of the EU’s ambitions in terms of  

61 

 
 
 
EU’s competitiveness,  resilience, climate  neutrality  and circularity. Considerations could  be 
given, for example, to setting GHG emissions, recycling targets or a comprehensive materials’ 
passport.    As  a  matter  of  priority,  consideration  should  be  given  to  how  to  increase  the 
effectiveness of the SRR’s current core objective of ensuring EU-flagged ships are dismantled 
in safe and environmentally sound facilities. 

62 

 
 
ANNEX I   PROCEDURAL INFORMATION 

LEAD DG: DG Environment 

DECIDE/AGENDA PLANNING REFERENCE: PLAN/2021/13186 

CWP  REFERENCE: N.a. 

1. 

Derogations granted and justification 

No exceptions were made to the Better Regulation Guidelines during this Evaluation. 

2. 

Organisation and timing 

The Inter-service Steering Group for the evaluation of Regulation (EU) 1257/2013 
on  ship  recycling  was  created  in  2022.  It  is  set  up  with  representatives  from  the 
following Directorate Generals: 

• Secretariat General (SG) 
• Legal Service (SJ) 
• Environment (ENV) 
• Climate Action (CLIMA) 
• Internal Market, Industry, Entrepreneurship and SMEs (GROW) 
• Maritime Affairs and Fisheries (MARE) 
• Mobility and Transports (MOVE) 
• Trade (TRADE) 
• Taxation and Customs Union (TAXUD) 
• Employment, Social Affairs and Inclusion (EMPL) 
• Neighbourhood and Enlargement Negotiations (NEAR) 
• Justice and Consumers (JUST) 
• Budget (BUDG) 
• Economic and Financial Affairs (ECFIN) 
• European Anti-Fraud Office (OLAF) 
• Joint Research Centre (JRC) 
• Eurostat (ESTAT) 
• European Maritime Agency (EMSA) 

The group met 5 times during the Evaluation process, first to steer work related to 
the support studies which were carried out for this evaluation, and then on the draft 
evaluation. Details on consultations on the Group are provided in the following table. 
There were also written consultations.

63 

 
 
 
 
 
 
Date 
7 October 2022 

10 January 2023 

22 May 2023 

26 October 2023 

2 May 2024 

Topic of discussion 

Background and scope of evaluation 
Draft Call for Evidence 
Draft Terms of reference for a service 
contract supporting the evaluation 
Draft  inception  report  presented  by 
the  contractor  for  the  supporting 
study, 
by  written 
consultation 
Draft interim report presented by the 
contractor  for  the  supporting  study, 
followed by written consultation 

followed 

Draft final report 
followed by written consultation 
Discussion on Draft Commission 
evaluation report (Staff working 
document for the evaluation and 
executive summary) followed by written 
consultation 

3. 

Consultation of the Regulatory Scrutiny Board 

Following its examination by the Regulatory Scrutiny Board on 19 June 2024, this 
report was modified with the following main changes: 

Comment by the Board 
(1) The report should clearly state the 
lack  of  quantitative  data  concerning 
the health and environmental benefits. 
It  should  strengthen  its  analysis  by 
providing  additional  evidence,  e.g., 
from  inspection  reports,  individual 
health  monitoring  data  from  workers 
the 
etc., 
qualitative  analysis.  It  should  clarify 
whether  a  monitoring  system  is  in 
place  that  allows  an  analysis  of  how 
the  situation  has  evolved  in  terms  of 
health and environment impacts due to 
the SRR.  

develop 

further 

and 

and 

areas 

p.25). 

Specific 

robustness, 

Modifications made 
The  lack  of  quantitative  data  is  clearly  stated 
and further underlined and developed in section 
1.2.  on  methodology, 
and 
limitations.  It  is  also  further  and  mainly 
developed under Section 4.1.1 on effectiveness 
(p.24 
of 
improvements  retrieved  from  reports  are 
highlighted for Türkiye and India. Qualitative 
analysis  on  the  impact  has  been  further 
developed  and  clarified,  through  a  dedicated 
question  on  the  effectiveness  of  the  SRR 
regarding  the  general  objective  in  reducing 
adverse  effects  on  human  health  and  the 
environment  caused  by  ship  recycling.  Under 
that section, the monitoring systems in place for 
measuring  how  the  situation  has  evolved  in 

64 

 
 
 
should 

facilities 

2) The report should provide both the 
estimates  of  the  total  costs  resulting 
from  the  SRR  and  the  aggregated 
estimates for the different stakeholders 
(shipping 
recycling 
companies, 
facilities,  inside  and  outside  the  EU, 
and  the  European  List).  In  particular, 
the  compliance  costs  for  the  ship 
recycling 
be 
presented  clearly,  both  for  EU  and 
non-EU  facilities,  considering 
the 
different  original  local  requirements 
regarding  health,  environment  and 
occupational safety. Total compliance 
costs should be stated so that they are 
isolated  and  separately  identifiable 
from  labour  costs  and  steel  revenues 
on  particular  markets,  differentiating 
business  as  usual  costs  for  EU  and 
non-EU facilities. 

terms of health and environment impacts due to 
the  SRR  are  presented,  highlighting 
its 
limitations. 

The  evaluation  explains  that  the  assessment  on 
costs  and  benefits  needs  to  take  account  of 
limited data availability, as well as a lack of a 
clear baseline of what would have happened in 
the absence of the SRR. A fully quantified cost 
benefit analysis was not possible, including the 
presentation of comprehensive aggregated data. 
The evaluation therefore draws overall prudent 
analysis  and  conclusion  on  efficiency,  largely 
based on qualitative data. In section 4.1.2. the 
compliance costs have been more distinctively 
presented for EU and non-EU facilities, as well 
as for shipowners. Some useful additional data 
are also presented on SRR compliance costs for 
recycling facilities in India.  Costs analysis for 
EU  facilities  have  slightly  been  developed, 
based on new input received from  EuRIC  but 
this could be done only in a qualitative manner 
as no additional quantitative data were received 
from EU recycling facilities on investment and 
compliance costs. An estimation of aggregated 
costs  paid  over  the  evaluation  period  by  the 
shipowners that sent their end-of-life vessels to 
facilities  on  the  European  List  compared  to 
dismantling costs in facilities in South Asia has 
been added. 

(3)  The  analysis  of  the  impacts  on 
competitiveness on EU ship recycling 
facilities,  the  EU  maritime  shipping 
industry and the EU steel sector should 
be  further  developed.  The  report 
should clearly describe the key drivers 
for re-flagging of ships, including how 
the  steel  scrap  market  affects  the 
market conditions for ship recycling. It 
should 
the 
competitive advantage is, or could be, 

also  discuss  what 

The impact on the competitiveness of the key 
EU  stakeholders  has  been  further  developed 
and  addressed  under  a  dedicated  sub-section 
under section 5. The competitive advantage for 
EU  recycling  facilities  to  be  on  the  European 
List  (not  effective)  is  discussed  both  under 
section 4.1.2 on efficiency (p.43) and section 5 
on competitiveness (p. 59).  These sections also 
refer a contrario to  the competitive advantage 
of recycling facilities in third country that are 
on  the  European  List  but  also  of  applicants 

65 

 
 
for ship recycling facilities to be on the 
European List. The evaluation should 
present an analysis of whether, and to 
what  extent  SRR  compliance  costs 
might  contribute 
to  driving  ship 
recycling  business  away  from  EU-
listed facilities. It should also analyse 
the  unintended  effects  of  the  SRR.  It 
should  discuss  the  coherence  of  the 
SRR  with  broader  EU  industrial  and 
raw material strategies.  

referring to SRR compliance. The competitive 
advantage of Turkish recycling facilities on the 
European List is also referred to in section 4.1.1 
where  the  unintended  effects  are  discussed 
(p.40).  Section  5  also  explains  that  a  few 
facilities have not requested the renewal of their 
national  permit  to  carry  out  ship  recycling 
business and were therefore removed from the 
European  List.  The  trend  of  inclusion  or 
renewal  of  facilities  remains  however  largely 
positive  over  the  evaluation  period.  Section  5 
puts  in  evidence  that  leaving  the  recycling 
business is attributed to the economics of ship 
recycling resulting in competitive disadvantage 
of EU recycling facilities rather than to the SRR 
compliance costs that are considered moderate. 
These  two  aspects  are  developed  respectively 
in more details under section 3 and 4.1.2. of the 
report. 
Under  section  3,  the  sub-section  on  the 
economics  of 
(p.10-14) 
describes  the  key  drivers  for  re-flagging  of 
ships,  including  how  the  steel  scrap  market 
affects the market conditions for ship recycling. 
It is also described under section 4 (on page 34 
the 
when  assessing 
European List. The same section has added the 
incentives 
to  dismantle  vessels  recycling 
facilities on the European List.  
Coherence  of  the  SRR  with  broader  EU 
industrial and raw material strategies has been 
developed under section 4.3 (p.54-56). 

the  effectiveness  of 

recycling 

ship 

(4) Since many EU recycling facilities 
are SMEs, the report should provide a 
more specific SME analysis. It should 
clarify if and how the SRR takes into 
account  SMEs,  e.g.,  if  there  are 
mitigation  measures  or  if  they  are 
more or less  affected by the overlaps 
and  differences  regarding  the  Hong 
Kong  Convention.  It  should  inform 

No specific SME analysis has been developed. 
The  two  associations  representing  interest  of 
EU ship recycling facilities were consulted. It 
was answered that in principle, with regards to 
ship recycling, rules and legislation should be 
the same for all types of companies. The clarity 
of the rules has nevertheless been underlined as 
point which is of particular importance for the 
SMEs,  without mentioning a particular aspect 

66 

 
 
how the EU ship recycling sector has 
developed  in  terms  of  cost  and  SME 
competitiveness  over  the  evaluation 
period  and  clarify  to  what  extent  the 
SRR had an effect on this. 

The 

report 

should  more 
5) 
transparently  state  what  conclusions 
can be reached, or that it is not possible 
to draw sufficiently robust conclusions 
in particular areas. It should also state 
the  limitations  on  any  conclusions 
particularly  those  based  solely  on 
stakeholder opinion data and be clear 
whether 
conclusions  were 
supported  by  other  evidence.  For 
example, given the lack of quantitative 
data for the health and environmental 
benefits,  the  report  should  clarify  to 
what extent conclusions can be drawn 
regarding  effectiveness  (the  extent  to 
which benefits have been attained). 

the 

the 

costs 

(6)  The  conclusion  that  the  benefits 
outweigh 
should  be 
substantiated with further evidence, if 
this  conclusion  is  retained  in  the 
evaluation.  Additionally,  the  report 
should present the conclusions on the 
objectives  in  a  more  differentiated 
manner  along 
three  specific 
the 
objectives  of  the  SRR.  It  should 
provide  more  nuanced  conclusions 
and  lessons  learned  on  re-flagging 
including  the  analysis  of  limitations 
regarding  transparency  of  ownership. 
Given the lack of data on benefits and 
costs,  the  report  should  draw  clear 

of  the  SRR.  The  elements  of  the  SRR  that 
would  benefit  from  clarifications  have  been 
covered  by  the  report  (under  sections  on 
effectiveness  eg  p.  31  and  35),  on  coherence 
(p.47), and underlined in  section 5 on lessons 
learnt.  The  possibilities  for  simplification 
which  is  generally  raised  by  SMEs  have  also 
been  covered  under  the  dedicated  evaluation 
question (section 4.1.2 on efficiency p.46). 

in  various 
The  report  has  been  adjusted 
locations  where  necessary  accordingly, 
in 
particular  section  4.1.1  on  effectiveness  and 
section 5 on lessons learnt. 

The conclusion that the  benefits  outweigh  the 
costs  as  not  be  retained  as  significant 
limitations  concern the quantification of  costs 
and  benefits.  The  conclusion  on  the  three 
specific  objectives  has  been  presented  in  a 
clearer  way,  while  retaining  the  structure  by 
key thematic areas which has the advantage to 
somewhat reduce redundant inputs. 
The conclusion on re-flagging and reference to 
beneficial ownership has been nuanced. 
Limitations  and  operational  conclusion  have 
been added in the lessons learnt regarding the 
‘European List and level of standards’(p.57). 

67 

 
 
conclusions 

a 
operational 
monitoring  and  evaluation  system 
including 
for 
demonstrating causality of impacts.  

needed 

data 

for 

(7)  The  report  should  further  discuss 
the  coherence,  relevance  and  EU-
added value of the SRR in light of the 
entering into force of the Hong Kong 
Convention  (HKC)  and  its  coherence 
with other EU legislation.  

(8) The system of enforcement for the 
SRR, or lack thereof, should be further 
analysed. The report should clarify the 
enforcement  obligations  for  Member 
States  and  how  they  are  applied 
differently  across  different  Member 
States, 
the  difference 
including 
regarding penalties. 

The  relevant  sections  have  been  further 
developed  supported  by  a  new  Annex  on  the 
main differences between the SRR and HKC) 
added to the report.  The coherence with other 
EU  legislation  has  been  covered  by  the 
evaluation  questions  but  no  significant  issue 
has  been  reported,  with  the  exception  of  the 
coherence  with 
the  Waste  Shipment 
Regulation,  which  has  therefore  received  a 
specific attention in the report (sections 4.1.1. 
on enforcement, 4.1.3. on coherence and Annex 
VI) 
Enforcement  is  specifically  addressed  under 
section  4.1.1.  under  p.35-38  in  relation  to  the 
first  specific  objective  and  under  p.38-39  in 
relation  to  the  second  specific  objective. 
Enforcement obligations are outlined in Table 
1 on p.8, under section on p.22.and reminded in 
section  4.1.1.  Some  information  on  penalties 
applied has also been added under that section. 

68 

 
 
 
 
 
 
 
ANNEX II METHODOLOGY  

This evaluation has been supported by two studies undertaken by a consortium composed of 
Ramboll,  Ecorys,  Grimaldi  Alliance  and  ABS  for  that  purpose158,  used  as  a  basis  for  this 
evaluation  report  and  complemented  as  appropriate.  The  first  study  was  to  support  the 
evaluation in general ( ‘the support study’) and the second study was dedicated to the issue of 
enforcement. The first study represented a solid support to the work of the Commission, with 
the limits outlined below, whilst the second was less relevant and also had difficulties to obtain 
the needed data. EMSA has also supported the Commission with statistics and analytic work 
based on the databases THETIS-EU197, MARINFO198 and EQUASIS199 as well on the reports 
from  Member  States  under  Article  21  of  the  SRR  submitted  the  reporting  portal  Dynamic 
Overview of National Authorities (DONA). 

The methodological approach for this evaluation covers: 

•  The definition of the scope 
•  The intervention logic 
•  The identification of the evaluation matrix and the approach to evidence gathering (in 

Annex III) 
•  Desk research 
•  Consultation strategy and consultation activities (synopsis report in Annex IV). 

The  evaluation  followed  the  classical  four  steps:  structuring,  data  gathering,  analysis,  and 
reporting.  

The sources of information used for this evaluation have been: 

-  A review of existing literature. 
-  Member States implementation reports (under Article 21 of the SRR). 
-  Data from the European Maritime Safety Agency. 
-  Stakeholder consultations, to gather additional data and information on the stakeholders’ 
perception  of  the  extent  to  which  the  SRR  has  been  successfully  implemented,  its 
coherence,  relevance  and  added  value.  This  included  an  online  public  consultation, 
targeted  surveys  and  interviews  (with  public  and  private  entities),  a  stakeholder 
workshop  and  an  expert  group  meeting.  A  wide  range  of  stakeholders  contributed, 
including  Member  States’  competent  authorities,  shipowners’  and 
recyclers’ 
associations, NGOs, classification societies, law firms and research institutes. 

In the table below we provide an overview of the methods applied in the evaluation. 

197 https://www.emsa.europa.eu/thetis-eu.html.  
198 MARINFO is EMSA’s own internal database based on data purchased to the same company as Equasis but 

contrary to the latter not enhanced through the provision of data from other data providers. 

199 https://www.emsa.europa.eu/equasis-statistics.html  

69 

 
 
 
 
 
 
 
Overview 

Literature 
review 

Databases 

Call for 
evidence 

Public 
consultation 

Survey 

The following steps have been carried out:  
•  Identification of literature and data sources;  
•  Assessment  of  available  literature  and  data 
sources identifying data gaps and key issues to 
allow  them  to  be  addressed  through  other 
means; and  

•  Recording of the results in a database that was 

updated throughout the study. 

The following data/databases from EMSA were 
used in the evaluation: 
•  the THETIS-EU on the inspections of ships on 

the inventories of hazardous materials; 

•  the MARINFO database on the list of vessels 

sent for recycling; 

•  the EQUASIS database for data on the EU and 

world’s merchant fleet; 

•  reporting portal DONA allowing for Member 
States to report on implementation in line with 
Article 21 of the SRR under a common portal. 

They were used for: 
•  Analysis  of  the  compliance  with  the  IHM 

requirements; 

•  Presenting  the  number/percentage  of  ships 

recycled; 

•  Review of the re-flagging phenomenon. 
•  Assess  the  quality  of  reporting  by  Member 

States and infringement related actions. 
The purpose of the Call for Evidence was to 
gather views from the public and stakeholders on 
the SRR as a starting step in the evaluation 
process. It was open 2-30 June 2022. The 
Commission received 16 responses. The 
responses came from business associations (6), 
companies (2), NGOs (2), Citizens (2), trade 
union (1), public authority (1) and other (2).  
A public consultation was published on the Have 
Your Say website to gather opinions and 
evidence on the key elements  of the SRR (based 
on the evaluation criteria : effectiveness, 
coherence, relevance, and EU added value) for a 
period of 12 weeks between 15 March 2023 and 
7 June 2023. A total of 63 responses were 
received from 18 Member States and 7 non-EU 
countries. Additionally, 12 position papers were 
received. 
The survey-questionnaire was open for about a 
month, with an official launching date on 3 

70 

Input into the evaluation 
and limitation of the 
instrument 
Mostly Effectiveness. 

While the literature review 
contributed to answering the 
evaluation questions, most of 
the available literature was not 
using up-to-date data 

Overall, the data from THETIS-EU and 
MARINFO provided up-to-date and 
extensive information. However, 
THETIS-EU is used on a voluntary basis 
by 16 MS and Norway to report SRR 
related PSC controls.  Therefore, it 
provides an incomplete picture in terms 
of inspections data. 

The first triannual reporting 
exercise by MS (using 
DONA) revealed incomplete 
reporting by Member States. 

All evaluation criteria. 

Limitation: relatively limited 
number of responses received. 

All evaluation criteria. 

Limitation: relatively limited 
number of responses received. 

All evaluation criteria. 

 
 
 
 
 
 
 
 
Limitation: relatively limited 
number of responses received. 

All evaluation criteria. 

The written feedback provided 
by Member States was very 
valuable for the analysis of 
Efficiency. Yet, as always 
with this evaluation criterion, 
the data on the costs (full-time 
equivalents) and their 
distribution per activity 
depends on the (limited) 
availability of the data and the 
perceptions of the people 
reporting. 
All evaluation criteria 

March 2023.The main purpose was to gather 
information and feedback from the relevant 
stakeholders to produce quantitative and 
qualitative analyses. The targeted audience 
included all the interested parties encompassing 
European shipowners, recycling facilities, 
environmental and workers’ right organisations 
and other relevant entities impacted by or 
interested in the SRR. Some questions were for 
all, some others targeted to a specific category of 
respondents. 79 respondents took part in the 
survey, with 69 completed responses.  
A total of 48 organisations were interviewed 
and/or provided written feedback between May 
and September 2023. During the targeted 
interviews, questions were asked to assess how 
well the regulation has achieved its objectives, 
and whether it continues to deliver in terms of 
effectiveness, efficiency, relevance, coherence, 
and EU added value, as well as areas for future 
improvement. 

Interviews 
and written 
feedback 

Workshop 
and expert 
group 
meeting 

A workshop was organised in June 2023 to 
discuss the intermediate findings from the 
support study on the evaluation.  The workshop 
gathered 62 stakeholders and 26 representatives 
of Member States. The consortium presented the 
outcome of their work to the Commission expert 
group on ship recycling during a meeting 
organised in January 2024. The expert group 
meeting served as an occasion for validating the 
key findings of the support study. 

Data limitations and measures to address them 

The main limitations in the analysis are the few quantitative data available on the impact of the 
SRR on the health of workers200 and on the pollution. Data is poor on both of these aspects, 
making  the  identification  of  the  benefits  (ie  improvements  in  environmental  and  safety 
performance)  uncertain.  When  data  are  available,  the  correlation  is  also  hindered  by  the 
influence of external factors and the decrease in ship recycling activities over the evaluation 
period. It is therefore difficult to estimate the likely situation had the SRR not been adopted. In 
third  countries,  it  is  difficult  to  isolate  its  effect  from  the  adoption  of  the  Hong  Kong 

200 The sector suffers from a serious lack of transparency, many likely go unreported, particularly in Bangladesh, 

India and Pakistan. There is also an absence of data on occupational diseases, including cancer (NGO 
Shipbreaking Platform (2024)). 

71 

 
 
 
 
 
Convention,  partnership  initiatives  carried  out  by  individual  shipping  companies  or  third 
countries and the general development towards more social corporate responsibility. 

The calculation of economic impacts is difficult due to the lack of data on the economics of 
ship recycling, resulting from business secrecy, on one hand, and the fluctuating character of 
the market, on the other.  Also, limited data on the costs per stakeholder group and item could 
be collected.  For the assessment of benefits and of the ratio between the costs and the benefits 
a  qualitative  assessment  was  preferred  to  avoid  arbitrary  assumptions  in  monetising  the 
contribution of the SRR. 

Evidence from stakeholder consultations always reflects the interests of the respondents, which 
always represents a potential bias in the evidence base.  In the sector, strong diverging views 
are expressed on a number of topics, like the capacity of the European List and the priority 
given to ensure a level playing field.  This is to be kept in mind, especially in a small sector 
like  ship  recycling.  Inevitably,  the  number  of  respondents  to  the  public  consultation  was 
somewhat  limited  but  considered  sufficient  for  the  size  of  the  sector.  It  remains  however 
difficult to constitute a representative sample, especially for specific stakeholders’ group.  To 
a lesser extent, this is also a limitation for the targeted surveys.    

These limitations have, to  some extent, negatively affected the robustness of the evaluation 
findings. The results are however seen as sufficiently robust through best efforts to mitigate the 
limitations.  Findings  have  been  essentially  based  on  triangulating  the  information  from 
multiple data sources. The consultation methods complemented each other and did not have 
significant divergence across consultation tools, neither within a stakeholder’ group as far as 
the main findings concerned.   

72 

 
 
 
 
 
 
ANNEX III EVALUATION  MATRIX 

In line with the Commission's better regulation policy, this report assesses the SRR along five 
criteria:  effectiveness,  efficiency,  coherence,  EU  added  value,  and  relevance.  These  criteria 
were  operationalised  via  elaborating  questions  specific  to  this  Regulation,  which  were 
systematically answered to assess the different criteria in a way that is specific to the Regulation 
(how these criteria translate in the context of this Directive). This set of (15) questions was also 
provided in the Call for evidence published at the start to inform citizens and stakeholders to 
allow them to provide feedback on the evaluation initiative.  

These  questions  were  broken  down  into  sub-questions,  and,  for  each  of  them,  assessment 
criteria, indicators, approach to take for the analysis and sources of information to use to answer 
the questions were identified. This resulted in the evaluation matrix presented here. 

73 

 
 
 
General questions 
Effectiveness 
1. How successful has the 
SRR been in achieving (or 
progressing towards) its 
objectives? 

Specific questions 

Judgement criteria 

Indicators 

Data sources 

EQ1.1: How successful has 
the SRR been in preventing, 
reducing, minimising and 
eliminating accidents, 
injuries, and other adverse 
effects on human health (e.g. 
occupational disease) and the 
environment caused by ship 
recycling? 

EQ1.2: How successful has 
the SRR been in ensuring the 
proper management of 
hazardous materials on ships? 

EQ1.3: How successful has 
the SRR been in facilitating 
the ratification of the Hong 
Kong Convention? 

EQ1.4: How successful has 
the SRR been in ensuring that 
EU-flagged ships are 
dismantled in safe and 
environmentally sound 
facilities worldwide? 

EQ1.1: Decreased rate and 
severity of accidents, injuries 
and other adverse effects on 
human health (e.g. 
occupational disease) caused 
by ship recycling 

EQ1.1: Decreased rate and 
severity of adverse effects on 
the environment caused by 
ship recycling 

EQ1.1: Increased number/size 
of EU-flagged ships recycled 
in facilities on the European 
list (by EU flags) 

EQ1.1: Decreased 
number/percentage/size of 
ships that have changed their 
EU flag before recycling 

EQ1.1: Increased values 
(number) of the output 
indicators (statements, 
facilities, recycling plans, 
etc.) 

EQ1.1: Perception of high 
quality of the outputs related 
to the regulation (e.g. 
statements, recycling plans) 

EQ1.2: Increased values 
(number) of the output 
indicators on the 

EQ1.1: Trends in the numbers and 
severity of accidents, injuries, 
occupational disease, etc. inside and 
outside the EU after the Regulation has 
been applied 

EQ1.1: Trends in the numbers and 
severity of environmental pollution 
accidents in ship recycling facilities 
inside and outside the EU after the 
Regulation has been applied 

EQ1.1: Trend in the number/size of EU 
and non-EU-flagged ships recycled in 
facilities on the European list 

EQ1.1: Number/percentage/size of 
ships that have changed their EU flag 
before recycling 

EQ1.1: Trends in the output indicators 
(statements, facilities, recycling plans, 
etc.), including: Number of ships for 
which Ready For Recycling 
Certificates (RFRC) are issued; 
Number of EU-flagged ships for which 
a Statement of Completion has been 
completed and sent to the 
Administration 

EQ1.1: Perception of the quality of 
statements, recycling plans, etc. 

EQ1.2: Output indicators on inventory 
of hazardous materials (Number of 
inventories (Part I) of hazardous 
materials; Number of inventories of 

EQ1.1: Desk research on 
health and environmental 
impacts and sustainable 
management of hazardous 
waste, including: 
E3 modelling (2021) EU 

Reference Scenario 2020, 
Energy Transport and 
GHG Emissions – Trends 
to 2050; 

COWI (2009) Support to the 
impact assessment of a 
new legislative proposal 
on ship dismantling; 
Wei-Te Wu (2016) Science 
for Environment Policy, 
Issue 55 on ship 
recycling; 

NGO Shipbreaking Platform 
(quarterly updates); 
IMO (2016) Evaluation of 

Environmental Impacts of 
Ship Recycling in 
Bangladesh; 

Ship Recycling Transparency 
Initiative – 2020 Report 
and SRTI database; 
SSI (2021): Exploring 

shipping’s transition to a 
circular industry; 
European Commission 

(2022), Updated list of 
ship recycling facilities; 
European Commission, desk 
assessment and inspection 
reports of third country 
ship recycling facilities; 

74 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
General questions 

Specific questions 

Judgement criteria 
inventories/certificates of 
hazardous materials 

EQ1.2: Perception of high 
quality (i.e. compliance) of 
the inventories 

Indicators 

hazardous materials and number of 
inventory certificates issued by MS 
administrations or RO (Art.9); Number 
of third country ships with inventories 
of hazardous materials / compliance 
statements)  

EQ1.3: Increased ratifications 
of the HKC 

EQ1.4: Reduced disparities in 
Health & Safety and 
environmental standards 
between recycling facilities in 
the Union and in relevant 
third countries 

EQ1.4: Adequate ship 
recycling capacity in the 
European list 

EQ1.4: Increased number of 
applications of non-EU ship 
recycling facilities 

EQ1.4: Increased number of 
third country ship recycling 
facilities in the European list 
EQ2.1: There are identifiable 
factors that have (had) a 
positive impact on the 
progress towards the 
objectives 

EQ2.2: There are identifiable 
factors that have (had) a 
negative impact on the 

75 

2. What factors have 
affected (positively or 
negatively) progress 
towards the objectives and 
its enforcement? 

EQ2.1: What factors have 
positively affected the 
progress towards each of the 
objectives? 

EQ2.2: What factors have 
negatively affected the 
progress towards each of the 
objectives?  

Data sources 
UNCTAD Statistics on Ship 

Recycling. 

EQ1.1: Data from ship 
recycling facilities on 
accidents during ship 
recycling and on occupational 
diseases 

EQ1.1-1.4: EMSA report 

EQ1.2 Perception of the quality of 
inventories and evidence of non-
compliance (if any) 

EQ1.3: Number of ratifications of the 
HCK 

EQ1.2: Data from EMSA on 
Port State control checks 

EQ1.4: Perception of the stakeholders 
on the disparities in Health & Safety 
and environmental standards between 
recycling facilities in the Union and in 
relevant third countries 

EQ1.4: Ship recycling capacity in the 
European list compared to the needs 

EQ1.4: Number of applications of non-
EU ship recycling facilities 

EQ1.4: Number of third country ship 
recycling facilities in the European list 
EQ2.1-2: Evidence of factors having 
positive/negative impact on progress 
towards objectives 

EQ2.1-2: Stakeholder opinion on 
factors having positive/negative impact 
on progress towards objectives 
External factors may include, for 
example: 

EQ1.3: IMO, Ratification by 
Treaty 

EQ1.1-1.4: Stakeholder 
consultations 
Online public consultation; 
Targeted survey / Bespoke 

survey; 
Interviews; 
Workshop. 

1.4 Studies on capacity…. 

EQ2.1-2: Desk research on 
factors 
Zhou et al. (2021): Factors 
influencing green ship 
recycling: A conceptual 
framework and modelling; 

Solakivi et al. (2021): The 

European Ship Recycling 
Regulation and its market 
implications: Ship-

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
General questions 

Judgement criteria 
progress towards the 
objectives 

Specific questions 
Objectives as per the 
Intervention logic: 
Ensure EU-flagged ships are 
dismantled in safe and 
environmentally sound 
facilities worldwide; 

Ensure the proper 

management of hazardous 
materials on ships; 
Facilitate the ratification of 

the Hong Kong 
Convention. 

Indicators 

Data sources 

Technological advances, incl. 

digitalisation 

MS and third country priorities 
MS and third country enforcement 

capacity 

Russian war in Ukraine 
COVID-19 pandemic 
The entry into force of the Basel Ban 

Amendment 

3. Are there unexpected or 
unintended effects that have 
occurred (for example, have 
there been harmful 
circumvention of the 
obligations of the SRR)? 

EQ3.1: Are there unexpected 
/ unintended effects? 

EQ3.2: What are the causes 
and effects of circumvention 
through re-flagging? 

EQ3.1: There are identifiable 
unexpected / unintended 
effects  

EQ3.1: Evidence of unexpected / 
unintended effects contributing to or 
hindering the progress 

EQ3.2: There is evidence of 
circumvention through re-
flagging  

EQ3.1: Stakeholder opinion on 
unexpected / unintended effects 
contributing to or hindering the 
progress 

recycling capacity and 
market potential; 
B van Werven (2019): 

European Ship Recycling 
Regulation: can we make 
a difference towards safe 
and environmentally 
sound practices? 
N. Mikelis (2019), The 
Recycling of Ships; 
EMSA data on fleets and 
change of flags. 

EQ2.1-2: Stakeholder 
consultations 
Interviews; 
Workshop. 
EQ3.1: Desk research on 
effects 
Lin et al. (2022): Unexpected 
side effects of the EU 
Ship Recycling 
Regulation call for global 
cooperation on greening 
the shipbreaking industry; 

EMSA statistics on ship 

EQ3.2: Number/percentage/size of 

recycling. 

ships that have changed their EU 
flag before recycling 

EQ3.2: Other evidence of 
circumventing the Regulation, e.g., 
criminal investigation cases and cases 
raised to the EC attention and its effects 

EQ3.1: Stakeholder 
consultations 
Online public consultation; 
Interviews; 
Workshop. 

EQ3.2: EMSA information, 
Shipbreaking platform 
data, IMPEL, IMO 

76 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
General questions 

Specific questions 

Judgement criteria 

Indicators 

Data sources 

4. To what extent Member 
States and stakeholders 
have been engaged in the 
process of improving 
implementation and 
enforcement of the SRR? 

Efficiency 
5. Are the costs related to 
the SRR proportionate to 
the benefits (overall and for 
different stakeholder 
groups)? 

EQ4.1: Member States and 
other relevant stakeholders 
consider that MS have been 
engaged in the process 

EQ4.1: Increased values of 
the relevant output indicators 
on administration and 
reporting 

EQ4.2: Stakeholders consider 
that they have been engaged 
in the process 

EQ5.1: Exploratory question 
(no need for a judgement 
criterion) 

EQ5.2: The benefits outweigh 
the costs / stakeholders 
consider benefits to outweigh 
the costs 

EQ4.1: To what extents have 
Member States been engaged 
in the process of improving 
implementation and 
enforcement of the SRR? 

EQ4.2: To what extent have 
stakeholders been engaged in 
the process of improving 
implementation and 
enforcement of the SRR? 

EQ5.1: What are the costs 
related to the SRR for the key 
activities (see below the 
activities, the costs are in the 
Indicators column)?  

EQ5.2: Can they be 
considered proportionate to 
the benefits for the key 
activities (see below)? 
Key activities, as per the 
developed Intervention logic: 
Meeting the requirements for 
ship recycling of EU-
flagged ships; 

Abandonment of 
Seafarers database 
EQ4.1: EMSA report, 
minutes of 
Committee/Experts groups 
meetings 

EQ4.1-2: Stakeholder 
consultations 
Online public consultation; 
Surveys; 

EQ4.1-2: Stakeholder perception of 
their own and others’ engagement in 
the process of improving 
implementation and enforcement of the 
SRR 

EQ4.1: Output indicators on 
administration and reporting 
(Number/comprehensiveness/timeliness 
of the MS reports; Number of 
meetings) – also a link to the indicators 
on enforcement 

EQ5.1: Costs for: 
For shipowners - to keep a list of 

hazardous materials (Art.5), provide 
information/conditions and have 
their ships dismantled in facilities 
on the European List (Art.6), 
shipowners of third countries to 
keep an inventory (Art.12) 

For administrations201 or a recognised 
organisation202 – to verify the list 
(Art.5), to approve the ship 
recycling plan (Art.7), to perform 
surveys (Art.8), issue certificates 
(Art.9) 

Port state control costs (Art.11) 

EQ5.1: Desk research on 
costs 
European Commission (2012) 

Commission Staff 
Working Document on 
the impact assessment 
accompanying the 
legislative proposal for 
the SRR (SWD(2012) 47 
final); 

European Commission 
(mission costs, 
contracting); 

OECD (2019) Ship recycling: 
An overview; OECD 
Science, Technology and 

201   ‘administration’ means a governmental authority designated by a Member State as being responsible for duties related to ships flying its flag or to ships operating under 

its authority. 

202   ‘recognised organisation’ means an organisation recognised in accordance with Regulation (EC) No 391/2009 of the European Parliament and of the Council. 

77 

 
 
 
 
 
 
 
 
 
 
General questions 

6. Are there significant 
differences in terms of costs 
(or benefits) for Member 
States and different 
stakeholder groups, and if 
so, what are the underlying 
causes? 

Specific questions 
Meeting the requirements for 
authorisation of EU ship 
recycling facilities; 
Inventory, maintenance and 
verification of hazardous 
materials; 

Facilitation of ratification of 

the HKC; 

Meeting the requirements for 

third-country ship 
recycling facilities and 
ships flying the flag of a 
third country; 

Communication, reporting, 

and enforcement. 

Beyond the key 
activities/objectives, benefits 
for some stakeholders in 
addition to the main 
objectives pursued (e.g., 
reputational value of the 
European List) 

EQ6.1: Are there significant 
differences in costs across 
MS and/or stakeholder 
groups? 

EQ6.2: In case of differences, 
what is causing them? 

Judgement criteria 

Indicators 

Data sources 

For ship recycling companies203 – to 
develop a ship recycling plan 
(Art.7), to be included in the 
European list (Art.13), in third 
countries (Art.15) 

The European Commission – to 

establish and update the European 
list of ship recycling facilities 
(Art.16), other costs related to the 
SRR (adoption of formats / 
implementing acts / delegated acts / 
actions requested of affected 
parties) 

For Member States to authorise ship 
recycling facilities (Art.14), to 
participate in meetings (Art.20), to 
report (Art.21), enforce (Art.22), to 
cooperate between each other 
(Art.22) 

EQ5.2: Stakeholder assessment on the 
costs/benefits ratio (incl. e.g. 
reputational benefits of being on the 
European List) 
EQ6.1: same as for EQ5.1 

EQ6.2: Stakeholder opinion on the 
causes of differences in costs 

Industry Policy Papers 
April 2019, No 68. 

EQ5.1-5.2 Stakeholder 
consultations 
Online public consultation; 
Targeted survey / Bespoke 

survey; 
Interviews; 
Workshop. 

EQ5.2: Effectiveness 
assessment 

EQ6.1: same as for EQ5.1 

EQ6.2: Stakeholder 
consultations 
Targeted survey / Bespoke 

survey; 
Interviews. 

EQ6.1-6.2: exploratory 
questions (no need for 
judgement criteria) 

203   ‘ship recycling company’ means, the owner of the ship recycling facility or any other organisation or person who has assumed  the responsibility for the operation of the 

ship recycling activity from the owner of the ship recycling facility. 

78 

 
 
 
 
 
 
 
 
 
Specific questions 
- 

General questions 
7. Are there opportunities 
to simplify the legislation or 
reduce unnecessary 
regulatory costs/burden 
without undermining the 
intended objectives of the 
intervention? 

Judgement criteria 
EQ7: Available opportunities 
for simplification and 
costs/burden reduction 
without hampering 
effectiveness 

Indicators 
EQ7: same as for EQ5.1 

EQ7: Stakeholder opinion on the 
opportunities for simplification and 
cost/burden reduction 

Data sources 
EQ7: same as for EQ5.1 and: 
International Chamber of 

Shipping (2022) Industry 
Guidance to Ship 
Suppliers and Shipowners 
on Materials Declarations 
for Inventories of 
Hazardous Materials. 

EQ7: Stakeholder 
consultations 
Online public consultation; 
Interviews; 
Workshop. 

Relevance 
8. To what extent is the 
SRR still relevant and does 
it correspond to the needs 
within the EU, in particular 
as regards the new policy 
ambitions (as set out, for 
example, in the European 
Green Deal, the Circular 
Economy Action Plan, the 
Zero Pollution Action Plan, 
the Sustainable and Smart 
Mobility Strategy and the 
Sustainable Blue 
Economy)?  

EQ 8.1: SRR provisions are 
in line with the EU needs 
stemming from the 
sustainability principles, such 
as the Circular Economy 
Action Plan  

EQ 8.2: SRR provisions are 
in line with the EU needs 
embodied in the EU Green 
Deal  

EQ 8.3: SRR provisions are 
in line with the needs 
embodied in the Zero 
Pollution Action Plan, the 
Sustainable and Smart 
Mobility Strategy and the 
Sustainable Blue Economy 

EQ 8.1: To what extent the 
SRR corresponds to the needs 
relevant to the sustainability 
principles included in the 
Circular Economy Action 
Plan, such as improving 
product durability, 
reusability, upgradability and 
reparability, addressing the 
presence of hazardous 
chemicals in products, and 
increasing their energy and 
resource efficiency? 

EQ 8.2: Does the SRR 
contribute to addressing the 
EU Green Deal needs to 
reduce by more than 55% (by 
2030) the health impacts of 
air pollution?  

EQ 8.3: To what extent the 
SRR contributes to 

79 

EQ 8.1: Assessment of comparability 
between the provisions of the SRR and 
the needs related to the Circular 
Economy Action Plan 

EQ 8.1-3: Desk research 
(review of the mentioned EU 
initiatives) 

EQ 8.1-3: Stakeholder 
consultations 
Online public consultation; 
Targeted survey; 
Interviews; 
Workshop. 

EQ 8.1: Stakeholder opinion on the 
correspondence between the provisions 
of the SRR and the ones of the Circular 
Economy Action Plan 

EQ 8.2: Assessment of comparability 
between the provisions of the SRR and 
the needs identified in the EU Green 
Deal 

EQ 8.2: Stakeholder opinion on the 
correspondence between the provisions 
of the SRR and the ones of the EU 
Green Deal 

EQ 8.3: Assessment of comparability 
between the provisions of the SRR and 

 
 
 
 
 
 
 
 
 
 
 
 
Judgement criteria 

Indicators 

Data sources 

General questions 

Specific questions 
addressing the needs 
identified in the Zero 
Pollution Action Plan, the 
Sustainable and Smart 
Mobility Strategy and the 
Sustainable Blue Economy? 

9. How well adapted is the 
SRR to technical and 
scientific progress and EU 
and global market 
developments? 

10. Is the scope of the SRR 
still appropriate? 

EQ 9.1: What are the 
technical developments and 
market trends that occurred in 
the field of ship dismantling 
since the entry into force of 
the SRR?  

EQ 9.2: Are the SRR 
provisions still fit and in line 
with these developments? 

EQ 9.1: Identifiable technical 
developments and market 
trends occurred after the entry 
into force of the SRR 

EQ 9.2: SRR provisions are 
considered fit for purpose in 
light of technical/market 
developments 

EQ  10.1:  To  what  extent  are 
the  objectives  of  the  SRR 
relevant 
current 
problems  and  needs  of  the 
ship dismantling industry? 

the 

to 

or 

EQ 10.2: Are there any newly 
emerged 
increasingly 
important  needs  which  are 
currently  not 
(adequately) 
covered by the SRR? 

EQ  10.3:  Should  the  SRR 
scope  be  extended,  e.g.  by 
covering all ships without any 
size and class limitation? 

EQ 10.1: SRR objectives 
match the current problems 
and needs of the ship 
dismantling industry 

EQ 10.2: Identifiable 
emerging needs that are not 
adequately covered by the 
SRR 

EQ 10.3: Identification of the 
needs for an extension of the 
scope of the SRR by ships 
size and class 

EQ 10.4: Identification of the 
needs for an extension of the 
scope of the SRR by flag 

80 

the needs identified in the Zero 
Pollution Action Plan 

EQ 8.3: Stakeholder opinion on the 
correspondence between the provisions 
of the SRR and the ones of Zero 
Pollution Action Plan, the Sustainable 
and Smart Mobility Strategy and the 
Sustainable Blue Economy 
EQ 9.1: Market trends in the ship 
dismantling industry after 2013 

EQ 9.1: Technical developments in the 
ship dismantling industry after 2013 

EQ 9.2: Stakeholder opinion on the 
relevance of the SRR provisions in 
light of market trends and technical 
developments in the ship dismantling 
industry after 2013 
EQ 10.1: Stakeholder opinion on the 
correspondence between current 
problems and needs of the ship 
dismantling industry and SRR 
objectives 

EQ 10.2: Stakeholder opinion on the 
emergence of new needs within the 
ship dismantling industry which are not 
adequately covered by the SRR 

EQ 10.3: Stakeholder opinion on the 
need to extend the scope of the SRR to 
cover all types of ships by size and 
class 

EQ 10.4: Stakeholder opinion on the 
need to extend the scope of the SRR 

EQ 9.1: Desk research  

EQ 9.1-2: Stakeholder 
consultations 
Interviews; 
Workshop. 

EQ 10.1-4: Stakeholder 
consultations 
Online public consultation; 
Targeted survey; 
Interviews; 
Workshop. 

EQ10.4: Data from EMSA 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
General questions 

Specific questions 
EQ  10.4:  Should  the  SRR 
scope  be  extended  beyond 
ships  flying  the  flag  of  a 
Member State204? 

Coherence 
11. To what extent is the 
SRR internally consistent 
and coherent? 

12. To what extent is the 
SRR coherent with other 
existing EU environmental 
and maritime legislation 
(such as the Waste 
Shipment Regulation, the 
Waste Framework 
Directive and other EU 

EQ 11.1: To what extent are 
there inconsistencies among 
the requirements and 
provisions of the SRR? 

EQ 11.2: Do these 
inconsistencies create 
overlaps between different 
provisions, resulting in a lack 
of coherence of the SRR? 

EQ 11.3: To what extent are 
there synergies among the 
requirements and provisions 
of the SRR? 
EQ 12.1: Is the SRR coherent 
with the Waste Shipment 
Regulation, in light of the 
entry into force of the Basel 
Ban Amendment (i.e. an 
export ban outside the 
OECD)?  

Judgement criteria 

Indicators 

Data sources 

beyond ships flying the flag of a 
Member State 

EQ 10.4: Number of abandoned vessels 
in EU ports with no flag or non-EU 
flag, or vessels under EU ownership 
which operate under a non-EU flag in 
European waters 

EQ 11.1: Identifiable 
inconsistencies between 
different SRR provisions 

EQ 11.1: Stakeholder opinion on the 
existence of inconsistencies between 
different SRR provisions 

EQ 11.2: Identifiable overlaps 
between different SRR 
provisions resulting in a lack 
of coherency 

EQ 11.2: Stakeholder opinion on the 
degree of coherence of the SRR due to 
overlaps between different SRR 
provisions 

EQ 11.3: Identifiable 
synergies between different 
SRR provisions 

EQ 11.3: Stakeholder opinion on the 
existence of synergies between 
different SRR provisions 

EQ 11.1-4: Stakeholder 
consultations 
Interviews; 
Workshop. 

EQ 12.1: SRR is coherent 
with the Waste Shipment 
Regulation 

EQ 12.2: SRR is coherent 
with the EU Directive on 
environmental crime, Waste 

EQ 12.1: Assessment of coherence 
between the provisions of the SRR and 
the ones of the Waste Shipment 
Regulation 

EQ 12.1: Stakeholder opinion on the 
coherence between the provisions of 

EQ 12.1-3: Desk research of 
the mentioned legislation 

EQ 12.1-3: Stakeholder 
consultations 
Interviews; 
Targeted surveys; 
Workshop. 

204   As specified in the ToR, for example, abandoned vessels in EU ports with no flag or non-EU flag, or vessels under EU ownership which operate under a non-EU flag in 
European waters, both of which cases currently fall outside the scope of application of the SRR, in order to take into account the possibilities for ownership transfers to 
offshore companies. 

81 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
General questions 
waste legislation, the Port 
State Control (PSC) 
Directive and the Flag State 
requirements Directive)? 

Judgement criteria 
Framework Directive and the 
other EU waste legislations 

EQ 12.3: SRR is coherent 
with the Port State Control 
Directive and the Flag State 
requirements Directive 

Specific questions 
EQ 12.2: Is the SRR coherent 
with the EU Directive on 
environmental crime, the 
Waste Framework Directive 
and the other EU waste 
legislations?  

EQ 12.3: Is the SRR coherent 
with the Port State Control 
Directive and the Flag State 
requirements Directive? 

13. To what extent is the 
SRR coherent with other 
relevant international 
policies and instruments 
such as the Basel 
Convention and the IMO 
Hong Kong Convention? 

EQ 13.1: Are there synergies 
or overlaps (potentially 
leading to inefficiencies) 
between the SRR and the 
Basel Convention?  

EQ 13.1: Identifiable 
synergies and overlaps (with 
examples of inefficiencies) 
between the SRR and the 
Basel Convention 

EQ 13.2: Are there synergies 
or overlaps between the SRR 
and the IMO Hong Kong 
Convention? 

EQ 13.2: Identifiable 
synergies between the SRR 
and the IMO Hong Kong 
Convention 

82 

Indicators 

Data sources 

the SRR and the ones of the Waste 
Shipment Regulation 

EQ 12.2: Assessment of coherence 
between the provisions of the SRR and 
the ones of the EU Directive on 
environmental crime, Waste 
Framework Directive and other EU 
waste legislations  

EQ 12.2: Stakeholder opinion on the 
coherence between the provisions of 
the SRR and the ones of the EU 
Directive on environmental crime, 
Waste Framework Directive and other 
EU waste legislations  

EQ 12.3: Assessment of coherence 
between the provisions of the SRR and 
the ones of the Port State Control 
Directive and the Flag State 
requirements Directive 

EQ 12.3: Stakeholder opinion on the 
coherence between the provisions of 
the SRR and the ones of the Port State 
Control Directive and the Flag State 
requirements Directive 
EQ 13.1: Assessment of synergies and 
overlaps between the SRR and the 
Basel Convention 

EQ 13.1: Stakeholder opinion on the 
synergies and overlaps between the 
SRR and the Basel Convention 

EQ 13.1-3: Desk research  

EQ 13.1-3: Stakeholder 
consultations 
Interviews; 
Workshop. 

 
 
 
 
 
 
 
 
 
 
 
 
General questions 

Specific questions 

Judgement criteria 

EQ 13.3: Are there any 
potential synergies or 
overlaps between the SRR 
and other international 
initiatives, policies and 
instruments? 

EQ 13.3: Identifiable 
synergies between the SRR 
and other international 
initiatives, policies and 
instruments 

Indicators 
EQ 13.2: Assessment of synergies and 
overlaps between the SRR and the IMO 
Hong Kong Convention 

Data sources 

EQ 13.2: Stakeholder opinion on the 
synergies and overlaps between the 
SRR and the IMO Hong Kong 
Convention 

EQ 13.3: Assessment of synergies and 
overlaps between the SRR and other 
international initiatives, policies and 
instruments 

EQ 13.3: Stakeholder opinion on the 
synergies and overlaps between the 
SRR and other international initiatives, 
policies, and instruments 

EU added value 
14. To what extent do the 
needs/problems addressed 
by the SRR continue to 
require action at EU level? 
Should they be better 
addressed at global level? 

EQ14: To what extent global 
initiatives (such as the Hong 
Kong International 
Convention for the Safe and 
Environmentally Sound 
Recycling of Ships) are 
effective in addressing the 
needs/problems within the 
scope of the SRR?  

EQ14: Global initiatives like 
the HKC have identifiable 
effects in addressing the 
needs/problems covered by 
the SRR 

EQ14: Stakeholder opinion on the 
extent to which the HKC and other 
global initiatives are ensuring or able to 
ensure adequate environmental and 
safety standards 

EQ14: Desk research 

EQ14: IMO, Ratification by 
Treaty 

EQ14: Number of ratifications of the 
HCK 

15. What has been the EU 
added value of the SRR 
compared to what could 
have been reasonably 
achieved by Member States 
acting alone? 

EQ 15.1: To what extent 
could the SRR’s outputs/ 
results/impacts have been 
achieved without EU 
intervention? 

EQ 15.1: Identifiable 
evidence that the SRR’s 
effects could have been 
achieved without EU 
intervention 

EQ 15.2: Could the objectives 
of the SRR have been 

EQ 15.2: Identifiable 
evidence that Member States 

EQ 15.1: Stakeholder opinion on the 
extent to which the SRR’s 
outputs/results/impacts could have been 
achieved without EU intervention 

EQ 15.2: Stakeholder opinion on the 
possibility for Member States acting 

83 

EQ14: Stakeholder 
consultations 
Online public consultation; 
Targeted survey; 
Interviews; 
Workshop. 
EQ 15.1-3: Stakeholder 
consultations 
Online public consultation; 
Interviews; 
Workshop. 

 
 
 
 
 
 
 
 
 
 
 
 
General questions 

Specific questions 
achieved by each Member 
State acting alone? If yes, are 
there any 
efficiency/effectiveness gains 
by doing so at EU level? 

EQ 15.3: To what extent is 
EU level coordination needed 
in each of the areas covered 
by the SRR? 

Judgement criteria 
acting alone met equivalent 
objectives to the ones of the 
SRR  

EQ 15.2: Identifiable 
evidence that the SRR 
ensures 
efficiency/effectiveness gains 
compared to Member States 
acting individually 

Indicators 

Data sources 

alone to meet the same objectives of 
the SRR 

EQ 15.2: Stakeholder opinion on 
efficiency/effectiveness gains driven by 
the SRR compared to Member States 
acting individually 

EQ 15.3: Stakeholder opinion on the 
need for EU level coordination 

EQ 15.3: EU level 
coordination is needed to 
meet the objectives of the 
SRR 

84 

 
 
 
 
 
 
 
 
 
 
ANNEX IV OVERVIEW OF BENEFITS AND COSTS  

TABLE 1: Overview of costs and benefits identified in the evaluation 

Type 

Name 

Description 

One-off / 
Recurrent / 
Long-term 

Direct 
compliance 
costs 

Inventory of 
Hazardous 
Materials costs 

Costs to develop a IHM  

Recurrent 

Ship recycling 
plan costs 

European List 
management costs 

Direct 
compliance 
costs 

Mixture of 
direct 
compliance 
costs and 
enforcement 
costs 

Costs to keep the IHM 
updated 

Recurrent 

Recurrent 

Recurrent 

Costs associated to the 
development and 
approval of a ship 
recycling plan 
EU resources mobilised 
to manage the European 
List (compliance cost), 
and desk assessment and 
inspections of third 
country applications to 
ensure enforcement 

Stakeholder 

Shipowners 

Recycling facilities 

MS / EU administrations 

Between EUR 4,000-8,000 
per ship, meaning a total of 
between EUR 88.6 and 177.2 
million  for existing (EU and 
non-EU) fleet calling at EU 
ports 205 
Between EUR 500-1500 per 
ship per year meaning a total 
of between EUR 11-33.2 
million per year 207 

/206 

/ 

/ 

/ 

/ 

/ 

From EUR 2,300 in the 
United Kingdom to EUR 
100,000 in Norway. 

Up to EUR 160 000 per annum based on 
7~10% of the total time dedicated by 
national administrations to the SRR 

/ 

0.75 of a FTE and EUR 3 million spent 
between 2016 and 2023 

205 Unit costs based on the survey and interviews. Total estimate based on the number of EU and non-EU vessels (i.e., 22,146) calling on EU ports in 2019 according to AIS 

data. 

206 When vessels do not come with a proper IHM, recycling yards may face the costs  shipowners should normally bear to prepare an IHM or complementary  costs to assess 

the hazardous materials with additional samplings on the ship to properly prepare the ship recycling plan. 

207 Estimates of unit costs are based on the responses to the survey and interviews. Total estimate based on the number of EU and non-EU vessels (i.e., 22,146) calling on EU 

ports in 2019 according to AIS data. 

85 

 
 
 
TABLE 1: Overview of costs and benefits identified in the evaluation 

Type 

Name 

Description 

One-off / 
Recurrent / 
Long-term 

Stakeholder 

Shipowners 

Recycling facilities 

MS / EU administrations 

Direct 
compliance 
costs 

Direct 
compliance 
costs 

Direct 
compliance 
costs 

Direct 
compliance 
costs 

Direct 
compliance 
costs 

Survey costs 

Costs to perform surveys 
of ships 

Recurrent 

+- EUR 2,100, meaning a 
total of around EUR 20 
million 208 

Certificate costs 

Costs associated with the 
issuance of inventory and 
ready for recycling 
certificates 

Recurrent 

+-EUR 5,500, meaning a total 
of around EUR 3.7 million209 

Ship recycling 
facilities approval 
costs 

Costs associated with the 
authorisation of ship 
recycling facilities 

Recurrent 

/ 

/ 

/ 

/ 

Costs 
environmentally 
sound 
recycling 

and 

of 

safe 

Recurrent 

Costs for selling to a 
facility on the European 
List instead of a non-
compliant facility in 
South Asia. 

Investment costs 

Costs of the upgrade to 
meet the required 
standards 

One-off 

+-EUR 200-350/ ton (LDT) 
or EUR, resulting in +- a cost 
of 178 million for dismantling 
vessels in facilities on the 
European List over the period 
2019-2023210 
/ 

Very variable depending on 
the upgrade needed and size 
of the yard. Amounts to 0.5 
million in USA but can 
easily be 10 times  more in 
South Asia211. 

Up to EUR 500,000 per annum based on 
30% of the total time dedicated by 
national administrations to the SRR 
(Typically it is outsourced to recognised 
organisations and charged to the 
shipowners) 
Up to EUR 160,000 per annum based on 
10% of the total time dedicated by 
national administrations to the SRR 
(Typically it is outsourced to recognised 
organisations and charged to shipowners) 
Up to EUR 320,000 per annum based on 
between 5% and 20% of the total time 
dedicated by national administrations to 
the SRR 

/ 

/ 

208 Total estimate based on the number of EU-flagged vessels (i.e., 9,523) calling on EU ports in 2019 according to AIS data. 
209 Total estimate based on the number of individual vessels (i.e., 678) recycled in the EU in 2019 according to EMSA data. 
210 These ‘costs’ are actually additional revenues that other shipowners would have made by beaching the vessels in South Asia.   
211 This does not include costs for upgrade needed for downstream waste management facilities and emergency capabilities, where necessary. 

86 

 
 
 
Type 

Name 

Description 

TABLE 1: Overview of costs and benefits identified in the evaluation 

One-off / 
Recurrent / 
Long-term 

Recurrent 

Recurrent 

Recurrent 

Costs to operate and 
ensure maintenance in 
accordance with the 
standards 
Port State inspections  

Costs to monitor and 
ensure that the SRR 
provisions are applied 

Costs to report to the 
European Commission 

Recurrent 

Economic benefit of 
being included in the 
European List 
Reputational benefit of 
being included in the 
European List 
Improved health and 
working conditions 

Decreased environmental 
damage from ship-
recycling activities 

Recurrent 

Recurrent 

Recurrent 

Recurrent 

Stakeholder 

Shipowners 

Recycling facilities 

MS / EU administrations 

/ 

/ 

/ 

/ 

/ 

Up to +- EUR 100/ton 212 
As well as longer time 
necessary for dismantling 
vessels 
/ 

/ 

/ 

/ 

Up to EUR 80,000 per annum based on 
less than 5% of the time needed for a Port 
State control inspection 
Up to EUR 800,000 per annum based on 
between 3%~50% of the total time 
dedicated by national administrations to 
the SRR 
Up to EUR 80,000 per annum based on 
<5% of the total time dedicated by 
national administrations to the SRR 

(for some yards) Increased 
demand, turnover and 
jobs213 

Not quantifiable 

/ 

Workers: improved health and working conditions (less accidents, enhanced health monitoring, better 
evaluation of the safety risks and protection of the workers).  Indirectly, these benefits affect positively all 
stakeholder groups and the whole society214.  
Less pollution of air, noise, soil, water and sediments resulting from the operations of the recycling 
facilities that applied or are on the European List as well as better environment monitoring215. Indirectly, 
these benefits affect positively all stakeholder groups and the whole society 

Mixed of direct 
and indirect 
compliance 
costs 
Enforcement 
costs 

Enforcement 
costs 

Direct 
compliance 
costs 
Direct benefits 

Operational and 
maintenance costs 

Port State control 

Costs related to 
applying penalties, 
sanctions, monitor 
for infringements 
Reporting costs 

Economic benefits 

Indirect 
benefits 

Reputational 
benefits 

Direct benefits 

Social benefits 

Direct benefits 

Environmental 
benefits 

212  Estimates based on the costs incurred by an applicant to European List in India working in accordance with standards of EU companies. 
213  Fluctuating depending on market conditions. No quantitative data available. 
214 Based on qualitative analysis. Quantification/monetisation not possible. 
215 Based on qualitative analysis. Quantification/monetisation not possible. 

87 

 
 
 
 
 
 
TABLE 2:  Overview of simplification and burden reduction 

Simplification and burden reduction (savings already achieved)  

Ship recycling facilities 

Shipowners 

Administrations 

Quantitative  

Comment 

Quantitative 

Comment  

Quantitative 

Comment 

/ 

Reduction of administrative burden was expected for both Member States and 
shipowners mainly related to the early implementation of the HKC in EU 
legislation, preventing in that way 27 diverging versions of national legislation. 
This happened to some extent but is not quantifiable.  

Potential simplification and burden reduction (savings) 

Ship recycling facilities 

Shipowners 

Administrations 

Quantitative  

Comment 

Quantitative 

Comment  

Quantitative 

Comment 

Considering longer period for inclusion in the 
European List until it has to be renewed, 
considering monitoring mechanisms in place. 

Instead of needing to be renewed 
every 5 years, it could be set to say 
8 years (to be investigated).  

Waiving the certification by an independent 
verifier required in the context of the renewal 
procedure of facilities located in third countries if 
the yard was subject to a recent (to be defined) 
inspection by the Commission. 

The cost of a certification process 
(for a renewal) by an independent 
verifier. This concern only ship 
recycling facilities located in third 
countries.  

Rationalisation and/or data flow between the EU 
portal DONA and ship recycling module of GSIS 
(IMO reporting portal) to implement ‘once only 
principle’ (after entry into force of the HKC and 
implementation of GSIS implementing ship 
recycling module 

Ensuring optimal synergies between HKC and 
SRR (avoiding unnecessary duplications) 

n.A. 

n.a. 

88 

/ 

- 

n.A. 

Instead of needing to be renewed 
every 5 years, it could be set to say 
8 years (to be investigated).  
This would have also a burden 
reduction effect on the 
Commission  

- 

Recurrent (note that it is not a 
simplification compared to the 
evaluation period but a potential of 
rationalisation to avoid duplication 
of reporting after the into force of 
the HKC in 2025 

Recurrent (note that it is not a simplification compared to the evaluation period but 
a potential of rationalisation to avoid duplication of certification, port state control 
and reporting after the into force of the HKC in 2025 (to be investigated) 

 
 
 
 
 
 
 
ANNEX V  STAKEHOLDERS CONSULTATION - SYNOPSIS REPORT  

This Annex provides an overview of the consultation activities carried out in line with the 
consultation strategy for this evaluation, as well as the responses and results received. 

Consultation strategy 

The stakeholder consultation strategy aimed to complement the information collected through 
desk research in policy documents, reports, literature and databases. It included the use of the 
following consultation tools: 

•  A call for evidence: to gather views from the public and stakeholders on the SRR as a 

starting step in the evaluation process.  

•  A Public consultation: to  complement  the evidence collected with  targeted tools to 
support  the  analyses  by  asking  questions  to  a  larger  audience,  granting  them  the 
possibility to contribute to the evaluation and future review process of the Regulation. 
•  Targeted  consultation:  to  collect  specific  evidence  from  a  variety  of  groups  that 
represent the enforcers and addressees of the Regulation, as well as other parties that 
play a role in the ship recycling system. This included notably the running of: 

o  Targeted surveys: to collect (to the extent possible quantitative) information, 

which cannot (easily) be found in written sources. 

o  Targeted interviews: to collect more qualitative insights and complement the 

inputs collected through the public consultation and surveys. 

•  General workshop: to complement primary data collection (from research and other 
consultation activities) as well as to validate the initial resulting analysis performed. 

•  Dedicated workshop: to complement the data on ship recycling capacity. 
•  Expert group meeting: to validate findings. 

The table below presents an overview of the stakeholder groups targeted through the different 
consultation activities. 

Overview of stakeholder groups consulted per consultation activity 

Stakeholder group 

1. Member State and 
third state authorities 
(in their capacity as 
Flag State, Port State, 
environmental 
administrations 
competent for recycling 
facilities) 

2. Shipowners 

3. Cash buyers 

4. Recycling facilities 

Call for 
evidence 
/Public 
consultation 

Targeted 
consultation 

Survey  Interviews 

Workshops 

Expert 
group 
meeting 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√  

√   

√ 

√ 

√ 

√ 

√ 

89 

 
 
 
 
 
 
 
 
 
 
 
 
 
  
√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

 √ 

√ 

√  

√  

√  

 √  

5. Steel industry 

6. Classification 
societies 

7. Banks financing the 
shipping sector 

8. Maritime Law offices 

9. EU and international 
associations / 
organisations 

10. Academia, research 
institutions and civil 
society 

11. Citizens 

1.  Call for evidence 

√ 

√ 

√ 

√ 

√ 

√ 

√ 

A call for evidence216 for the evaluation of the Ship Recycling Regulation was launched on the 
Have  Your  Say  website  between  2  and  30  June  2022  to  gather  views  from  the  public  and 
stakeholders on the SRR as a starting step in the evaluation process. A total of 16 responses 
were  submitted  from  stakeholders  representing  different  groups  such  as  businesses  (4 
respondents)  and  business  associations  (4  respondents),  NGOs  (2 respondents),  citizens  (2 
respondents) as well as one public authority and trade union. Inputs provided by respondents 
across  evaluation  criteria  were  analysed  and  integrated  into  each  evaluation  criteria  of  the 
study.  These  inputs  were  triangulated  with  inputs  provided  through  the  public  and  targeted 
consultations and contributed to the evidence base of the evaluation analysis.  

2.  Public consultation 

An open public consultation was published on the ‘Have your say’ portal217  and made available 
in  all  EU  languages  to  gather  opinions  and  evidence  on  the  key  elements  (effectiveness, 
coherence, relevance and EU-added value) of the SRR for 12 weeks between 15 March 2023 
and  7  June  2023.  The  questionnaire  was  targeted  at  a  broad  range  of  stakeholder  groups, 
including the general public, public authorities and bodies responsible for the enforcement of 
the  Regulation,  shipowners  and  recycling  facilities,  industry  and  sectorial  associations, 
environmental organisations and NGOs, universities and research institutes. 

Respondents’ profile 
A total of 63 responses were received from 18 Member States and 7 non-EU countries.  No 
duplicates nor campaigns were identified among the answers provided by respondents. Most 
contributions to this public consultation came from respondents identifying as businesses and 
business associations (44%, 28 out of 63 respondents), followed by public authorities (27%, 17 
out  of  63  respondents),  EU  and  non-EU  citizens  (13%,  8  out  of  63  respondents)  and  non-
governmental organisations (11%, 7 out of 63 respondents). A large majority of respondents 
(83%, 52 out of 63 replies) replying to the public consultation indicated being very familiar or 
familiar with the Ship Recycling Regulation. 

Inputs received 

216 EU Ship Recycling Regulation – evaluation (europa.eu) 
217 Have Your Say website 

90 

 
  
  
 
 
  
  
 
  
  
  
  
  
  
 
 
 
 
 
Effectiveness 

Most  respondents  consider  that  the  EU  Ship  Recycling  Regulation  has  been  successful  in 
achieving its objectives compared to a situation without any EU legislation. Overall, 86% (54 
out of 63 replies) of respondents consider that the Regulation was to a large or some extent 
successful in preventing and reducing adverse effects on human health and the environment 
and  in  ensuring  the  proper  management  of  hazardous  materials  on  ships.  This  opinion  was 
globally consistent across all stakeholder groups. However, it is noteworthy that 67% of NGO 
respondents hold a different point of view, stating that the Regulation had no effect. 

Over  two-thirds  of  respondents  (67%,  42  out  of  63  replies)  also  consider  the  Regulation 
successful in ensuring that EU-flagged ships are dismantled in safe and environmentally sound 
ship  recycling  facilities.  Within  the  group  affirming  the  effectiveness  of  the  regulation, 
stakeholders identified as NGOs, EU citizens and others are the most favourable in their views, 
demonstrating  support  for  the  regulation's  ability  to  ensure  safe  and  environmentally  sound 
ship dismantling practices.  

Less than half of respondents (46%, 29 out of 63 replies) consider that the Regulation reduced 
disparities in health, safety and environmental standards between recycling facilities in the EU 
and in third countries, while 35% (22 out of 63 replies) indicate that the Regulation had no 
effect in this regard. When analysing the responses of the different stakeholder groups, it was 
found that companies, business associations and public authorities are more likely to support 
the effectiveness of the Regulation in this respect. In contrast, stakeholders among NGOs and 
academic and research institutions state that the regulation had no effect or negative effect. 

A majority of respondents (78%, 49 out of 63 replies) think that the Regulation’s requirement 
to  develop  and  maintain  an  inventory  of  Hazardous  Materials  (IHM)  was  very  effective  or 
effective, while 49% consider the control  and  enforcement  of  IHM as such. The opinion is 
shared across the different stakeholder groups. 

Almost  two-thirds  of  respondents  (65%,  41  out  of  63  replies)  think  that  the  safety  and 
environmental standards requirements for ship recycling facilities to be listed on the European 
List were very effective or effective. However, it is important to note that the assessment of 
effectiveness  was  less  favourable  among  certain  stakeholder  groups.  Specifically,  business 
associations  and  companies/businesses  were  less  likely  to  consider  these  standards 
requirements effective.  

Respondents’ views on the effectiveness of the requirements to monitor ship recycling facilities 
differ, with only 37% of respondents considering the monitoring of EU ship recycling facilities 
as very effective or effective and 38% for the monitoring of third countries’ facilities. These 
views are consistent among the various stakeholder groups. 

When  asked  about  the  European  List  of  ship  recycling  facilities,  almost  two-thirds  of 
respondents (63%, 40 out of 63 replies) strongly or somewhat agree that the List has been an 
effective tool in preventing and reducing adverse effects on human health and the environment. 
Additionally, a majority of respondents  (73%, 46 out  of 63 replies) think that the list  has a 
brand value and increases the reputation of the facilities included on the list. These opinions 
are consistent across all stakeholder types. 

91 

 
 
 
 
 
 
 
 
 
 
Nevertheless, around half of respondents do not consider that the European List has sufficient 
recycling capacity to cover current and future needs. 43% of respondents (27 out of 63 replies) 
strongly or somewhat disagree that the list has sufficient capacity to cover current needs and 
57% (36 out of 63 replies) disagree that it has sufficient capacity for forecasted needs. These 
opinions  are  particularly  shared  among  businesses  and  business  associations,  notably 
shipowners (9 out of 9 replies). 

Coherence 
With regards to the coherence of the Ship Recycling Regulation, less than half of respondents 
consider the Regulation as very coherent or coherent with other EU priorities. About 44% of 
respondents  think  that  the  Regulation  is  very  coherent  or  coherent  with  the  EU’s  transition 
towards a circular economy (27 out of 63 replies) and its ambition to achieve zero pollution for 
air water and soil (28 out of 63 replies).  

However, 46% of respondents (29 out of 63 replies) think the Ship Recycling Regulation is not 
coherent or not coherent at all with the EU’s sustainable and smart mobility strategy and 37% 
of  respondents  (23  out  of  63  replies)  do  not  consider  it  coherent  with  the  EU’s  strategic 
autonomy policy. When perceptions are analysed according to stakeholder groups, two distinct 
categories emerge. Academic and research institutions tend to consider regulation to be more 
coherent  in  all  these  areas.  In  contrast,  NGOs,  business  associations,  businesses  and  public 
authorities show more mixed views. The different  opinions between the two groups remain 
when considering the priorities individually. 

Relevance and EU-added value 
A majority of respondents consider the Ship Recycling Regulation as relevant and recognise 
its EU-added value. 87% of respondents (59 out of 63 replies) consider the Regulation to be a 
relevant piece of legislation and to bring better results than if Member States were acting alone. 
The opinion is shared across the different stakeholder groups. 

However,  46%  of  respondents  (29  out  of  63  replies)  do  not  consider  the  scope  of  the  Ship 
Recycling Regulation to be appropriate. In this regard, the suggestion was particularly made 
for enlarging the scope of the Regulation to go beyond the flag of the vessel and studying the 
possibility of covering vessels below 500 GT. When examining responses across stakeholder 
groups, it was observed that all groups demonstrated a similar pattern of response except for 
the NGO respondents. In this group, the view was unanimous: none of the NGO respondents 
considered the scope of the regulation to be appropriate. 

On the articulation of the European List with an entry into force of the Hong Kong Convention, 
over  two-thirds  of  respondents  (68%,  43  out  of  63  replies)  consider  that  the  European  List 
should  not  automatically  include  ship  recycling  facilities  having  received  a  Hong  Kong 
Convention certification, considering the stricter requirements of the EU regulation. About a 
fifth of respondents (22%, 14 out of 63 replies) consider that the European List should include 
all ship recycling facilities, while 3% think that the European List should be removed if the 
Hong Kong Convention enters into force. These views remain consistent across all types of 
stakeholders. 

3.  Targeted surveys 

The  survey  questionnaire  was  open  for  about  a  month,  with  an  official  launching  date  of  3 
March  2023.  The  survey  has  been  formally  closed  on  31  March  2023.  Together  with  the 
European Commission, a long list of respondents (i.e. 514 individual contacts) was selected 

92 

 
 
 
 
 
 
 
and invited to participate in the survey questionnaire. The questionnaire aimed to collect inputs 
on the key elements of the SRR (effectiveness, efficiency, relevance, coherence and EU added 
value) as well as inputs feeding the study on a potential financial incentive. 

Respondents’ profile 
The distribution of the questionnaire led to a total of 148 registered results. Out of those 148 
responses, many have been found incomplete (i.e. only introductory questions answered) or 
duplicates (i.e. multiple entries under the same name and/or organisation). After the cleaning 
process had been completed, the team ended up with a sample of 79 respondents, of which 69 
reached the end. Respondents answering the survey represented national competent authorities 
(20 respondents), recycling facilities (17), EU and international associations (8), shipowners 
(7),  classification  societies  (6)  and  other  stakeholder  groups  such  as  maritime  law  offices, 
academia, cash buyers, the steel industry. 

In parallel, another targeted survey was conducted between 03 March and 12 April 2023 to 
collect  inputs  on  enforcement  procedures  and  sanctions  in  place  in  Member  States  for 
infringements and circumvention of the SRR. After the cleaning process was completed, 17 
responses from respondents originating from 9 MS (FR, PL, MT, LT, LI, SK, LU, BE, NL) 
were  analysed.  Responding  stakeholders  involved  competent  authorities  responsible  for 
recycling facilities; administrations responsible for duties related to ships flying their flag or to 
ships operating under their authority; Port State Control Inspectors; Environmental Inspectors/ 
Police  Environmental  agencies;  Prosecutors  officers,  and  NGOs.  Inputs  provided  for  this 
survey were directly included in the study on enforcement procedures and sanctions in place 
related to the SRR. 

Inputs received 

Effectiveness 
A large majority of stakeholders surveyed consider that the SRR contributed to a large or some 
extent to prevent and reduce the adverse effects of ship recycling on the environment (62 out 
of 67 responses) and on human health (57 out of 69 responses). These responses are shared 
across all stakeholder groups.  

Additionally, most respondents surveyed (52 out of 60 responses) also indicate that the SRR 
contributed to  a large or some extent to  reducing  disparities in  environmental  and health & 
safety standards between recycling facilities in the Union and in third countries. This opinion 
is  shared  across  stakeholder  groups  except  for  academic  and  research  institutes  and 
international organisations. Among respondents indicating the SRR had no or a negative effect 
in reducing disparities, two stakeholders (one shipowner and one recycling yard) pointed out 
the difference in standards between European (higher standards) and Asian recycling facilities 
(lower standards). 

Respondents  to  the  survey  disagree  on  the  question  if  the  ship  recycling  capacity  currently 
included in the list can cover the current needs or not. Most participants in the survey disagree 
that the capacity is sufficient (17 out of 29 responses to the question). Looking at the group of 
recycling facilities (n=14), 7 consider the capacity insufficient, while 4 consider it sufficient 
(with 3 neutral answers). 

As concerns the forecasted needs, out of 28 respondents, 16 strongly disagree that the European 
list of ship recycling facilities has sufficient capacity to cover future needs. Responses provided 

93 

 
 
 
 
 
 
 
 
among  recycling  facilities  particularly  differ,  showing  different  points  of  view  among  the 
stakeholder group - 6 out of 14 strongly disagree that the capacity is sufficient, while 3 strongly 
agree. 

Efficiency 
Overall, around half of the stakeholders surveyed (18 out of 39 responses) consider the SRR 
efficient, with benefits outweighing (by far) the costs associated with the requirements. This 
opinion is  particularly  shared  among  recycling  facilities  (9 out  of 15  responses), competent 
authorities such as Member States in their capacity of Port State (3 out of 5 responses) and 
classification societies (3 out of 4 responses. A fourth of stakeholders (10 out of 39 responses), 
particularly Member States in their capacity as Flag States (5 out of 9 responses) consider the 
costs of the SRR proportionate to the benefits. 

Another  fourth  of  respondents  (11  out  of  39  responses)  however  indicate  that  the  SRR  is 
inefficient or very inefficient. This opinion is notably shared among a majority of academic, 
research and civil society organisations (2 out of 3 responses), half of the shipowners surveyed 
(2 out of 4 responses) and a minority of recycling facilities (4 out of 15 responses). 

On costs associated with the SRR, a majority of shipowners (associations) surveyed (4 out of 
5 responses) indicate low costs for shipowners flying the flag of a Member State associated 
with the SRR requirement to provide and notify ship recycling facilities operators and Member 
States  with  all  the  necessary  information  to  recycle.  Similarly,  costs  associated  with 
establishing and maintaining a list of hazardous materials are considered moderate to low for 
ships  flying  an  EU  flag  as  well  as  for  ships  flying  the  flag  of  a  third  country  (4  out  of  5 
responses). 

Administration and competent authorities consulted through the survey indicate low costs for 
some of the SRR requirements. This is notably the case for costs associated with cooperation 
with other Member States authorities to prevent and address potential circumventions (6 out of 
9 responses) and for the reporting to the EC on the state of ship recycling (5 out of 8 responses). 
Most of the administration and competent authorities indicate moderate costs associated with 
granting  ship  recycling  facilities  authorisations  and  performing  the  monitoring  of  those 
authorised (5 out of 9 responses), issuing inventory and ready-for-recycling certificates (6 out 
of 11), approving ship recycling plans (4 out of 7 replies) and performing surveys to ensure 
compliance with the list of hazardous materials and ship recycling plans (5 out of 9). 

Administration and competent authorities indicate low to moderate costs associated with the 
control  and  inspection  of  inventory,  ready-for-recycling  certificates  and  statements  of 
compliance (3 out of 6 responses each). 

Quantifications  of  the  costs  associated  with  the  development  of  a  ship  recycling  plan  are 
provided by a few recycling facilities but are very different and range from GBP 2,000 in the 
UK to EUR 100,000 in Norway While half of the recycling facilities – both listed and non-
listed - in the EU consider costs to develop a ship recycling plans as low (4 out of 8 responses), 
a majority of them indicate high costs associated with compliance with EU requirements to be 
included  in  the  European  list  (5  out  of  8  responses.  The  scope  of  these  costs  is  currently 
unknown, with one yard claiming they could reach EUR 500,000. 

94 

 
 
 
 
 
 
 
 
 
High costs are also identified by ship recycling companies (8 out of 12 responses) to apply to 
the European list and meet the requirements. These views are shared by both non-listed and 
listed yards. 

Regarding benefits  brought  by the SRR, half of  the recycling  facilities, shipowners and the 
steel industry surveyed (7 out of 13 responses) indicate that the SRR was a determining factor 
in  the  evolution  of  their  revenues.  One  recycling  yard  mentioned  the  role  of  the  SRR  in 
stimulating  investors’  funding  to  establish  recycling  facilities.  Another  recycling  yard 
mentioned  that  the  SRR  incentivised  the  facility  to  use  better  quality  personal  protective 
equipment which reduced workers' injuries and therefore resulted in lower costs.  

Coherence 
A majority of stakeholders surveyed do not see inconsistencies between the SRR and the Flag 
State requirements (11 out of 14 responses), the Port State Control (9 out of 13 responses) or 
the  Waste  Framework  Directives  (7  out  of  10  responses).  However,  a  majority  indicates 
elements of inconsistencies between the SRR and the Waste Shipment Regulation (11 out of 
17 responses), the Basel Convention (11 out of 16 responses) and the Hong Kong Convention 
(13 out of 19 responses).  

Some  stakeholders  clarified  their  answers  stating  that  inconsistencies  with  the  HKC  (2 
responses)  lie  in  the  difference  of  hazardous  materials  covered  and  in  the  management  of 
downstream  waste.  With  regards  to  the  WSR  and  the  Basel  Convention,  one  respondent 
highlighted a potential contradiction in that the WSR implements the Basel Ban Amendment 
into EU law where it prevents waste from OECD countries from being recycled in non-OECD 
countries, which would subsequently exclude non-OECD countries from the European List of 
ship recycling facilities under the SRR. 

EU added value 
Stakeholders’ responses to the targeted survey indicate a positive EU-added value of the SRR 
compared  to  what  Member  States  could  have  achieved  alone  for  all  three  points.  A  large 
majority  of  stakeholders  surveyed  (46  out  of  57  respondents)  think  that  the  SRR  brings  an 
added value compared to what Member States could reasonably achieve alone in the absence 
of  the  entry  into  force  of  the  HKC.  A  fifth  of  the  stakeholders  surveyed  (11  out  of  57 
respondents, which mainly represent recycling facilties, shipowners and two Member States) 
disagree with this statement. 

A few stakeholders (2 out of 57 responses) see the SRR as a solution to avoid the multiplication 
of national legislations and act faster than what Member States alone could achieve. However, 
more than half of the  survey respondents  (31 out  of 45 responses) also  see opportunities to 
simplify the legislation or reduce unnecessary regulatory burdens.  

A wide range of stakeholders consulted (16 out of 68 respondents representing ship recycling 
facilities, classification societies, consultancies and academics) also values the role of the SRR 
in setting minimum standards for ship recycling. One stakeholder recognises the role of the 
SRR to ensure the required level playing field for the maritime industry and recycling yards 
operating in the EU. However, three stakeholders also mention the need to not limit the level 
playing field at the EU level only and take instead a global approach as initially foreseen with 
the HKC.  

95 

 
 
 
 
 
 
 
 
Relevance 
A majority of stakeholders surveyed (27 out of 45 responses) consider the need to extend the 
scope  of  the  SRR  beyond  ships  flying  the  flag  of  a  Member  State.  However,  views  differ 
according  to  the  stakeholder  group.  While  a  majority  of  recycling  facilities  (10  out  of  11 
responses) and environmental authorities (4 out of 4 responses) are in favour of extending the 
scope  of  the  SRR,  a majority  of  shipowners  (5  out  of  6  responses),  Flag  States  (5  out  of  7 
responses) and Port States (5 out of 6 responses) are against. 

Arguments in favour of a scope extension brought by stakeholders suggest including all types 
of  ships  (fishing  vessels,  yachts,  inland  navigation),  including  ships  of  less  than  500  gross 
tonnage. Suggestions to extend the scope to the ownership of the ship instead of the flag the 
ship is flying were also made by one public authority. On the other hand, arguments against it 
point out the existing limited capacity of the European List to absorb existing ship recycling 
needs as well as the misalignment with the scope of the HKC it would create. 

Concerning the relevance of a financial instrument, the majority of stakeholders surveyed either 
strongly  agreed  or  agreed  that  a  financial  incentive  (completely  or  partially)  bridging  the 
revenue gap may be helpful to encourage safe and environmentally sound recycling. Overall, 
the majority of respondents surveyed across stakeholder groups, except for shipowners and EU 
and international believe that introducing a financial incentive would have a positive impact. 
However,  stakeholders’  views  on  the  impacts  of  introducing  a  Ship  Recycling  Licence  for 
smaller vessels differ. The stakeholders in favour indicate that this would be consistent with 
the broadening of the scope of the EU SRR. They indicate that the same rules should apply to 
all  vessel  types,  including  pleasure  yachts  and  shipowners  that  often  adjust  tonnage  to 
circumvent regulation.  

The stakeholders that disagree with the extension are often also not in favour of the financial 
instrument. The other arguments against the extension of under 500 GT vessels are that (i) it 
would cause market distortion, given that the scope of SRR Regulation would be wider than 
the one of the HKC, (ii) it would unreasonably add a disproportionate burden to small shipping 
companies and thus would not be in line with the principle of proportionality. 

4.  Targeted interviews 

During  the  targeted  interviews,  questions  were  asked  to  assess  how  well  the  regulation  has 
achieved its objectives, and whether it continues to deliver in terms of effectiveness, efficiency, 
relevance,  coherence  and  EU-added  value,  as  well  as  areas  for  future  improvement.  Some 
interviews also touched upon the likely evolution of the current situation in the absence of a 
potential financial incentive and the impacts stemming from its implementation. As a follow-
up to the interviews, written feedback was provided by a few Member States on issues related 
to SRR administrative costs and burdens. This input was used for the analysis of Efficiency.  

Respondents’ profile 
A total of 48 organisations were interviewed and/or provided written feedback between May 
and  September  2023.  These  included  stakeholder  groups  such  as  EU  and  international 
associations, Member States’ competent authorities, shipowners, recycling yards, businesses, 
classification societies and representatives from the steel industry. 

Inputs received 

96 

 
 
 
 
 
 
 
 
Effectiveness 
Stakeholders interviewed have different views on the effective role the SRR has in ensuring 
that EU-flagged ships are safely dismantled. Two environmental administrations recognised 
that the SRR allowed to establish good standards for the dismantling of ships and a couple of 
stakeholders  (one  classification  society,  one  shipowner  association  and  one  shipowner) 
consider that the SRR has contributed to setting higher standards than the HKC would have. 
One shipowner association, one consultancy and one recycling yard however point out the lack 
of effectiveness of the SRR due to the existing circumventions of the regulation where ships 
are being re-flagged before being sent for recycling, while two shipowners refer to the lack of 
available  capacity  (with  difficulties  to  host  larger  vessels  and  with  recycling  yards  already 
occupied  with  other  activities  such  as  the  recycling  of  offshore  oil  and  gas  facilities)  as 
hampering factors. One public authority also indicated low levels of ship recycling requests as 
an indicator of the limited effectiveness of the SRR. 

Views  on  the  evolution  of  health  and  safety  and  environmental  standards  in  EU  ship 
recycling  facilities  are  positive  across  most  stakeholders  interviewed.  One  classification 
society and one consultancy interviewed note the positive impacts of the regulation to establish 
recycling standards. They notably referred to the inclusion of requirements for safety incident 
reporting and follow-up (corrective measures), the provision of personal protective equipment 
to  workers,  the  use  of  fit-for-purpose  machinery  to  move  the  ships  into  the  dismantling 
surfaces,  emergency  response  (availability  of  firefighting  equipment,  medical  services)  and 
environmental  monitoring  procedures  in  listed  yards.  Additionally,  one  recycling  yard,  one 
classification  society  and  one  organisation  from  the  steel  industry  considered  that  the  SRR 
contributed to creating a business case and establishing a market – even if currently limited – 
for ship recycling in Europe.  

Stakeholders’  views  are  split  on  the  effectiveness  of  the  SRR  to  ensure  the  proper 
management of hazardous materials. On the one hand, two environmental administrations 
stress the poor management of hazardous waste afterwards and notably the persistence of health 
and environmental risks linked to the presence of asbestos and PFOS in extinguishing systems 
on tankers which remain insufficiently addressed. On the other hand, one consultancy considers 
that the SRR had a positive impact, requiring shipowners to establish an inventory of hazardous 
materials.  

On  the  role  of  the  SRR  in  facilitating  the  Hong  Kong  Convention,  one  public  authority 
interviewed considered that the regulation did not contribute to facilitating the ratification of 
the convention.  

When  asked  about  potential  changes  to  improve  the  regulation’s  enforcement,  most 
stakeholders  (one  shipowner  association,  one  consultancy,  one  organisation  from  the  steel 
industry and one NGO) agree with the idea of introducing the concept of beneficial ownership 
liability.  One  shipowner  association  also  suggests  additional  solutions:  these  include  for 
example the extension of the SRR’s scope to include all ships that have, at some point within 
their  lifetime,  flown  an  EU  flag.  Another  suggestion  put  forward  is  to  require  a  temporary 
restriction to obtain a recycling licence (e.g., for a couple of years) for EU vessels having re-
flagged to a non-EU flag, to discourage re-flagging practices just before sending the vessel to 
waste/recycling.  

While  public  authorities  do  not  necessarily  object  to  the  idea  of  introducing  the  concept  of 
beneficial ownership liability, two of them mention that it could complicate enforcement due 

97 

 
 
 
 
 
 
to  legal  difficulties.  They  notably  refer  to  the  complexity  of  identifying  ownership  and  the 
necessity of agreeing on a clear definition of ‘beneficial owner’ and suggest that introducing a 
hierarchy of responsibilities is essential. One consultancy also has more nuanced views on the 
introduction of the concept which is not perceived as a comprehensive solution for improving 
enforcement but did not specify further its reasoning.  

On  whether  current  sanctions  are  sufficient  to  ensure  an  effective  enforcement  of  the 
regulation,  
a  couple  of  stakeholders  (one  consultancy,  one  recycling  yard)  consider  that  the  current 
administrative sanctions in case of infringement are too low to be effective while one public 
authority considers them adequate.  

Efficiency 
Interviews  with  stakeholders  show  differences  in  costs  for  public  authorities  in  charge  of 
implementing the SRR. One public authority mentioned that the enforcement costs of the SRR 
were minimal for their administration as the national legislation is already well aligned with 
EU standards. Another public authority estimated enforcement  costs to  be about  10% of an 
FTE  to  monitor  ship  recycling  facilities  and  up  to  5%  of  an  FTE  for  other  reporting  and 
monitoring  activities.  Finally,  a  third  authority  indicated  that  the  SRR  requires  significant 
resources, mobilising at least 8 to 9 FTEs. However, these costs can also vary across competent 
authorities of the same jurisdiction depending  on their level  of responsibility to  enforce the 
regulation.  

Costs associated with the development and maintenance of IHM also  vary according to 
stakeholders interviewed. Three consultancies and one shipowner association explained that 
many shipowners use external companies to develop and maintain their IHM as these activities 
can entail important administrative tasks to cope with.  

Coherence 
A  few  concerns  related  to  the  internal  coherence  of  the  SRR  were  raised  by  a  couple  of 
stakeholders.  One  NGO  emphasised  the  challenges  arising  from  the  regulation's  current 
definition of 'ship recycling', which is considered too narrow to be sufficiently aligned with 
broader sustainability goals. One public authority also raised concerns about the ambiguity in 
the  definitions  within  the  SRR,  the  HKC,  the  Basel  Convention,  and  the  Waste  Shipment 
Regulation. The lack of a specific definition of when a ship becomes ‘waste’ is identified as a 
significant issue affecting both supervision and enforcement efforts. Another public authority 
identified procedural gaps within the SRR as an internal coherence concern, noting the absence 
of explicit requirements for maintaining Part I of the inventory of hazardous materials. 

Regarding external coherence, one NGO recognised some progress in aligning the SRR with 
the  circular  economy  objectives  and  other  environmental  legislation,  especially  concerning 
high-quality  scrap  steel  recycling  from  ships.  However,  they  also  identified  areas  for 
improvement,  considering  that  the  SRR  and  the  Waste  Shipment  Regulation  overlap.  One 
public  authority  also  considered  that  the  SRR  is  not  consistent  with  the  Waste  Shipment 
Regulation, supporting simplification measures to enhance overall external coherence, such as 
extending  the  approval  period  for  EU  facilities  and  limiting  the  number  of  entities  under 
obligations.  

98 

 
 
 
 
 
 
 
EU added value 
Stakeholders interviewed recognise  the EU added value of the ship recycling regulation. 
One public authority mentioned the added value of the SRR in setting stricter rules for ship 
recycling and setting an example for ship recycling practices beyond the EU. This opinion is 
shared by other stakeholders (one organisation from the steel industry and one consultancy) 
who stress the role of the SRR in providing clear guidance for the industry on the direction to 
follow to adopt and implement sustainable ship recycling practices.  

A  few  stakeholders  (one  public  authority  and  one  consultancy)  consider  that  having  a 
regulation  at  the  EU  level  rather  than  at  national  levels  allows  to  reduce  discrepancies  and 
inconsistencies.  They  considered  that  the  SRR  avoids  the  multiplication  of  different 
legislations across countries and sets a harmonised approach and standards. 

Relevance 
Stakeholders  offer  diverse  perspectives  on  the  relevance  of  the  SRR.  Two  consultancies 
expressed concerns about the coexistence of dual regulatory frameworks, such as the HKC 
and European regulations, which could pose challenges in Europe, and stressed the importance 
of  aligning  these  regulations  for  consistency.  They  suggested  exploring  synergies  with 
complementary  sectors  and  expanding  the  SRR's  scope  to  include  non-EU-flagged  ships, 
irrespective of their ownership or flag.  

From a shipowner's perspective, limitations in the geographical distribution and size capacity 
of the European List of recycling yards' have posed challenges. According to them, the current 
capacity, the pricing constraints and underquoted vessels in approved yards make it difficult 
for stakeholders to meet the SRR standards. Questions on whether the SRR's impact stems from 
its effectiveness or diplomatic efforts were raised, suggesting focusing on enhancing global 
regulations like the HKC instead.  

5.  General workshop 

The workshop included three sessions: one related to the evaluation of the SRR which touched 
upon  issues  related  to  capacity,  control  of  hazardous  materials  and  the  extension  of  the 
regulation’s  scope;  another  one  discussed  the  enforcement  of  the  regulation  and  included 
exchanges of views on the definition of end-of-life vessels, transfer of liability, and effects of 
sanctions;  a  third  session  dealt  with  the  introduction  of  a  potential  financial  incentive  to 
facilitate safe and sound ship recycling. The key points raised per topic are presented below for 
the three sessions. 

Respondents’ profile 
Organised  in  June  2023,  the  workshop  gathered  62  stakeholders  and  26  representatives  of 
Member States. Out of these 88 participants, 36 joined the meeting in person and 52 online via 
a teleconferencing platform. 

Session 1 – Evaluation of the Ship Recycling Regulation 
The first session focused on the evaluation of the Ship Recycling Regulation. The participants 
expressed different opinions on two main aspects: the capacity of the Facilities on the European 
List to handle the current and future demand for ship recycling and the control of hazardous 
materials that are present or generated during the recycling process. Some stakeholders argued 
that there is enough capacity on the Facilities on the European List, while others pointed out 
the  limitations  and  challenges,  especially  for  larger  ships.  Some  stakeholders  also  raised 

99 

 
 
 
 
 
 
 
 
concerns about the enforcement and monitoring of the regulation, the quality and availability 
of the inventory of hazardous materials, and the level playing field between the EU and non-
EU ship recycling facilities. There was a debate on whether to extend the scope of the regulation 
to  other vessels,  such as fishing  vessels, inland  waterway vessels,  and  military vessels, and 
under what conditions. 

Session 2: Enforcement 
The second session discussed the challenges and solutions for the effective enforcement of the 
Ship Recycling Regulation. The participants highlighted the role of different actors, such as 
flag  states,  port  state  control,  classification  societies,  and  financial  institutions,  in  ensuring 
compliance  with  the  regulation.  They  also  addressed  the  issues  of  transfer  of  liability,  re-
flagging, and beneficial ownership, which can be used to circumvent the regulation or avoid 
responsibility for ship recycling. They stressed the need for more transparency, cooperation, 
and  harmonization  among  the  relevant  authorities  and  stakeholders,  as  well  as  the  use  of 
incentives and sanctions to promote responsible ship recycling practices. 

Session 3: Financial instrument 
The  third  session  debated  the  pros  and  cons  of  a  financial  instrument,  such  as  the  Ship 
Recycling  Licence,  to  support  the  implementation  of  the  Ship  Recycling  Regulation.  The 
participants  expressed  doubts  about  the  feasibility,  effectiveness,  and  fairness  of  such  an 
instrument,  and  raised  concerns  about  its  possible  negative  impacts  on  the  EU  ports  and 
shipping industry. 

6.  Dedicated workshop on capacity 

A dedicated workshop on the capacity of recycling yards was held in Brussels on 3 August 
2023  and  involved  representatives  from  the  ship  recycling  industry  and  shipowners.  The 
discussion  focussed  mainly  on  the  current  ship  recycling  capacity  in  the  Facilities  on  the 
European List and how it compares to the demand from EU-flagged ships. It also allowed to 
exchange on respective quantitative data available. 

7.  Expert group meeting 

Findings of the evaluation of the SRR were presented to the expert group on  ship recycling 
during a meeting organised in January 2024.  The presentation was followed by discussions. 
This  meeting  gathered  representatives  from  national  competent  authorities,  the  NGO 
Shipbreaking platform, ISRA and ECSA.  Downstream waste management costs (linked to the 
costs  of  management  of  hazardous  materials)  and  corporate  costs  (eg  insurance)  were 
mentioned as important factors in the determination of the recycling price. Member States also 
highlighted that the fact that the SRR allows for independent inspection of yards, which the 
HKC  does  not,  should  be  considered  as  an  important  EU  added  value.  In  relation  to  the 
efficiency/costs  aspects,  it  was  underlined  that  controls  of  ships  by  inspectors  are  currently 
mainly documents checks but there is a need for more training, resources, and investigation 
tools for better enforcement.  Finally, the actual impact of the SRR on the ratification of HKC 
and the concept of beneficial ownership was also questioned. 

On enforcement specifically, a few competent authorities raised the possibility of using new 
tools  to  enforce  compliance  and  bring  evidence  of  cases  where  ships  are  being  illegally 
recycled. They noted the challenges of Port State Control Officers to verify and check some 
elements such as hazardous materials. 

100 

 
 
 
 
 
 
 
 
ANNEX  VI  INTERNATIONAL  AND  EU  LEGAL  FRAMEWORKS  APPLICABLE  TO  THE 
TRANSBOUNDARY MOVEMENTS AND RECYCLING OF END-OF-LIFE SHIPS   

The legal status of an end-of-life vessel is peculiar as an end-of-life vessel can be defined both 
as a waste and as a ship. When considered as waste, end-of-life vessels are subject to specific 
rules applying to hazardous waste, as they contain hazardous materials. This dual legal status 
as  hazardous  waste  and  ship  has  a  particular  importance  in  relation  to  the  transboundary 
movements of end-of-life vessels.  

International legal framework 

At the international level, the transboundary movements of hazardous waste are subject to the 
Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and their 
Disposal, which has been in force since 1992 and has 191 Parties, including the EU and its 
Member States. This Convention sets out a comprehensive regime governing the transboundary 
movements of hazardous waste. The Convention was amended in 1995 by the so-called ‘Ban 
Amendment’ which prohibits the exports of hazardous wastes from OECD countries to non-
OECD  countries.  The  Ban  Amendment  entered  into  force  at  the  international  level  on  5 
December 2019. Parties to the Basel Convention which have ratified the Ban Amendment and 
are members of the OECD are therefore not authorised to allow the export hazardous waste 
(such as end-of-life vessels) to non-OECD countries.  

End-of-life  vessels  are  also  covered  by  Hong  Kong  Convention  for  the  safe  and 
environmentally  sound  recycling  of  ships  (“HKC”).  This  Convention  aims  to  address  ‘the 
environmental,  occupational  health  and  safety  risks  related  to  ship  recycling,  taking  into 
account the particular characteristics of maritime transport and the need to secure the smooth 
withdrawal of ships that have reached the end of their operating lives’. It was adopted in 2009 
under  the  auspices  of  the  International  Maritime  Organisation  (IMO).  It  has  23  Parties, 
including 11 Member States and Norway. The HKC will enter into force in June 2025. The 
HKC establishes a dedicated regime for ship recycling, which sets out obligations for its Parties, 
in respect of the vessels flying their flags and ship recycling facilities located in their territory. 
One key element of the HKC is that each Party shall only authorise ships to be dismantled in 
recycling facilities that meet the requirements of the Convention relevant to such facilities; and 
conversely  that  recycling  facilities  shall  only  be  authorised  to  recycle  ships  meeting  the 
requirements of the Convention relevant to ships.  

Unlike the Basel Convention, the HKC does not contain any geographical limitation, so that it 
does not prohibit the movements of an end-of-life vessel from OECD to non-OECD countries. 

Discussions took place in the context of the Basel Convention on the interplay between the 
HKC and the Basel Convention. In October 2011, Parties to the Basel Convention encouraged 
the ratification of the НКС in order to enable its entry into force. However, they could not reach 
a  consensus  on  the  question  of  equivalence  between  the  Basel  and  HKC  regime218.  These 
discussions  took  place  before  the  Basel  Ban  amendment  and  the  Hong  Kong  Convention 
entered into force. No further discussion took place since then at the multilateral level.  

218 BC-10/17: Environmentally sound dismantling of ships: 

https://www.basel.int/Portals/4/download.aspx?d=UNEP-CHW-COP.10-BC-10-17.English.pdf 

101 

 
 
 
EU legal framework 

At the EU level, the shipments of hazardous waste are regulated through the Waste Shipment 
Regulation,  which  implements  the  Basel  Convention.  This  includes  the  Ban  Amendment, 
which is implemented into EU law through the Waste Shipment Regulation (WSR), therefore 
establishing a ban on the export of hazardous waste from the EU to countries outside the OECD. 
The WSR has just been revised and a new version of this Regulation entered into force in May 
2024. It contains specific provisions designed to ensure the implementation of the Basel Ban 
amendment to end-of-life vessels, taking their specificity into consideration. Under the WSR, 
it is prohibited to export end-of-life vessels which have become waste in the EU to non-OECD 
countries (and therefore fall within the scope of the Basel Ban amendment). On the other hand, 
those EU-flagged ships that have become waste outside the EU are exempted from the regime 
established by the WSR and are subject to the Ship Recycling Regulation, as they are outside 
the scope of the Basel Ban amendment. This means that they can still get recycled in facilities 
located outside the OECD, as long as these facilities are included in the European List set out 
by  the  Ship  Recycling  Regulation.  In  this  respect,  it  is  also  important  to note  that  a  certain 
proportion  of  the  EU-flagged  fleet  reportedly  operates  solely  outside  European  waters. 
Furthermore, a decision to recycle a ship is often taken while the ship is in international waters 
outside the jurisdiction of a Member State. 

The EU is not a Party to the Hong Kong Convention as only States can become Parties to it. In 
2009, the Council adopted conclusions to ‘encourage strongly Member States to ratify the Hong 
Kong Convention as a matter of priority so as to facilitate its entry into force as early as possible 
and to generate a real  and effective change on the ground.219’.  The Commission adopted in 
2010  a  Communication  on  ‘An  assessment  of  the  link  between  the  IMO  Hong  Kong 
Convention for the safe and environmentally sound recycling of ships, the Basel Convention 
and  the  EU  waste  shipment  regulation.’220  This  Communication  laid  the  ground  for  the 
development of the Ship Recycling Regulation, which was adopted in 2013. The Council of 
the European Union adopted a Decision in 2014 authorising Member States to ratify or accede 
to the HKC. The EU Ship Recycling Regulation contains provisions which implement the HKC 
and makes several references to the latter. Yet it also includes a few different definitions, more 
stringent  environment  and  safety  requirements,  a  different  control  system  and  standalone 
administrative  documents  to  support  implementation.  The  Ship  Recycling  Regulation  was 
amended in May 2024 through the revised WSR221, to ensure consistency with the WSR and a 
sound implementation of the Ban amendment in EU legislation.  

The EU legislation on the transboundary movements of end-of-life vessels is therefore in line 
with  the  Basel  Convention,  including  the  Basel  Ban  amendment.  It  does  not  go  against  the 
Hong Kong Convention, which states in its Article 1(2) that the provision of the HKC shall not 
be  interpreted  as  preventing  a  Party  from  taking  ‘more  stringent  measures  consistent  with 
international  law,  with  respect  to  the  safe  and  environmentally  sound  recycling  of  ships,  in 
order to prevent, reduce or minimize any adverse effects on human health and the environment’. 

219 https://www.consilium.europa.eu/uedocs/cms_data/docs/pressdata/en/envir/110626.pdf 
220 COM(2010)88 final. 
221 OJ L, 2024/1157, 30.4.2024, https://eur-lex.europa.eu/eli/reg/2024/1157/oj  

102 

 
 
 
 
Practical implications  

In practice, the EU rules applicable to the transboundary movements of an end-of-life vessel 
depend on the location where such vessel becomes waste.  

If a vessel becomes waste in the EU, then it cannot be exported outside the OECD, in line with 
the provisions in the waste shipment regulation which implement the Basel ban amendment. In 
addition, if that vessel is flying the flag of a Member State, it can only be recycled in facilities 
included in the European List of ship recycling facilities, in line with the SRR.  

If a vessel flying an EU flag becomes waste outside the EU, then it is only subject to the SRR 
and not to the ban on export to non-OECD countries: it can be recycled in facilities outside the 
OECD, as long as the facility is included in the European List established under the SRR.  

103 

 
 
 
ANNEX VII REPORTING REQUIREMENTS UNDER SRR AND ADMINISTRATIVE BURDEN 

In its Communication on ‘Long-term competitiveness of the EU: looking beyond 2030’, the 
Commission  stressed the importance of  a regulatory system  that  ensures  that objectives  are 
reached  at  minimum  costs.  It  committed  to  rationalise  and  simplify  reporting  requirements, 
with the ultimate aim to reduce such burdens by 25%, without undermining the related policy 
objectives.  

Reporting requirements play a key role in ensuring correct enforcement and proper monitoring 
of legislation. Their costs are overall largely offset by the benefit they bring, in particular in 
monitoring and ensuring compliance with key policy measures. 

A ‘reporting requirement’ (RR) is a requirement stemming from  EU legislation  that obliges 
Member  States  authorities,  private  organisations  and/or  public  organisations  to  provide  (in 
principle periodically) structured or unstructured data (qualitative or quantitative) to competent 
authorities at EU or national level. The notion of reporting requirements includes the provision 
of  information  from  businesses  to  other  businesses  or  from  businesses  to  consumers,  while 
certification, labelling, permitting, and similar processes are not included. 

In the context of the SRR, ten potential reporting requirements are identified. Of these, four are 
included in the Commission’s baseline of reporting requirements (as set out by the Office of 
Publications and being used to measure the reduction of reporting burdens by 25%). The six 
excluded  are  either  obsolete,  related  to  notification  of  competent  authorities  or  contacts,  or 
relate to the Commission notifying the other institutions of the exercise of its delegated acts.  

Of the four, each is considered proportionate. The reporting obligations under Articles 14, 15 
and 16 are indispensable information for the management of the European List of ship recycling 
facilities and costs are negligeable. Without that information the Commission cannot include 
the ship recycling facilities that have been authorised by Member States (Article 14) and update 
related information where needed (Article 16). This said, to reduce administrative burden it 
could  be  considered  to  increase  the  period  of  validity  of  inclusion  in  the  European  List 
(currently of 5 years after which it can be renewed) (see also Annex IV), taking into account 
the  monitoring  mechanisms  put  in  place. As  the  certification  by  the  independent  verifiers 
required for applications and renewals of facilities located in third countries shows some limits, 
it could also be envisaged to waive that requirement at least for the renewal if the yard was 
subject to a recent (to be defined) inspection by the Commission. The Commission needs also 
to be kept informed about any change in the facilities located in third countries  and receive 
updated evidence of compliance for their renewal (Article 15).  

The reports by the Member States under Article 21 are important for the enforcement of the 
Regulation.  It enhances transparency of ship recycling and should contribute to Member States 
taking measures to prevent circumvention of ship recycling rules. With that objective, Member 
States should report information concerning ships to which an inventory certificate has been 
issued, ships for which a statement of completion has been received and information regarding 
illegal recycling and follow up actions that they have undertaken. This information should in 
principle be ready-made-available in relevant competent authorities’ record.  It can be noted 
that the reporting of these three items is required under the Hong Kong Convention (HKC).  
However, the HKC includes a longer list of seven items that must be reported annually, whereas 
the reporting is every 3 years under the SRR. In view of the entry into force of the HKC in June 
2025,  the  Commission  is  working  with  EMSA  to  rationalise  the  reporting  via the  Dynamic 

104 

 
 
 
Overview  of  National Authorities  (DONA)  in  accordance  with  the  ‘once  only  principle’  to 
prevent double reporting to the IMO and to the Commission. In this context, it will be assessed 
how a dataflow could take place between IMO Global Integrated Shipping Information System 
(GISIS) and DONA. 

Article title 

Reporting requirement identified by 
the Office of Publications 

1  Article 14: 

Authorisation 
of ship 
recycling 
facilities 
located in a 
Member State  

2  Article 15: 

Ship recycling 
facilities 
located in a 
third country  

3  Article 16: 

Establishment 
and updating of 
the European 
List  

4  Article 21: 

Reports by the 
Member States  

5  Article 18: 

Designation of 
competent 
authorities and 
administrations  

6  Article 19: 

Designation of 
contact persons  

Where a ship recycling facility has 
been authorised in accordance with 
paragraph 1, the Member State 
concerned shall inform the 
Commission thereof without delay. 

The ship recycling company shall 
provide updated evidence without 
delay in the event of any changes to the 
information provided to the 
Commission and shall, in any event, 3 
months prior to expiry of each 5 year 
period of inclusion on the European 
List, declare that: (a) the evidence that 
it has provided is complete and up-to-
date; (b) the ship recycling facility 
continues and will continue to comply 
with the requirements of Article 13. 

Member States shall communicate to 
the Commission all information that 
may be relevant in the context of 
updating the European List. The 
Commission shall forward all relevant 
information to the other Member 
States. 
Each Member State shall send to the 
Commission a report containing the 
following: (a) a list of the ships flying 
its flag to which a ready for recycling 
certificate has been issued, and the 
name of the ship recycling company 
and the location of the ship recycling 
facility as shown in the ready for 
recycling certificate; (b) a list of the 
ships flying its flag for which a 
statement of completion has been 
received; (c) information regarding 
illegal ship recycling, penalties and 
follow-up actions undertaken by the 
Member State. 
Member States shall designate the 
competent authorities and 
administrations responsible for the 
application of this Regulation and shall 
notify the Commission of those 
designations. Member States shall 
immediately notify the Commission of 
any changes in such information. 
Member States shall notify the 
Commission of the designation of 
contact persons.  

105 

In the 
Commission 
baseline (for 
measurement 
of the 25%)? 
YES 

Reporting 
entity 

The 
Member 
State 
concerned 

Addressee 

Frequency 

the 
Commission 

Every5 
years and 
where 
needed 

YES 

Ship 
recycling 
company 

the 
Commission 

without 
delay and, 
in any 
event, 3 
months 
prior to 
expiry of 
each 5  
year 
period of 
inclusion 

YES 

Member 
States 

the 
Commission 

YES 

Each 
Member 
State 

the 
Commission 

Every 3 
years 

Member 
States 

the 
Commission 

- 

Member 
States 

the 
Commission 

- 

NO - 
provision of 
information 
on contact 
points 

NO - 
provision of 
information 
on contact 
points 

 
 
  
 
7  Article 19: 

Designation of 
contact persons  

Member States shall immediately 
notify the Commission of any changes 
to that information. 

8  Article 22: 

Enforcement in 
Member States  

9  Article 29: 

Financial 
incentive  

10  Article 24: 

Exercise of the 
delegation  

Member States shall communicate to 
the Commission the provisions of their 
national law relating to the 
enforcement of this Regulation and the 
applicable penalties. 

The Commission shall, by 31 
December 2016, submit to the 
European Parliament and to the 
Council a report on the feasibility of a 
financial instrument that would 
facilitate safe and sound ship recycling 
and shall, if appropriate, accompany it 
by a legislative proposal. 

As soon as it adopts a delegated act, 
the Commission shall notify it 
simultaneously to the European 
Parliament and to the Council. 

Member 
States 

the 
Commission 

- 

Member 
States 

the 
Commission 

- 

NO - 
provision of 
information 
on contact 
points 
NO - only 
once off 
transposition 
notification  

NO - 
obsolete 

The 
Commission 

NO - exercise 
of derogation 
power 

the 
Commission 

- 

- 

the 
European 
Parliament 
and the 
Council 

the 
European 
Parliament 
and the 
Council 

106 

 
 
 
 
 
 
 
ANNEX VIII MORE DATA ON VESSEL RECYCLING, AND THE EVOLUTION OF THE FLEET AND 
ITS RECYCLING FORECAST 

1. Detailed information about vessel recycling 

1.1.   Recycled materials by type of vessel 

Table 0-1 Recycled materials and percentage of the recycled weight (LDT) by type of 
vessel 

Recycled material 

Re-rollable ferrous steel 
Meltable ferrous steel 
Cast iron scrap 
Non-ferrous metals 
Weight loss 
Machinery  
Wooden furniture and fitting/ 
Fixtures 

General cargo 
56 - 70% 
10% 
1.5 - 5% 
0.5 - 1% 
9 - 15% 
4 -8 % 
5% 

Bulk carriers 
61 - 76% 
8 - 10% 
1.5 - 2.5% 
0.5% 
10 - 16% 
1 - 6% 
1 - 5% 

Oil tankers 
72 - 81% 
5 - 7% 
1.5 - 3% 
0.5 - 2% 
10 - 12% 
0.5 - 2% 
1.5 - 2% 

Source: Compilation based on Mahindrakar et al. (2008). 

1.2.  Evolution of the average age of recycling from 2012 to 2022 

Most vessels have a normal  life span of about  30 to  40 years after which they are send for 
recycling,  although  in  the  specific  case  of  container  vessels  the  age  of  recycling  has  been 
consistently lower than that in the period from 2012 to 2022. The average recycling age varies 
over  time,  with  shipping  market  conditions  largely  determining  whether  the  recycling  of  a 
vessel  is  delayed  or  done  before  the  expected  lifetime.  Recycling  data  for  this  period  also 
suggests that this recycling age varies not only on the type of the vessel as shown in the figure 
below, but also depending on its size. 

Figure 0.1.: Average age of recycling per type of vessel 2012-2022 

Source: Elaboration by consortium that carried out the support study based on NGO Shipbreaking Platform and 
EMSA data. 

107 

 
 
 
 
On the basis of data of the vessels recycled during 2012-2022, the median lifetime for all vessel 
types have been calculated and are presented in the table below. The calculated median lifetime 
for vessels recycled in this timeframe is between 19 and 48 years, depending on the type and 
size of the vessel.  

      0.2.: Median age at which vessels are recycled, broken down by vessel size and type 

Vessel size 

Small 
GT<500  

Medium 
500≤GT<25,000 

Large 
5,000≤GT<60,000 

Very large  
GT≥60,000 

Vessel type 

General cargo 

Median 
48 

Standard deviation 
7.2 

Other types of vessels 
Fishing vessels 
Offshore vessels 
General cargo 

Container vessels 
Bulk carriers 
Oil tankers 
Other types of vessels 
Fishing vessels 
Offshore vessels 
General cargo 

Container vessels 
Bulk carriers 
Oil tankers 
Other types of vessels 
Fishing vessels 
Offshore vessels 
Container vessels 

Bulk carriers 
Oil tankers 
Other types of vessels 
Offshore vessels 

45 
28 
36 
33 

23 
30 
28 
34 
37 
36 
31 

20 
24 
23 
25 
25 
33 
19 

22 
25 
20 
27 

15.7 
n. a. 
3.0 
8.5 

5.5 
7.1 
6.3 
9.6 
8.0 
10.7 
5.1 

7.3 
5.3 
6.3 
6.3 
n. a. 
12.2 
3.3 

3.7 
8.6 
5.3 
11.3 

Source: Elaboration by consortium that carried out the support study based on NGO Shipbreaking Platform and 
EMSA data (EQUASIS). 

1.3.  Recycling in 2021 and 2022 

The table below shows the total number of ships, gross tonnage, and LDT recycled in the last 
two years for which data was available. It is worth noting that the dataset used include only 
vessels of 500 GT or above. 

     0.3.: Recycling volumes in 2021 and 2022 by size - number of ships, total volume in GT and LDT 

Recycling 
year 
2021 

Total number of 
ships 
809 

Gross tonnage 

LDT 

16,206,825 

6,348,159 

108 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Gross tonnage 

Recycling 
year 
8,067,298 
2022 
24,274,123 
Total 
Source: Elaboration by consortium that carried out the support study based on NGO Shipbreaking Platform and 
EMSA data 

Total number of 
ships 
451 
1,260 

3,225,854 
9,574,013 

LDT 

The volumes recycled are lower in 2022 than they are in 2021. The combined recycled volume 
for 2021 and 2022 can also be broken down by vessel size as seen in the table below. 

     0.4.: Cumulated recycling volumes for 2021 and 2022 by vessel type - number of ships, total volume 
in GT and LDT (for all ships) 

Vessel type 

Gross tonnage 

LDT 

Total number of 
ships 
128 
22 
61 
182 
237 
295 
335 

Bulk carriers 
Container ships 
Fishing vessels 
General cargo 
Offshore vessels 
Oil tankers 
Other types of 
ships 
Grand total 
Source: Elaboration by consortium that carried out the support study based on NGO Shipbreaking Platform and 
EMSA data 

5,734,262 
269,904 
138,757 
1,121,276 
4,241,464 
8,657,234 
4,111,226 

1,648,999 
130,994 
119,231 
611,962 
2,268,387 
2,885,358 
1,909,082 

24,274,123 

9,574,013 

1,260 

The largest share of vessels (measured by GT) over that period is taken by oil tankers, followed 
by  bulk  carriers.  In  contrast,  very  little  container  vessels  were  recycled  over  that  period, 
possibly reflecting shipping market conditions where container shipping rates were high. 

1.4.  Evolution of the recycling locations from 2012 to 2022 

The figure below shows the geographical distribution of vessel recycling from 2012 to 2022. 

109 

 
 
 
F     0.2.: Gross tonnage of recycled vessels by country 

Source: Elaboration by consortium that carried out the support study based on data of NGO Shipbreaking 
Platform and EMSA. 

The figure shows that in recent years the total recycling activity has slowed, while the share 
that  South  Asian  facilities  take  from  the  global  activity  has  slowly  increased  and  is  now 
upwards of 80%. The figure below shows the share of each country in greater detail. 

F      0.3.: Share of gross tonnage of recycled vessels by country 

110 

 
 
 
 
Source: Elaboration by consortium that carried out the support study based on data of NGO Shipbreaking 
Platform and EMSA. 

The share of global vessel recycling taken up by India has decreased from almost 40% to almost 
30% from 2012 to 2022. In contrast, over the same period Bangladesh has almost doubled its 
share from 23% to 37%, and Türkiye has grown from around 2% to 10% of the market. During 
this period China implemented a ban on the recycling of foreign-flagged vessels, bringing the 
share of Chinese facilities from 18% to just over 2%. 

The  figure  below  represents  the  volume  of  vessels  recycled  by  country  over  the  evaluation 
period, this time expressed in LDT recycled. 

F     0.4.: Volume of scrapped vessels by country of recycling (in LDT) (2012-2022) 

12

10

)
T
D
L
s
n
o

i
l
l
i

m

(
d
e
l
t
n
a
m
s
i
d
e
m
u
o
V

l

8

6

4

2

0

a
i
s
A
h
t
u
o
S
n

i

d
e
l
c
y
c
e
r

%

100%

90%

80%

70%

60%

50%

40%

30%

20%

10%

0%

2012

2013
2014
Bangladesh
China
Other

2015

2016

2017

2018

2019

2020

India
Türkiye
% southeast Asia

2021

2022
Pakistan
EU/EEA

Source: Elaboration by consortium that carried out the support study based on data of NGO Shipbreaking 
Platform and EMSA. 

For 2021 and 2022, the majority of EU-flagged vessels (including re-flagged 1 year or less 
before being dismantled) were recycled, in order of largest volume to lowest volume (in GT), 
in Pakistan, Türkiye, and Bangladesh, with smaller shares being recycled in India and the EU 
(see figure below). 

111 

 
 
 
 
 
 
 
 
 
 
 
 
 
F      0.5.: Share (GT) of EU and non-EU-flagged vessels recycled in each country. 

Source: Elaboration by consortium that carried out the support study based on data of NGO Shipbreaking 
Platform and EMSA. 

In terms of registered ownership, Indian recycling facilities receive the largest share of vessels 
owned by EU companies, followed by Bangladesh, Pakistan, and Türkiye, with only a very 
minor fraction ending in EU recycling facilities. The share of EU-owned vessels recycled in 
South Asia is larger than the share of EU-flagged vessels recycled there. 

F      0.6.: Share (GT) of EU and non-EU owned vessels recycled in each country. 

Source: Elaboration by consortium that carried out the support study based on data of NGO Shipbreaking 
Platform and EMSA. 

112 

 
 
 
 
 
 
     0.5.: Recycling locations of EU-flagged and EU owned commercial vessels (of over 
500 GT)  in terms of percentage of total recycling (GT) in 2021 and 2022 

Country of recycling 

Total gross tonnage 

Share of total gross 
tonnage 

Bangladesh 
India 
Pakistan 
Türkiye 
EU 
Other 
Source: Elaboration by consortium that carried out the support study based on data of NGO Shipbreaking 
Platform and EMSA. 

968,547 
1,071,422 
853,917 
954,020 
155,884 
1,286 

24.18% 
26.75% 
21.32% 
23.82% 
3.89% 
0.03% 

The  two  tables  below  allow  a  comparison  of  the  top  flag  states  by  vessels  recycled  and  by 
vessels in operation in 2022. 

      0.6.: Top 25 flag states by recycling volume in 2022 (registered flags at the moment of recycling) 

Flag 

GT 

Numbe
r of 
vessels 

Percentage 
from global 
fleet (GT) 

St Kitts & Nevis 
1567374  66 
Comoros 
1106032  33 
Panama 
47 
949802 
Liberia 
17 
837363 
Palau 
22 
383011 
Bahamas 
6 
309264 
Gabon 
17 
261269 
Tanzania 
9 
234934 
Togo 
11 
234608 
Marshall Islands 
6 
230127 
Isle of Man 
4 
186554 
China 
11 
179523 
United States of America 
7 
161480 
Indonesia 
11 
108075 
Cameroon 
12 
107582 
Dominica 
2 
100179 
South Africa 
1 
92993 
Sierra Leone 
12 
79702 
Norway 
9 
75310 
India 
7 
70352 
Vietnam 
5 
62162 
1 
Saudi Arabia 
57949 
2 
48953 
Guyana 
5 
St Vincent & The Grenadines  43703 

113 

19.86 
14.02 
12.04 
10.61 
4.85 
3.92 
3.31 
2.98 
2.97 
2.92 
2.36 
2.28 
2.05 
1.37 
1.36 
1.27 
1.18 
1.01 
0.95 
0.89 
0.79 
0.73 
0.62 
0.55 

Cumulat
ive 
percenta
ge 
19.86 
33.88 
45.92 
56.53 
61.39 
65.31 
68.62 
71.6 
74.57 
77.49 
79.85 
82.12 
84.17 
85.54 
86.9 
88.17 
89.35 
90.36 
91.32 
92.21 
93 
93.73 
94.35 
94.91 

 
 
 
Flag 

GT 

Numbe
r of 
vessels 

Percentage 
from global 
fleet (GT) 

Cumulat
ive 
percenta
ge 
95.42 

Singapore 
Source: Elaboration by consortium that carried out the support study bbased on data of NGO Shipbreaking 
Platform and EMSA. 

40581 

0.51 

3 

      0.7.: Top 25 flag states by vessels in operation in 2022  

GT 

Number 

Percentage from 

Cumulative 

230487027 

of ships 
7986 

global fleet (GT) 
15.52 

percentage 
15.52 

Flag 

Panama 

Liberia 

Marshall Islands 

China, Hong Kong SAR 

Singapore 

Malta 

China 

Bahamas 

Greece 

Japan 

Denmark 

United Kingdom 

Cyprus 

Indonesia 

Norway 

Portugal 

Italy 

Korea, Republic of 

207730469 

4304 

177890350 

4047 

131258613 

2663 

89004784 

83140842 

77171289 

61513721 

36397286 

29815720 

3226 

2046 

7939 

1309 

1230 

5193 

22961571 

735 

22927210 

22572765 

1181 

1030 

21217721 

11243 

19763660 

1712 

19221303 

824 

14197620 

12598918 

1285 

2147 

13.99 

11.98 

8.84 

5.99 

5.6 

5.2 

4.14 

2.45 

2.01 

1.55 

1.54 

1.52 

1.43 

1.33 

1.29 

0.96 

0.85 

0.79 

0.73 

0.7 

0.7 

0.63 

0.54 

0.52 

29.52 

41.5 

50.34 

56.33 

61.93 

67.13 

71.27 

73.73 

75.73 

77.28 

78.82 

80.34 

81.77 

83.11 

84.4 

85.36 

86.2 

86.99 

87.72 

88.43 

89.13 

89.76 

90.29 

90.82 

Iran (Islamic Republic of) 

11708882 

949 

United States of America 

India 

Bermuda 

Russian Federation 

Malaysia 

France 

10835458 

10451434 

3529 

1813 

10396365 

135 

9326566 

7965360 

7789102 

2925 

1763 

561 

Source: Elaboration by consortium that carried out the support study based on data of UNCTAD maritime 
transport statistics 

In 2022 a total of 42 EU-flagged vessels were sent to dismantling, including both vessels that 
had an EU flag upon arrival to a recycling facility and those that had still an EU flag 1 year 
before being recycled. This amounted to 8.52% of the worldwide volume sent for recycling in 
that year (see figure below). 

114 

 
 
 
      0.8.: Proportion of EU-flagged vessels recycled (including vessels re-flagged in the last year before 
being recycled) compared to the worldwide volume sent for recycling in 2022. 

Flag 
Norway 
Malta 
Cyprus 
Greece 
Italy 
Denmark 
France 
Netherlands 
Croatia 
Germany 
Romania 
Iceland 
Spain 
Total 
Source: Elaboration by consortium that carried out the support study based on data of NGO Shipbreaking 
Platform and EMSA. 

Number of vessels  Percentage from global fleet 
12 
5 
5 
4 
2 
3 
2 
2 
1 
1 
1 
3 
1 
42 

GT 
259,875 
130,294 
126,071 
94,694 
43,502 
6,797 
3,162 
2,622 
2,425 
1,992 
1,047 
1,876 
715 
675,072 

3.28 
1.64 
1.59 
1.19 
0.55 
0.09 
0.04 
0.03 
0.03 
0.03 
0.01 
0.02 
0.01 
8.52 

In 2022, 8.63% of the total volume of vessels recycled was registered under the ownership of 
EU entities (EU-owned). It is worth noting that this includes a number of vessels for which 
registered  ownership  is  not  identified,  and  that  EU-owned  vessels  represent  12.22%  of  the 
vessels for which there is an owner noted in the data. 

      0.9.: Proportion of EU-flagged vessels recycled in 2022 (including re-flagged vessels)  

Registered owner  Flag 
Non-EU 

EU 

Unknown 

LDT 

DWT 

GT 
4,564,768  1,677,383  6,870,167  241 
Non-EU 
164,077 
12 
434,031 
580,740 
EU 
25 
186,671 
505,039 
791,776 
Non-EU 
23 
79,903 
191,266 
273,437 
EU 
2,894,497  125 
2,179,329  994,877 
Non-EU 
43,294 
30,049 
EU 
49,775 
138,428 
92,894 
Unknown  143,090 

7 
18 

Number of vessels 

Source: Elaboration by consortium that carried out the support study based on data of NGO Shipbreaking 

Platform and EMSA. 

115 

 
 
 
 
 
 
 
 
 
 
 
 
 
2.  Detailed information about the fleet and recycling forecasts 

2.1. World fleet and EU-flagged vessels 

      0.10.: The world fleet of small vessels not covered by the Hong Kong Convention (500 GT and 
below) by type - number of vessels and total volume in GT (2021) 

Total number of vessels 
World fleet 

EU-
flagged 

Total volume (GT) 

World fleet 

EU-flagged 

Bulkers 
Containers 
Fishing ship 
General cargo 
Offshore vessels 
Oil tankers 
Other vessels 

0 
0 
926 
42 
207 
22 
2,107 
Source: Elaboration by consortium that carried out the support study based on Equasis data. 

115,001 
7,999 
4,399,002 
1,444,000 
789,000 
651,000 
6,340,001 

0 
0 
201,943 
14,208 
58,994 
7,057 
515,139 

286 
12 
20,185 
4,135 
2,809 
2,015 
25,929 

Only a relatively small fraction of vessels from the global fleet flies an EU flag. Elaborating 
on EMSA’s data, below shows the share of the world fleet that flies an EU flag per vessel type. 
The share of the world fleet that flies an EU flag goes from 1.7% for offshore vessels to 18.8% 
for container vessels, or around 13.3% overall (or 16.23% in GT). This compares with 33.17% 
of vessels globally owned by nationals or companies of the EU. 

     0.11.: Share of world fleet vessels by flag 

Vessel type 

EU share of world fleet 

Bulk carriers 
Container vessels 
Fishing vessels 
General cargo 
Offshore vessels 
Oil tankers 
Other types of vessels 

9.9% 
19.0% 
12.6% 
10.4% 
1.7% 
12.0% 
15.1% 

Non-EU share of world 
fleet 
90.1% 
81.0% 
87.4% 
89.6% 
98.3% 
88.0% 
84.% 

Source: Elaboration by consortium that carried out the support study based on EMSA (2022) and UNCTAD 
(2022). 

The table below shows the size of the EU and global fleets in number of vessels and GT, for 
vessels over 500 GT. 

Table0.12: The world fleet of large vessels covered by the Hong Kong Convention (500 GT and 
above) by type - number of vessels and total volume in GT 

Total number of vessels 

Total volume (GT) 

World fleet 
12,586 
Bulkers 
5,539 
Containers 
5,766 
Fishing ship 
General cargo  14,132 

EU-flagged  World fleet 
509,063,000 
668 
265,885,001 
544 
8,032,000 
190 
117,185,999 
1,978 

EU-flagged 
24,756,482 
33,021,617 
259,098 
16,165,191 

116 

 
 
 
 
 
 
 
Total number of vessels 

275 

5,551 

Offshore 
vessels 
1,664 
Oil tankers 
1,012 
Other vessels 
Source: Elaboration by consortium that carried out the support study based on Equasis data 

467,267,999 
42,235,002 

14,497 
5,808 

56,384,999 

59,280,647 
11,839,262 

Total volume (GT) 
1,493,567 

Projections were elaborated for the recycling of vessels in the future until 2050, taking 
into account also the recycling of vessels that are not yet in the fleet but that are expected 
to join in the future, for both the EU-flagged fleet and the global fleet, which can be 
found summarised in the tables below, for both vessels under 500 GT and vessels of 
500 GT and above.2.2.  Projected evolution of vessel recycling 

     0.13: Projected future volumes of recycling of vessels not covered by the Hong Kong Convention 
(under 500 GT) by flag state and year of recycling - number of vessels and total volume.  

Year 

Total number of vessels 

Total volume (GT) 

World fleet 

EU-flagged 

World fleet 

EU-flagged 

2024 
2025 
2026 
2027 
2028 
2029 
2030 
2031 
2032 
2033 
2034 
2035 
2036 
2037 
2038 
2039 
2040 
2041 
2042 
2043 
2044 
2045 
2046 
2047 
2048 
2049 
2050 

1,420 
1,529 
1,607 
1,680 
1,710 
1,720 
1,708 
1,688 
1,654 
1,621 
1,599 
1,586 
1,559 
1,529 
1,492 
1,461 
1,417 
1,384 
1,341 
1,316 
1,312 
1,297 
1,294 
1,289 
1,254 
1,233 
1,217 

16,404 
17,956 
19,346 
20,402 
21,021 
21,205 
21,066 
20,754 
20,459 
20,271 
20,207 
20,236 
20,261 
20,198 
19,984 
19,641 
19,246 
18,890 
18,683 
18,688 
18,909 
19,268 
19,618 
19,856 
19,859 
19,663 
19,324 

73 
81 
84 
92 
92 
93 
90 
95 
90 
86 
89 
90 
86 
86 
80 
81 
83 
78 
79 
77 
75 
85 
78 
81 
77 
72 
84 

332,098 
354,168 
373,232 
387,234 
394,868 
396,284 
393,088 
387,630 
382,225 
378,294 
376,155 
375,166 
374,036 
371,561 
366,895 
360,117 
352,151 
344,363 
338,134 
334,425 
333,266 
333,795 
334,413 
333,459 
329,896 
323,831 
316,503 

117 

 
 
 
 
 
Source: Elaboration by consortium that carried out the support study. 

      0.14: Projected future volumes of recycling of vessels covered by the Hong Kong Convention (500 
GT<) by flag state and year of recycling - number of vessels and total volume. 

Year 

Total number of vessels 

Total volume (GT) 

World fleet 

EU-flagged 

World fleet 

EU-flagged 

2024 
2025 
2026 
2027 
2028 
2029 
2030 
2031 
2032 
2033 
2034 
2035 
2036 
2037 
2038 
2039 
2040 
2041 
2042 
2043 
2044 
2045 
2046 
2047 
2048 
2049 
2050 

2,372 
2,403 
2,394 
2,424 
2,445 
2,486 
2,491 
2,511 
2,512 
2,466 
2,486 
2,422 
2,375 
2,332 
2,256 
2,226 
2,176 
2,147 
2,094 
2,043 
2,042 
2,015 
2,002 
1,997 
2,003 
1,983 
1,970 

239 
245 
235 
234 
241 
244 
239 
244 
231 
228 
238 
217 
223 
217 
205 
208 
199 
202 
198 
194 
189 
199 
186 
191 
200 
193 
167 

49,387,546 
49,878,380 
51,397,761 
54,103,240 
57,809,502 
62,016,759 
66,053,871 
69,285,085 
71,298,335 
71,997,334 
71,570,341 
70,368,835 
68,768,055 
67,069,582 
65,468,211 
64,066,802 
62,907,278 
61,995,662 
61,316,709 
60,842,477 
60,540,128 
60,378,735 
60,331,215 
60,373,241 
60,480,685 
60,629,089 
60,796,413 

5,323,160 
5,303,007 
5,423,817 
5,689,927 
6,058,014 
6,449,297 
6,776,260 
6,973,530 
7,019,663 
6,939,185 
6,785,961 
6,617,077 
6,471,979 
6,365,217 
6,292,524 
6,242,864 
6,207,438 
6,182,429 
6,167,001 
6,159,799 
6,157,742 
6,157,105 
6,154,844 
6,149,884 
6,142,582 
6,134,300 
6,126,634 

Source: Elaboration by consortium that carried out the support study. 

In  the  projections  above,  recycling  is  forecasted  on  the  basis  of  vessel  ages,  however,  the 
forecasts reveal a rate of recycling that is significantly higher than current trends in recycling 
(please see further below). This means that a backlog of vessels that are due for recycling is 
likely to be developing, likely due to higher demand for capacity. In practice this could mean 
that the average ages of recycling could increase in future years, and that when demand for 
capacity drops and shipping rates decrease, recycling facilities could see a marked increase in 
the influx of vessels for recycling due to a possibly no longer profitable ageing fleet. 

118 

 
 
 
 
 
 
 
 
 
 
2.3.  Age profile of the fleet 

F      0.7.: Age profile of the fleet (percentage by Gross Tonnages) 

Source: Elaboration by consortium that carried out the support study. 

F      0.8.: Age profile of the fleet per type category in Gross Tonnage 

Source: Elaboration by consortium that carried out the support study based on Equasis 

119 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
2.4.  Evolution of the world fleet: comparison between the number of vessels delivered 
and the number of vessels recycled between 2014 and 2022. 

F      0.9: Increasing capacity of the world fleet, number of vessels recycled and vessels 
built, in GT 

Source: Elaboration by consortium that carried out the support study based on UNCTAD data. 

120 

 
 
 
 
 
 
 
 
ANNEX IX REPORTING REQUIREMENTS UNDER ARTICLE 21 

1. INTRODUCTION 

This report is part of the obligation of the Commission under Article 21 of the Ship Recycling 
Regulation to report on the implementation of the Regulation based on the individual reporting 
of Member States required under the same article.  This first report covers the information on 
the  period  from  1  January  2019  to  31  December  2021  that  was  due  in  autumn  2022.  
Considering  the  limited  dataset  received  and  the  upcoming  evaluation,  the  Commission 
decided to integrate this first report in the evaluation.  The European Maritime Safety Agency 
(EMSA)  that  has  developed  a  dedicated  reporting  portal  has  contributed  substantially  to 
accompany this exercise in providing guidance and analysing the contributions from Member 
Sates.  

2.  REPORTING OBLIGATIONS UNDER SRR 

2.1. Requirements  

Article 21 of the SRR requires Member State to send every three years to the Commission a 
report containing the following: 

(a)  a list of the ships flying its flag to which a ready for recycling certificate has been 
issued, and the name of the ship recycling company and the location of the ship 
recycling facility as shown in the ready for recycling certificate; 

(b)  a  list  of  the  ships  flying  its  flag  for  which  a  statement  of  completion  has  been 

received; 

(c)  information  regarding  illegal  ship  recycling,  penalties  and  follow-up  actions 

undertaken by the Member State. 

In accordance with Article 21, the first 3-year reporting period covers 1 January 2019 to 31 
December 2021 with 30 September 2022 as deadline for submission of individual reports by 
Member States. No later than nine months after receiving the reports from the Member States, 
the Commission should publish a report on the application of the SRR.  

1.2.Method 

The  Dynamic  Overview  of  National  Authorities  (DONA),  is  a  stand-alone  maritime 
application, developed, maintained and enhanced by EMSA which became operational in June 
2022.    One  of  its  functionalities  is  to  provide  a  single-entry  portal  with  restricted  access, 
through which Member States could, if they opt to do so, fulfil their reporting obligations under 
EU maritime legislation. The SRR is one of the three legal acts covered by the portal in its 
initial phase.  

Where possible, DONA reporting template has tried to reduce the administrative burden for 
Member State’s by eliminating the necessity to repeat entries, which was for example the case 
for ships for which Member States had both the Ready for Recycling Certificate (RFRC) and 
the  ‘Statement  of  Completion’  (SOC).  Also,  if  the  information  in  the  RFRC  and  SOC  had 
already  been  uploaded  into  the  relevant  Ship  Recycling  module  of  THETIS-EU222  by  the 
relevant Member State, then this information is automatically available to DONA.  

222  A  tool  developed  by  EMSA  for  the  recording  of  inspections  on  the  inventories  of  hazardous  materials,  to 

support the Ship Recycling Regulation. 

121 

 
 
To  provide  information  regarding  illegal  ship  recycling,  penalties  and  follow-up  actions 
undertaken by the Member State, the relevant template in DONA provided a section where free 
text could be added. 

The Commission and EMSA issued a note and organized a training event for Member States 
on the use of the Ship-Recycling module in DONA and expected reporting content. 

3.  OVERVIEW OF THE REPORTING FROM MEMBER STATES 

All Member States used DONA for their reporting under Article 21 of the SRR. 26 Member 
States and Norway submitted a report. The submissions can be presented in two categories: 

•  10  Member  States  (Belgium,  Croatia,  Cyprus,  Denmark,  Greece,  Italy,  Malta, 
Netherlands,  Spain,  and  Sweden)  and  Norway  submitted  reports,  providing  specific 
details  or  the  certificates  issued  to  the  vessels  flying  their  flag.  3  Member  States 
(Belgium,  Italy,  Greece223)  provided  information  regarding  actions  undertaken  with 
respect to illegal ship recycling. 

•  16  Member  States  (Austria,  Bulgaria,  Estonia,  Finland,  France,  Germany,  Ireland, 
Hungary  Latvia,  Lithuania,  Luxembourg,  Poland,  Portugal,  Romania,  Slovenia  and 
Slovakia)  provided  a  report  with  no  information  on  vessels  that  have  been  issued  a 
RFRC or for which a SOC had been received. This means that each of these Member 
States reported they had not issued any RFRC over the reporting period, and therefore 
not  received  any  SOC,  as  none  of  their  flagged  vessels  had  been  recycled  in  the 
reporting period. Half of the Member States have just left blank the entire form. The 
others  (Finland,  Ireland,  Latvia,  Lithuania,  Luxembourg,  Romania,  Poland  and 
Slovenia) provided a specific statement saying no RFRC or SOC were issued, and no 
illegal action was identified. 

3.1. On the quality of the reporting 

Regarding  the  respect  of  the  deadline,  it  can  be  noted  that  Latvia,  Lithuania  and  Greece 
submitted their report several months after the deadline and that Czechia and Iceland did not 
submit any report.  

For the 10 Member States and Norway that submitted detailed information, the datasets were 
on many occasions not complete. For almost half of the ships reported the date of the RFRC is 
missing and for less  than one third the date of the  receipt of the  SOC  is  indicated. Limited 
report was received on actions undertaken by Member States regarding illegal ship recycling. 
Member States may have focused their reporting on infringements for ships flying their flag, 
rather than on all ships which they would have taken measures against.  

The  dataset  provided  by  Member  States  (Appendix  I)  was  compared  with  the  information 
extracted  by  EMSA  from  MARINFO224.  54  vessels  that  were  registered  in  MARINFO  as 
recycled between 2019 and 2021 were not part of the Member States’ reporting (Appendix II). 
It appears that 84% of these vessels had a domestic shipping pattern and might therefore not 
fall under the scope of the SRR. However, 9 vessels had a clear international trading pattern in 
the  last  year  of  their  operation  and  should  therefore  have  been  reported  by  Member  States. 
These came from 6 different flags, all of which provided information on other vessels through 

223 The information provided by NL was not sufficient to understand the case. 
224 Marinfo is EMSA’s own internal database based on purchased data. 

122 

 
 
DONA.  This  comparative  exercise  underlines  the  need  to  improve  the  completeness  of  the 
reports.  

 3.2. The outcome on substance 

Member States and Norway reported a total of 90 ships for which RFRC were issued in the 
period  from  1  January  2019  to  31  December  2021225.    A  SOC  had  been  received  for  41  of 
them226. From the information requested no inference could be made as to whether the recycling 
started within the 3 months that the RFRC is valid.  

The  reports  refer  to  vessels  recycled  in  7  countries  at  recycling  facilities  included  in  the 
European list.227 

Table0.15: Location of recycling of reported ships per Member State 

Flag 

Country of Recycling 

Belgium 
Croatia 

Cyprus 

Denmark 

  Greece 

Italy 

Malta 

The Netherlands 

Spain 

Sweden 
Norway 

TOTAL 

Belgium 
Türkiye 

Türkiye 

Norway 

Spain 

Belgium 

Denmark 

Türkiye 

Türkiye 

Ship still in service 
Türkiye 
Italy 

Unknown 
Türkiye 

Unknown 
The Netherlands 

Belgium 

Spain 

Türkiye 

Spain 

Türkiye 
Türkiye 

Norway 

Denmark 

Number of vessels 
2 
1 

5 

4 

1 

1 

10 

2 

6 

2 
4 
1 

1 
18 

6 
4 

1 

1 

1 

1 

1 
11 

4 

2 

90 (including 7 unknown and 2 still in service) 

225 BE:2, HR:1, CY:11, DK:9, EL:8, IT:6, MT:24, NL:7, ES:1, Se:1, NO:17.   
226 There are various reasons for why a Member State has given a ship a RfRC but does not have a corresponding 
SoC. These include: i) The ship is still trading ii) The ship was still being recycled and the SoC had not been 
completed iii) The ship-recycling facility has not forwarded the SoC to the flag State iv) The ship was recycled 
in a facility that is not on the EU-List v) The SoC has been sent but not recorded by the MS or has been 
recorded but not reported in DONA. 

227 Note that the country and the recycling facility were provided for 90% of the submissions. 

123 

 
 
 
 
 
In  general,  considering  that  only  a  few  Member  States  reported  issuing  RFRC,  no  clear 
patterns can be deducted from these data. Nevertheless, the following can be observed: 

•  51.1% of the vessels reported by the Member States were recycled in Türkiye.  
•  For 3 Member States most of their vessels have been recycled in the country of their 

flag: 
-  100% of Belgian flagged vessels were recycled in Belgium; 
-  83% of Danish flagged vessels were recycled in Denmark; and, 
-  57% of Dutch flagged vessels were recycled in The Netherlands. 

•  Conversely,  3  Member  States  reported  that  most  of  their  vessels  were  recycled  in 

Türkiye: 
-  75% of Maltese and Greek flagged vessels and 69% of Norwegian flagged vessels. 

Table0.16: Where ships reported by MS were recycled 

Country of 
Recycling 

Türkiye 
Denmark 
Norway 
Belgium 
The Netherlands 
Spain 
Italy 
Unknown 
Still trading 
Total 

Number of 
vessels where 
information 
was reported 

Percentage 
share of 
Recycling 

46 
12 
8 
4 
4 
3 
1 
7 
2 
90 

51.1.% 
13.3 % 
8.8% 
4.4% 
4.4% 
3.3% 
1.1% 
7.7% 
2.2% 
100% 

Table0.17: A breakdown of reported vessels with a RFRC issued, per ship type 

IMO Ship Type 

Oil Tanker 
General Cargo 
Liquid Gas Tanker 
Ro-Pax 
Bulk Carrier 
Cruise Ships 
Chemical Tanker 

Container Ship 
Ro-Ro 
Vehicle Carrier 

Others  Fishing Vessels 

Tugs/ Oil Support Vessel 

Research/Survey Ship 
Dredger 

Other 

TOTAL 

Number of Ships 
11 
7 
5 
4 
7 
5 
2 

6 
6 
3 

1 

21 

4 
3 

2 
88228 

228 Tables .0.17 and 0.18 do not include the 2 Greek vessels still in service with a RfRC. 

124 

 
 
 
 
 
 
     0.18: A breakdown of reported vessels with a RFRC issued by ship size 

Size range 

Number of 
ships 

500GT to 1,000GT 
1,000GT to 2,000GT 
2,000GT to 3,000GT 
3,000GT to 4,000GT 
4,000GT to 5,000GT 
5,000GT to 10,000GT 
10,000GT to 50,000GT 
50,000GT to 100,000GT 
100,000GT to 150,000GT 
150,000GT to 200,000GT 
Over 200,000GT 
Unknown 
TOTAL 

4 
9 
14 
10 
4 
2 
4 
27 
10 
1 
1 
2 
88 

Finally, four Member States provided information on infringements of the SRR that they have 
pursued. This information, as reported by the Member States, can be found in Table 5 below. 
Among the reported cases, only four clearly relate to illegal ship recycling229. Due to the limited 
dataset, it is therefore difficult to gauge the level of enforcement of the Regulation based on 
this reporting only.   

     0.19: Infringements of Ship Recycling Regulation as reported by Member States as follows230: 

Country  Date 

Ship 

Issue 

Measures/Penalty 

1  Belgium 

2019 

ATLANTICO 
DUE  
IMO 
760629
3 

The ship flagged out 
without notifying the 
Belgian Flag State of 
their intent to recycle the 
vessel (15/02/2019). In 
this case they were 
headed to the recognized 
Belgian facility 
(GALLOO) 

They ship was required to re-flag 
and register the vessel back to 
follow the right procedure so we as 
Belgian flag State could issue a 
ready for recycling certificate. An 
official report was made by the 
Belgian Flag State. A fine was 
issued of 100.000 euro (10.000 euro 
to pay immediately and 90.000 euro 
if they make another breach of the 
SRR in 
the coming 3 years). 

229 Cases 6, 7 and 8 concern the control of inventory certificates or statement of compliance. Case 4 is not clear. 
230 References to personal data have however been removed. 

125 

 
 
 
 
 
Under Legislative Decree no. 99 of 
30/07/2020,  the  owner  has  been 
fined  a  total  of €  33,000.00  for  the 
violations  of  art.  6,  paragraph  n.  2, 
letter a) and lett. 
c) of the Regulations. 
It should be noted that the same 
owner was 
investigation in violation of other 
regulations,  including   those 
relating  to  Article  160  of  the 
Italian Navigation Code: 
(https://www.gazzettaufficiale.it/d 
ettaglio/codici/navigazione). 

under 

also 

in 

the 

that 

(Aliaga) 

The  Port  Authority  of  Naples, 
shipping 
ascertained 
company,  obtained 
the  required 
certifications,  after  the  ship  was 
delivered  the  unit  to  the  Isiksan 
in 
shipyard 
Izmir 
Türkiye.  The 
also 
confirmed that it did not receive any 
request or communication from  the 
Turkish  purchaser, nor 
the  shipowner  has  authorized,  or 
agreed, 
‘Asso 
transfer 
Ventuno’ to a different ship recycling 
facility. 

company 

the 

to 

2 

Italy 

Feb 
202
1 

DG Environment reported 
to the Directorate General 
that the shipowner had 
sold the ship, for its 
recycling, to a Turkish 
shipyard (Dortel Gemi 
Sokum) not included in 
the European list of 
recycling facilities. 

Necessary checks were 
initiated, with the Port 
Authority of Genoa, the 
competent body under Art. 
2, paragraph n. 1, letter c) 
of the Interministerial 
Decree 12/10/2017. 

JUMEIR
A (IMO 
7396769
) 
Purchased 
by  
‘Rimorchiato
ri Riuniti’ in 
2019, then 
transferred 
to ‘Ammat 
Marine 
limited’, 
based in 
Kalkara 
(Malta). On 
01/12/2020, 
it was resold 
to Mr. X 
domiciled 
Greece. 

3 

Italy 

2021  ASSO 

VENTU
NO 

On 18/02/2021 the ship 
was sold with contract 
for demolition, by the 
company Augusta 
Offshore S.p.A. (Naples, 
Italy), to the recycling 
facility Isiksan Gemi 
Sokum (Aliaga - Izmir 
Türkiye), enlisted in 
European List of ship 
recycling facilities. 
Subsequently, the NGO 
Shipbreaking Platform 
provided evidence that 
the ship was recycled in 
the Dortel Demi Sokum 
shipyard (not included in 
the aforementioned List). 
After investigation this 
was found to be true, 
despite 

126 

 
 
 
4  The 

Netherlands 

5 

Greece  

2019 

6 

Greece  

the fact that a ship 
recycling plan from the 
initial recycling yard 
Isiksan Gemi Sokum, 
had been passed to the 
Authorities by RINA. 
Dutch owned ship, under a 
different EU flag. 

Taxiaschis S,  
ΙΜΟ 6913340 

1.  The  vessel  was  recycled  in 
January  2019  on  the  22nd, 
carrying  the  Greek  Flag.  
The  vessel has been sent for 
recycling in the port facility 
named    ‘EGE  GEMI  SAN 
VE  TIC  S.A.’  in  Türkiye. 
The  said  facility  was  not 
included  in  the  European 
recycling 
List  of 
ship 
to 
facilities 
Regulation 
No 
1257/2013.  

pursuant 
(EU) 

M/V Rudolf 
IΜΟ:9535591 

2.  On  the  3rd  of  November 
2021 the carrying the flag of 
ANTIGUA and BARBUDA 
was  found  not  carrying  on 
board  a  valid  inventory  of 
hazardous  material  and  a 
statement  of  compliance 
issued  by  the  authorities  of 
the  country  whose  flag  is 
flying  according 
the 
provisions of Article 12.5 of 
No 
EU 
1257/2013 
Regulation .  

to 

No further information provided 

A monetary fine of 30000 EUROS 
has been imposed to the ship-owners 
for not complying with the 
requirements of Regulation (EU) No 
1257/2013 (in particular Article 6.2a 
thereof) for recycling the ship in a 
facility not included in the European 
list. 

A monetary fine of 10000 EUROS 
has been imposed. 

7  Belgium 

2021 

8  Belgium 

2021 

SCOT 
BREMEN 
(9260835) 

BASHT 
(9346536): 

3.  no 

inventory 

certificate 

(11/01/2021) 

4.  no statement of compliance 

(02/06/2021) 

Fine 2500 euro to pay immediate. 
7500 euro if the company makes 
another breach of the SRR in the 
coming 3 years 
Fine 2500 euro to pay immediate. 
7500 euro if the company makes 
another breach of the SRR in the 
coming 3 years. 

4. CONCLUSION 

Due  to  the  limited  dataset  resulting  from  the  first  tri-annual  reporting  period  and  its 
completeness,  no  conclusion  on  the  level  of  implementation  of  the  Regulation  and  its 
enforcement based on this first reporting exercise only.  For the next reporting period, further 
guidance will need to be provided to Member States to improve the completeness of the data.

127 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Appendix 1: List of vessels reported by Member States 

Flag 

BE 

IMO 
Number/Name 
7606293 
ATLANTICO DUE 

RFC Issued  Certificate 
Issued By 

29/05/2019  RINA Services 

S.p.A 

Survey 
Date 
29/05/2019  RINA 

Survey by  Company Recycling 
the Ship 
NV Galloo Recycling 
Ghent 

Services 
S.p.A 

Address of 
Company 
Scheepszatestraat 99000 
Gent Belgium 

SOC 
Received. 
19/12/2019 

BE 

CY 

CY 

CY 

CY 

CY 

CY 

CY 

7816288 
PANTAGRUELE 

8416906 
OSPREY 
EXLORER 
8824139 
WADDEN 4 

9161338 
HIGHLAND 
ROVER 
9166364 
SEA LEOPARD 
Tug 2990 

9166376 
SEA TIGER 
9171747 
SEA PANTHER 
Tug 1968 

9169677 
CHALLENGER 
Offshore Supply 
1968 

29/07/2020  RINA Services 

29/07/2020  RINA 

S.p.A 

Services 
S.p.A 

NV Galloo Recycling 
Ghent 

Scheepszatestraat 
99000 Gent Belgium 

05/05/2021 

07/05/2020  RINA Services 

S.p.A. 

NV Galloo Recycling 
Ghent 

Scheepszatestraat 
99000 Gent Belgium 

02/12/2021  Bureau Veritas 

DDR VESSELS XXI, S.L. Port of ‘El Musel’ Gijon 

16/07/2020  American 

Bureau  of 
Shipping 

26/05/2020  DNV GL AS 

Spain 

Isiksan Gemi Sokum 
Pazar-lama Ve Tic. Ltd. 
Sti. 
Green Yard AS 

Gemi Söküm 
Tesisleri, Parcel 22 
Aliağa 
Angholmen, 4485 Feda  15/02/2021 

15/02/2021 

28/10/2021  DNV AS 

Green Yard AS 

Angholmen, 4485 Feda  18/02/2021 

13/08/2021  DNV AS 

Green Yard AS 

Angholmen, 4485 Feda  19/02/2021 

18/09/2020  American 

Bureau  of 
Shipping 

Isiksan Gemi Sokum 
Pazar-lama Ve Tic. Ltd. 
Sti. 

Gemi Söküm 
Tesisleri, Parcel 22 
Aliağa 

02/04/2021 

128 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
CY 

CY 

CY 

CY 

DK 

DK 

DK 

DK 

18/09/2020  American 
Bureau of 
Shipping 
16/07/2020  American 

Bureau  of 
Shipping 

28/09/2020  American 
Bureau of 
Shipping 
29/10/2021  DNV AS 

9249441 
BUGLER 
1992 OSV 
9249491 
HIGHLAND 
COURAGE 
Tug 
9249506 
VALOR 

9392951 
SEA POLLOCK 
9146455 
STINE MÆRSK 

9100231 
NUKA ARCTICA 

9100229 
NAJA ARCTICA 

9227754 
OCEA
NIC 
PHOE
NIX 

Isiksan Gemi Sokum 
Pazar-lama Ve Tic. 
Ltd. Sti. 
Isiksan Gemi Sokum 
Pazar-lama Ve Tic. 
Ltd. Sti. 

Gemi Söküm 
Tesisleri, Parcel 
22 Aliağa 
Gemi Söküm 
Tesisleri, Parcel 22 
Aliağa 

Isiksan Gemi Sokum 
Pazar-lama Ve Tic. 
Ltd. Sti. 
Green Yard AS 

Gemi Söküm 
Tesisleri, Parcel 22 
Aliağa 
Angholmen, 4485 Feda 

Sök Denizcilik Tic. 
Ltd. Sti 

Jatob ApS Langerak 
12, 9900 
Frederikshavn 

Jatob ApS Langerak 
12, 9900 
Frederikshavn 

Smedegaarden A/S 
Vikingkaj 5, 6700 
Esbjerg 

Gemi Söküm Tesisleri, 
Parcel 8- 
9 Aliağa, Izmir 
35800, Türkiye 
Jatob ApS Langerak 
12,9900 
Frederikshavn 

Jatob ApS 
Langerak 12, 
9900 
Frederikshavn 
Smedegaarden A/S 
Vikingkaj 5, 
6700 Esbjerg 

Yes 

Recycling not yet 
completed. 

Yes 

RfRC not reported 
ahead of RFRC. 
and SOC has 
been 
reported 

129 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
DK 

DK 

DK 

DK 

DK 

DK 

DK 

DK 

ES 

1832186 
AARSLEFF 

7724540 
PAJUTTAAT 

9134531 
NORTHERN 
SEA 
9183609 
DAN EAGLE 

7432202 
HOLGER 
DANSKE 
9246736 
MÆRSK 
HELPER 
7704849 
NORDVÅG 

8316871 
NIELS PAULI 

8611180 
DRAVO 
COSTA 
DORADA 

24/03/2021  S.G. de 

24.03.2021 

Seguridad, 
Contaminación e 
Inspección 
Marítima 

130 

Jatob ApS  
Langerak 12, 9900 
Frederikshavn 

Jatob ApS  
Langerak 12, 9900 
Frederikshavn 

Jatob ApS  
Langerak 12,  
9900 Frederikshavn 

Jatob ApS 
Langerak 12, 9900 
Frederikshavn 

Smedegaarden A/S 
Vikingkaj 5, 6700 
Esbjerg 
Gemi Sokum Tesisleri 
Parsel 25 
Aliaga, Izmir 35800, 
Türkiye 

Smedegaarden A/S 
Vikingkaj 5, 
6700 Esbjerg 
Gemi Sokum Tesisleri 
Parsel 25 Aliaga, Izmir 
35800, Türkiye 

Fornæs Ship 
Recycling 

Fornæs Ship 
Recycling 

Rolshøjvej 12, 
8500 Grenaa 

Rolshøjvej 12, 
8500 Grenaa 

Fornæs Ship 
Recycling 
Rolshøjvej 12, 
8500 Grenaa 
Smedegaarden A/S 
Vikingkaj 5, 
6700 Esbjerg 

Fornæs Ship 
Recycling Rolshøjvej 
12, 8500 Grenaa 

Smedegaarden A/S 
Vikingkaj 5, 6700 
Esbjerg 
DDR VESSELS XXI, 
S.L. 
AAI106/14 

Yes 

Recycling not yet 
completed. 

Yes 

RfRC not received 
ahead of 
recycling. Only the 
SOC has been 
reported 
Yes 

Recycling 
not yet completed. 

Yes 

Recycling not yet 
completed. 

19.11.2021 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
EL 

EL 

EL 

EL 

EL 

EL 

EL 

EL 

8813130 
EKO 3 

18/06/2019 

Hellenic 
Lloyds 

8813142 
EKO 4 

09/10/2019 

Hellenic 
Lloyds 

8820121 
EKO 5 

09/10/2019 

Hellenic 
Lloyds 

7521651 
EXPRESS 
PEGASUS 

22/10/2021 

Hellenic 
Lloyds 

9934890 
IRINI 

9401075 
MELINA 

9650054 
MARAN GAS 
ALEXANDRIA 

9724075 
ELIA TSAKOS 

05/07/2021 

11/03/2020 

Hellenic 
Lloyds 

Hellenic 
Lloyds 

17/12/2020  ABS 

08/08/2020  Lloyd’s 

Register 

LEYAL-DEMTAŞ 
GEMİ SÖKÜM 
SANAYİ ve 
TİCARET A.Ş 

ISIKSAN GEMİ 
SÖKÜM 
PAZARLAMA VE 
TİCARET 
LTD.STİ. 

ISIKSAN GEMİ 
SÖKÜM 
PAZARLAMA VE 
TİCARET 
LTD.STİ. 

SIMSEKLER GIDA 
GEMI SOKUM 
INSAAT SANAYI 
VE TICARET 
LTD.STI. 
LEYAL-DEMTAS 
GEMI SOKUM 
SAN VE TIC A.S. 

LEYAL-DEMTAS 
GEMI SOKUM 
SAN VE TIC A.S. 

Gemi Söküm Tesisleri 
Parcel 3-4 Aliaga, Izmir 
35800 TURKEY 

Gemi Söküm Tesisleri 
Parsel No : 22 
Aliaga – Izmir / TURKEY 
, Post code: 35800 

Gemi Söküm Tesisleri 
Parsel No : 22 
Aliaga – Izmir / TURKEY 
, Post code: 35800 

Ataturk Mah. Aygaz 
Cad., No:41 Gemi 
Sökum Bolgesi, 35800 
Aliaga, Izmir, TURKEY 

Gemi Söküm Tesisleri, 
Parcel 25 Aliaga, Izmir 
35800, Turkey 

Gemi Söküm Tesisleri, 
Parcel 25 Aliaga, Izmir 
35800, Turkey 

131 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
IT 

IT 

IT 

IT 

IT 

IT 

MT 

MT 

HR 

8351118 
LUBERNICE 

15.12.21 

Croatian 
Register of 
Shipping 

Isikan Ship 
Recycling Facility 

1/6/22 

7018422 
MAR GRANDE 

04/05/2021  RINA Services 

S.p.A 

San Giorgio del Porto 
S.p.A. 

Calata Boccardo 8 
16128 — Genova 

28/10/2021 

9030864 
SPES 

11/08/2020  RINA Services 

S.p.A 

ÖGE GEM? SÖKÜM 
ITH. IHR. TIC. SAN.A?. 

9109031 
ST VICTORIA 

01/12/2020  RINA Services 

S.p.A 

EGE CELIK SAN. VE 
TIC. A.S 

21/01/2021 

16/02/2022 

Gemi Söküm 
Tesisleri, Parcel 23 
Alia?a, Izmir 
35800, 
Gemi Söküm 
Tesisleri, Parcel 23 
Alia?a, Izmir 
35800, 
Türkiye 

9183192 
ASSO 
VENTURO 
9435466 
NORMAN 
ATLANTIC 

9504645 
MARMED 

7393822 
ASSO ZEJT 1 

9074389 
APL CHINA 

09/02/2021  RINA Services 

Sanctions 

S.p.A 

25/06/2019  RINA Services 

S.p.A 

03/01/2021  RINA Services 

S.p.A 

LEYAL GEMI SÖKÜM 
SANAYI ve TICARET 
LTD 

Gemi Söküm Tesisleri, 
Parcel 3- 
4 Alia?a, 

11/11/2019 

ISIKAN GEMI 
SOKUM 
PAZARLAMA VE 
TIC. LTD STI, 
TÜRKIYE 
LEYAL GEMI 
SOKUM SANAYI ve 
TICARET Ltd,. 
ALIAGA TÜRKIYE 

132 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
MT 

MT 

MT 

MT 

MT 

MT 

9030852 
FIDES 

8512281 
SOVEREIGN 
8819500 
MONARCH 

8027298 
MARELLA 
CELEBRATION 
8807088 
HORIZON 

9131515 
EUROCAR
GO 
TRIESTE 

MT 

84077435 

MAREL
LA 
DREAM 

LEYAL GEMI 
SOKUM SANAYI ve 
TICARET Ltd,. 
ALIAGA TÜRKIYE 
EGE CELIK SAN. 
Ve Tic A.S 
SOK  DENIZCILIK 
VE  TIKARET  LTS 
SIKETI, ALIAGA, 
IZMIR, TÜRKIYE 
ISIKSAN Gemi 
Sokum, TÜRKIYE 

ISIKAN GEMI 
SOKUM 
PAZARLAMA VE 
TIC. LTD STI, 
TÜRKIYE 
LEYAL GEMI 
SOKUM SANAYI ve 
TICARET Ltd,. 
ALIAGA TÜRKIYE, 
OGE GEMI SOKUM 
ITHALAT IHRACAT 
TICARET ve SANAYI 
AS & LEYAL 
DEMTAS GEMI 
SOKUM SANAYI ve 
TICARET AS 

ISIKAN GEMI 
SOKUM 
PAZARLAMA VE 
TIC. LTD STI, 
TÜRKIYE 

133 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
MT 

MT 

MT 

MT 

MT 

MT 

MT 

7616779 
CALAMITY 
JANE 

9112143 
B GAS 
CHAMPI
ON 
9112155 
B GAS 
COMMAND
ER 

8008450 
CSL RHINE 

8107062 
GSP VEGA 

9083158 
GSP PHEONIX 

9131527 
EUROCAR
GO 
PATRASSO 

LEYAL DEMTAS 
GEMI SOKUM San 
Ve Tic. S.A 
Gemi Söküm Bölgesi 
Nolu Parsel 25, 
Aliağa 35800 – 
İzmir – Türkiye 

GEMI SOKUM 
ITHALAT IHRACAT 
TICARET ve SANAYI 
AS & LEYAL 
DEMATAS GEMI 
SOKUM SANAYI ve 
TICARET AS 

SOK  DENIZCILIK 
VE  TIKARET  LTS 
SIKETI, ALIAGA, 
IZMIR, TÜRKIYE 
ISIKAN GEMI 
SOKUM 
PAZARLAMA VE 
TIC. LTD STI, 
TÜRKIYE 
ISIKAN GEMI 
SOKUM 
PAZARLAMA VE 
TIC. LTD STI, 
TÜRKIYE 
Oge Semi Sokum, 
Ticaret ve Sanayi 
A.S 

134 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
ISIKAN GEMI 
SOKUM 
PAZARLAMA VE 
TIC. LTD STI, 
TÜRKIYE 
LEYAL Gemi Sokum 
San. ve Tic. Ltd 

MT 

MT 

MT 

MT 

MT 

MT 

MT 

MT 

9083172 
GSP LICORN 

8405892 
AMT 
EXPLORER 
9125372 
CELESTINE 

RORO 23986 
9166625 
VALENTIN
E RORO 
23987 
9425124 
IOLCOS 
PRIDE BULK 
47984 
9489560 
BOMAR 
VESTA 
CHEMICAL 
4365 
9776432 
CMA CGM 
LOUIS 
BLERIOT 
CONTAINER 
219277 
9835795 
MALYOVISTA 
BULK 29076 

02/06/2021  DNV AS 

03/01/2020  DNV GL AS 

25/03/2021 

Lloyd's 
Register 

05/02/2021  RINA Services 

S.p.A 

23/06/2021  Bureau Veritas 

30/06/2020  DNV AS 

135 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
NL 

JAN STEEN 

Galloo Gent 

Scheepssloperij 
Nederland B.V. 

Scheepssloperij 
Nederland B.V. 

Scheepssloperij 
Nederland B.V. 

DECOM Amsterdam 
B.V. 

DDR VESSELS XXI, 
S.L. 

Scheepzatestrat 9 
Kaainummers 750-790 
9000 Gent – 
Belgium 
Havenweg 1 
3295 XZ 's- 
Gravendeel 
The Netherlands 
Havenweg 1 
3295 XZ 's- 
Gravendeel 
The Netherlands 
Havenweg 1 
3295 XZ 's- 
Gravendeel 
The Netherlands 

Siciliëweg 10 
1045 AS 
Amsterdam 
1ª alineación Muelle de 
Ribera Rincón de 
Langre, 33212 Gijón, 
Asturias, Spain 

ISIKSAN GEMI 
SOKUM 
PAZARLAMA VE 
TICARET LTD STI 
Gemi Söküm 
Tesisleri 

Gemi Sökum 
Tesisleri, Parcel 22 
Aligia Izmir 
35800, Türkiye 
Parcel 3-4 Aliaga, Izmir, 
TÜRKIYE 

NL 

VOS POWER 

NL 

NL 

NL 

VOS 
PRODUC
ER 

VOS 
PROMINENCE 

SLIEDRECHT 
26 

NL 

ESPERANZA 

NL 

GEOPOTES 15   

SE 

8705383 
SASSNITZ 
RFRC 

EFTA Countries 

14/10/2021  RINA 

12/10/2021  RINA 

SERVICES 
S.p.A 

SERVICE
S S.p.A. 

136 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
NO 

NO 

NO 

NO 

NO 

NO 

NO 

NO 

NO 

NO 

NO 

NO 

8309830 
STAR FUJI 
9431848 
HÖEGH 
XIAMEN 
8750833 
DEEPSEA 
BERGEN 

7431698 
IDUNA 
9204752 
NAVION 
ANGLIA 
9209130 
NAVION OSLO 
9172870 
BETTY 
KNUTSEN 

9186675 
FAR 
SOVEREIGN 

9121053 
NORMAND 
NEPTUN 

9155054 
NORMAND 
ATLANTIC 

9229477 
NORMAND 
BORG 

9190298 
POLAR 
MARQUIS 

08/08/2019 

03/10/2020 

04/12/2020 

08/03/2021 

10/03/2021 

27/04/2021 

06/07/2021 

09/11/2021 

30/11/2021 

30/11/2021 

30/11/2021 

07/12/2021 

Leyal / Leyal Demtaş  Aliaga / Türkiye 

Leyal 

Aliaga / Türkiye 

ISIKSAN 

Aliaga / Türkiye 

FORNAES 

Denmark 

Leyal 

OGE 

Leyal 

Aliaga / Türkiye 

Aliaga / Türkiye 

Aliaga / Türkiye 

Green Yard AS - 
Norway 

Norway 

Green Yard Kleven 
AS - Norway 

Norway 

Green Yard Kleven 
AS - Norway 

Norway 

Green Yard Kleven 
AS – Norway 

Norway 

Simsekler 

Aliaga / Türkiye 

137 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
NO 

NO 

NO 

NO 

NO 

9194115 
OCEANIC 
CHALLENGER 
8420799 
STAR GRAN 

21/12/2021 

19/02/2019 

8420787 
STAR GRIP 

26/02/2021 

7369027 
TERNESKJAER 

10/06/2021 

9216389 
VINLAND 

07/07/2020 

Simsekler 
Leyal Demtas Gemi 
Sokum San. Ve Tic. 
AS 
Leyal Demtas Gemi 
Sokum San. Ve Tic. 
AS 
Smedegaarden A/S – 
CVR No. 
36024992 
Leyal Demtas Ship 
Recycling Yard 

Aliaga / Türkiye 

Izmir, Türkiye 

Izmir, Türkiye 

Esbjerg, 
DENMARK 

Aliaga, Türkiye. 

138 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Appendix 2: List of ships found in MARINFO as having been recycled and not part of the reporting by the Member States  

FLAG AT 
SCRAP 

IMO 
NOS 

SHIP 
NAME 

SCRAP 
DATE 

SCRAP 
YEAR 

EST. 
LDT 

GT 

SHIP TYPE 
IHS 

Belgium 

8515520 

ORWELL 

9/10/2020 

2020 

2468  2598 

Belgium 

8638932 

ADRIATICO 

2/1/2021 

2021 

627 

840 

Bulgaria 

7911052 

NORVARG 

11/9/2021 

2021 

828 

1085 

Cyprus 

8422723 

ODIN R 

4/1/2020 

2020 

2440  2081 

Cyprus 

8915782  MUNIN 

8/1/2019 

2019 

1405  2387 

Denmark 

5100477 

Denmark 

7516876 

Denmark 

7921007 

Denmark 

8510972 

Denmark 

8516990 

Denmark 

8521531 

EXPLORER 
ELBJORN 

SABLE 
EXPRESS 
BLUE ALFA 

GRETHE 
HVIID 
SC NORDIC 

SHELF 
EXPRESS 

1/1/2020 

2020 

5/29/2021 

2021 

1875  2341 

4/1/2021 

2021 

1875  1887 

12/18/2020 

2020 

537 

630 

4/13/2021 

2021 

1566  4876 

4/1/2021 

2021 

1164  1423 

Trailing Suction 
Hopper Dredger 
Bucket Ladder 
Dredger 
Products Tanker 

Cutter Suction 
Dredger 
Research Survey 
Vessel 
Restaurant Vessel, 
Stationary 
Platform Supply 
Ship 
Anchor Handling 
Tug Supply 
Fishing Vessel 

Palletised Cargo 
Ship 
Platform Supply 
Ship 

PLACE  OF 
BREAKIN 
G 

SHIP BREAKER 

COUNTRY 

Gijon 

Ddr Vessels Xxi Sl Spain 

Ghent 

Aliaga 

Grenaa 

Van Heyghen 
Recycling 
Ersay Gemi 
Geri Donusum 
As 
Fornaes Aps 

Belgium 

Türkiye 

Denmark 

Esbjerg 

Smedegaarden  Denmark 

Denmark  

Jatob ApS 

Denmark 

Denmark 

Denmark 

Grenaa 

Fornaes Aps 

Denmark 

Denmark 

Denmark 

139 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Denmark 

9198044 

Estonia 

7362524 

ESVAGT 
CONNECTOR 
FOREST 
COSTA RICA 

France 
France 
France 

4546844  MALABAR 
4546856 
7704552 

TENACE 
VLAANDEREN 
XIX 
KURA ORA II 

France 

7813391 

11/4/2020 

2020 

1671 

1890 

8/1/2021 

2021 

0 

1403 

2/13/2021 
1/27/2021 
7/12/2021 

2021 
2021 
2021 

464 
464 
2468 

896 
896 
2970 

1/11/2019 

2019 

1566 

1113 

France 

7912745 

France 

9075589 

HALTEN 
BANK II 
CORSAIRE 

4/2/2021 

2021 

537 

791 

1/1/2020 

2020 

694 

851 

Germany 

8986896 

BREDSTEDT 

12/31/2021 

2021 

547 

784 

Greece 

6517005 

ANASTASIA III  8/27/2020 

2020 

782 

1286 

Greece 

7517533 

TZOANNA VI 

2/10/2021 

2021 

968 

977 

Anchor Handling 
Tug Supply 
Fishing Vessel 

Tug 
Tug 
Cutter Suction 
Dredger 
General Cargo 
Ship 
Fishing Vessel 

Passenger/Ro-Ro 
Ship (Vehicles) 
Patrol Vessel 

General Cargo 
Ship 
General Cargo 
Ship 

Grenaa 

Fornaes Aps 

Denmark 

Ghent 

Van Heyghen 
Recycling 
Unknown  Unknown 

Belgium 

France 
France 
Belgium 

Belgium 

Frederik 
shavn 

Aliaga 

Jatob Aps, 
Handelsselskab 
et 
Bereket Gemi 
Sokum Ltd Sti 

Denmark 

Türkiye 

Unknown  Unknown 

Türkiye 

Greece 

9249104 

Latvia 
Latvia 

8721765 
8846694 

ELKA 
VASSILIKI 
SOLVITA 
INTA 

6/5/2021 

2021 

4/17/2021 
5/24/2020 

2021 
2020 

1784 
3 
806 
0 

55096  Chemical/Products 
Tanker 
Fishing Vessel 
Bunkering Tanker  Liepaja 

734 
718 

Malta 

9004217 

PURKI 

2/22/2020 

2020 

4950 

10396  Container Ship 
(Fully Cellular) 

Alang 

140 

Türkiye 

Pakistan 

Latvia 
Latvia 

India 

Unknown 
Shipbreakers, 
Latvia 
Leela Ship 
Recycling Pvt 
Ltd 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
The 
Netherlands 

8414790 

GEOPOTES 
15 

7/18/2020 

2020 

7319 

10188 

Trailing Suction 
Hopper Dredger 

Aliaga 

The 
Netherlands 

8639728 

TRITON 

1/28/2019 

2019 

627 

662 

Cutter Suction 
Dredger 

's- Gravend 
eel 

Unknown 
Shipbreakers, 
Türkiye 
Scheepssloperij 
Nederland Bv 

Netherlands 

8863745 

Romania 

8767630 

STEMAT 
SCRADEWAY 
GLORIA 

1/11/2019 

2019 

5/1/2019 

2019 

Spain 
Spain 

6506329 
8619704 

NAUMON 
CHILREU 

3/4/2021 
11/29/2019 

2021 
2019 

1160 
6 
1160 
6 

1954 
1077 

Sweden 

8705383 

SASSNITZ 

10/20/2021 

2021 

9805 

EFTA Countries 

2054 

8763 

Pontoon (Function 
Unknown) 
Drilling Rig, jack up  Romani a 

Netherla nds  Scheepssloperij 

1057 
1316 

Theatre Vessel 
Fishery Patrol 
Vessel 
21154  Passenger/Ro-Ro 

Gijon 

Aliaga 

Ship 
(Vehicles/Rail) 

Iceland 

6721216 

STURLA 

12/5/2020 

2020 

537 

672 

Fishing Vessel 

Klaipeda 

Iceland 

6828923 

SNAEFELL 

9/25/2019 

2019 

2481 

1319 

Fishing Vessel 

Ghent 

Iceland 

7607065 

HJALTEYRIN 

9/25/2019 

2019 

537 

658 

Fishing Vessel 

Ghent 

Iceland 
Norway 

8003993  MARS 
ISELIN 
5051224 

6/8/2021 
1/1/2019 

2021 
2019 

537 
481 

716 
542 

Norway 

7207463 

SIGMA 

1/1/2020 

2020 

1954 

1467 

Norway 

7303267 

HERLAUG 

6/29/2020 

2020 

694 

737 

Fishing Vessel 
General Cargo 
Ship 
Research Survey 
Vessel 
Passenger/Ro-Ro 
Ship (Vehicles) 

Stokksund 

Hanoyta 
ngen 
Stokksund 

141 

Türkiye 

Netherlands 

Netherlands 

Nederland Bv 
Gsp Offshore 

Romania 

Spain 
Ddr Vessels Xxi Sl Spain 

Leyal Gemi 
Sokum Ltd Sti 

Türkiye 

Unknown 
Shipbreakers, 
Lithuani 
Van Heyghen 
Recycling 
Van Heyghen 
Recycling 

Fosen 
Gjenvinning As 
Norscrap West 
As 
Fosen 
Gjenvinning As 

Lithuania 

Belgium 

Belgium 

Belgium 
Norway 

Norway 

Norway 

 
 
 
 
 
 
 
Norway 

7369027 

Norway 

7412020 

Norway 

7508881 

Norway 
Norway 

7705116 
7712951 

TERNESKJAE 
R 
EIDE 
FIGHTER 
EIDE 
TRAVELER 
BIOTRANS 
NORDMORE 

6/8/2021 

2021 

481 

882 

8/1/2021 

2021 

1875 

1388 

5/21/2021 

2021 

1875 

1389 

4/1/2021 
11/18/2021 

2021 
2021 

537 
1584 

797 
1105 

Norway 

7728508 

FRAFJORD 

9/28/2020 

2020 

522 

739 

Norway 

7805124 

VETNE 

10/1/2020 

2020 

1584 

1660 

Norway 

8211899 

ANDAL 

4/27/2019 

2019 

1114 

Norway 

8412261  MELDERSKIN 

6/29/2020 

2020 

1584 

1974 

Norway 

8510673 

VENTURER 

4/7/2019 

2019 

2795 

3935 

Norway 

8714281 

SKJERVOEYF 
ISK 

7/1/2019 

2019 

537 

579 

General Cargo 
Ship 
Anchor Handling 
Tug Supply 
Anchor Handling 
Tug Supply 
Fishing Vessel 
Passenger/Ro-Ro 
Ship (Vehicles) 
Passenger/Ro-Ro 
Ship (Vehicles) 
Passenger/Ro-Ro 
Ship (Vehicles) 
Passenger/Ro-Ro 
Ship (Vehicles) 
Passenger/Ro-Ro 
Ship (Vehicles) 
Research Survey 
Vessel 
Fishing Vessel 

Denmark 

Denmark 

Denmark 

Norway 
Norway 

Norway 

Stokksu nd  Fosen 

Unknow n 

Gjenvinning As 
Unknown 

Esbjerg 

Smedegaarden  Denmark 

Norway 

Hanoyta 
ngen 
Aliaga 

Fosen 
Gjenvinning As 
Norscrap West 
As 
Ege Celik Gemi 
Sokum As 

Norway 

Norway 

Türkiye 

Eydeha vn  Norsk 

Norway 

Norway 

9043081  WOLVERINE 

7/18/2020 

2020 

6950 

Norway 

9183867 

Norway 

9190298 

GEOWAVE 
COMMANDER 
SW MARQUIS 

8/1/2020 

2020 

5002 

11/11/2019 

2019 

8867 

11360  Chemical/Products 
Tanker 

USA 

5631 

Research Survey 
Vessel 
13339  Research Survey 
Vessel 

Aliaga 

142 

Skipsbrukt As 
ISL 

Green Yard As 

Simsekler Gida 
Gemi Sokum 
Sti 

United 
States Of 
America 

Türkiye 

 
 
 
 
 
 
 
 
 
 
 
 
 
ANNEX X MAIN DIFFERENCES BETWEEN THE SRR AND THE HKC 

The documents used in the comparison exercise231 are the following:  
The Hong Kong Convention and the following IMO guidelines:  

-  MEPC.211(63) Guidelines for the authorisation of ship recycling facilities 
-  MEPC.196(62) Guidelines for the Development of the Ship Recycling Plan 
-  MEPC.210(63) Guidelines for Safe and Environmentally Sound Ship Recycling 

Regulation (EU) No 1257/2013, as amended by Decision (EU) 2018/853 and Regulation (EU) 2024/1157 
and implemented by Commission Implementing Decision (EU) 2016/2325 on the format of the certificate 
on the inventory of hazardous materials, Commission Implementing Decision (EU) 2016/2321 on the 
format of the ready for recycling certificate, Commission Implementing Decision (EU) 2016/2324 on the 
format of the report of planned start of ship recycling, Commission Implementing Decision (EU) 
2016/2322 on the format of the statement of completion of ship recycling and Commission Implementing 
Decision (EU) 2015/2398 on information and documentation related to an application for a facility 
located in a third country for inclusion in the European List of ship recycling facilities.  It also covers the 
Communication from the Commission — Requirements and procedure for inclusion of facilities located 
in third countries in the European List of ship recycling facilities — Technical guidance note under 
Regulation (EU) No 1257/2013 on ship recycling.  A reference is also made to the Directive (EU) 
2024/1203 on the protection of the environment through criminal law. 

Target 
group  

All 

HKC 

SRR 

Differences 

Art 3 
Art 6 
Reg 17 

Art 2,  
15 
(recital 
9) 

Application/scope  
The SRR defines its scope by reference to EU-flagged vessels. Only 
with respect to the obligation to hold an IHM onboard, the scope also 
includes  ships  flying  the  flag  of  a  third  country  calling  at  a  port  or 
anchorage of a MS. The SRR is applicable to EU SRFs, but also to 
third countries SRFs if they apply for inclusion in the European List. 
The HKC applies to ships flying the flag of a Party and SRFs operating 
under its jurisdiction. For ships flying a non-Party flag, Parties shall 
apply the HKC as may be necessary to ensure that no more favourable 
treatment  is  given  to  such  ships  when  recycled.  This  is  a  clearer 
obligation to apply the same requirements for dismantling non-parties 
ships than in the SRR On the other hand it is not clear to what extent 
Parties  to  the  HKC  will  decide  to  require  an  IHM  from  non-parties 
flag, in application of the ‘no-more favourable’ clause.  

Art 5 

Art 8 

Art 8, 
9, 10 

Art 11 
Art 12 

Hazardous materials and inspection of ships 
- For ships flying the flag of a Party under the HKC and a Member 
state  under  the  SRR,  identical  regimes  for  survey,  certification  and 
inspection apply identical but they are parallel. 
-Under  the  SRR,  non-EU-flagged  ships  visiting  an  EU  port  may  be 
subject  to  an  inspection  to  check  the  validity  of  the  statement  of 

Port 
states, 
flag 
states, 
shipown
ers 

231 Elaboration based on input provided under a contract with DNV AS. 

143 

 
 
 
  
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Appen
dix 1, 
2  

Annex 
1, 2 

Art 9 

Art 11, 
Art 12 

Art 13, 
Art 14, 
Art 15,  
Art 16, 
Art 22, 
Art 23 

Art 4, 
Art 6,  
Reg 
15, 
Reg 
16, 
Art 9, 
Reg 17 

Recycli
ng 
States, 
SRFs, 
COM 

compliance (IHM certificate) which is required under the SRR. Under 
the HKC there is no such an obligation to require an IHM for vessels 
flying the flag of a non-party. 
-Annex I of the on control of hazardous materials incudes PFOS but 
not the Appendix I of HKC.  Annex II of the SRR on the minimum 
List  of  Items  for  the  Inventory  of  Hazardous  Materials  includes  15 
hazardous  materials.    The  HKC  Appendix  2  lists  13  materials.  The 
SRR includes Brominated Flame Retardants (HBCDD) and PFOS (as 
part of Appendix I) but not the HKC. 
-See also below ‘Certificates and reporting forms.’ 
-Under  the  HKC,  any  Party  with  some  evidence  of  violation  or 
intention to violate can ask another Party to investigate when a ship is 
calling its port. The party must report back about action to the Party 
that requested the investigation, to the flag state and to IMO. Though 
slightly different, it can be considered the mechanisms under Port State 
Control  Directive  allow  similar  action  and  communication  between 
authorities. 

Authorisation and controls of ship recycling facilities 
-Authorisation  from  competent  local  authorities  to  conduct  ship 
recycling  is  required  both  under  the  HKC  and  the  SRR.  The  SRR 
includes  however additional requirements  (see below).    In  the  HKC 
there is a form for the ‘authorisation of ship recycling facilities’, while 
there is no dedicated template in the SRR. 
- Under the HKC, parties should provide upon request of IMO or other 
parties, information on which its decision for SRF authorization was 
based. There is no similar provision under EU SRR.  However, COM 
makes publicly available all compliance assessment reports related to 
decision for listing third countries facilities and publish draft decisions 
for  updates  of  the  European  List  for  public  feedback,  as  part  of  its 
decision-making process. 
-The  HKC  requires  the  parties  to  identify  the  terms  for  which  the 
authorization  will  be  issued,  withdrawn,  suspended,  amended  and 
renewed. The SRR indicates that any non-compliance with Art.13 shall 
lead to withdrawal, suspension or corrective actions of SRFs located 
in  MS  and  the  Commission  should  be  informed  about  it.  If  their 
country facilities on the European List cease to comply with EU SRR 
requirements, the SRR only provide for the removal from the European 
List. 
- The HKC has a specific provision related to the obligation to establish 
mechanism for inspection, monitoring and enforcement for SRFs. If 
audits  are  carried  out  under  the  HKC,  the  results  should  be 
communicated to IMO.  There is not such a provision under the SRR 
applying to MS; only a general provision on enforcement. However, 
SRFs in third countries before and after inclusion in the European List, 
are  subject  to  specific  compliance  assessment  and  monitoring  by 
independent  verifiers  and/or  the  Commission  (in  additional  to  any 
national measure). 
-  Under the  HKC,  another  Party  with  evidence  may request  another 
party to investigate alleged violation by a SRF under its jurisdiction. 
Report of such investigation is to be sent to the Party requesting it and 

144 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Art 13 
Art 15 
EC 
TGN 

Reg 3, 
Reg 17 
Reg 19 
Reg 20 
Reg  
21 
Reg 22 
MEPC
.210(6
3) 

SRFs, 
downstr
eam 
waste 
manage
ment 
facilities 

to IMO.  Under the SRR, there is a general duty of cooperation among 
MS and, in addition, any third party affected may request action from 
the Commission with respect to a breach of the SRR by a third country 
SRF. There are no specific provisions concerning SRF located in  MS. 

Standards for Safe and environmentally sound management 
-  Under  the  SRR,  environmentally  sound  management  may  only  be 
assumed to be in place for  waste recovery and disposal concerned 
provided the SRF located in third countries can demonstrate operations 
in  accordance  with  human  health  and  environmental  protection 
standards that are broadly equivalent to relevant international and EU 
standards. 
-The SRR explicitly requires monitoring systems. Under HKC it is 
implicit in having an effective management system that monitoring is 
performed with nevertheless guidance for monitoring provided under 
MEPC.210(63). On environmental monitoring, the EU Technical note 
goes  beyond  and  suggests  e.g.  additional  monitoring  of  high 
temperatures. 
-Specific  guidance  on  control  of  leakage  is  included  in  MEPC 
Guideline but the HKC does not include the specific requirement of 
the  SRR  related  to  demonstration  of  control  of  any  leakage 
(complemented by its Technical Guidance Note (EC TGN) explaining 
how  to  prevent adverse  effects  on  the environment from ‘hazardous 
materials’  as  well  as  ‘waste  generated  during  the  ship  recycling 
process’)  and  of  their  handling  ‘only  on  impermeable  floors  with 
effective drainage systems. 
- The requirement to operate on built structures as included in the 
SRR (+ EC TGN) is not included in the HKC.   
- Regarding the removal of hazardous waste, the SRR does include the 
specific  requirement  of  documenting  the  quantities  of  removed 
hazardous  waste  and  the  identification  and  handling  of  additional 
hazardous materials that may be part of the structure of the ship. The 
EU  SRR  also  requires  evidence  of  competence  for  the  personnel 
authorized to carry out removal of hazardous materials in facilities in 
third countries. 
- The IMO guidelines reference the same ILO and Basel Convention 
guidelines, but the EU Technical note goes beyond in some aspects by 
suggesting  how  to  apply  environmentally  sound  management 
principles  (‘transfer  of  elements  from  the  ship  to  the  facility’s 
impermeable floor is done without the elements coming in contact with 
the sea, the intertidal zone or any other permeable surface such as sand 
or gravel’). EC TGN  also suggests some specific technical measures 
to control, respond and mitigate on  adverse effects on the environment 
(‘prior  assessment  of  pollutants  remaining  on  board  the  ship;  rapid-
response  teams;  oil  absorption  booms;  oil  containment  booms; 
drainage  canals  and  impermeable  floors’)  ;  on  containment  of 
hazardous  materials,  it  describes  measures  to  be  taken  when  risks 
related to exposure to asbestos at work and  on elevated tanks to store 
oily residues.  

145 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Reg 8, 
Reg 17 

Art 6 

Reg 9 

Art 7, 
Art 17 

All 

-The  HKC  describes more  detailed requirements for the  emergency 
preparedness and response plan (i.e. the plan shall ensure that the 
necessary  equipment  and  procedures  are 
in  place,  necessary 
information and internal communication and training (including drills) 
but  EU  SRR  goes  beyond  HKC  when  requiring  rapid  access  for 
emergency  response.    However,  both  HKC  and  EU  SRR  make 
reference  to  the  Basel  Convention,  Technical  Guidelines  for  the 
Environmentally  Sound  Management  of 
the  Full  and  Partial 
Dismantling  of  Ships  (BC  TG)  where  immediate  first  aid  and  rapid 
additional medical care from medical personnel is described. 
- For EU SRR, EC TGN also suggests that the current layout of the 
recycling facility is reflected in the plan and that workers, including 
contractor personnel and employees hired for a short period of time is 
informed about the plan. 
- The Stockholm Convention on Persistent Organic Pollutants is not 
referenced in the HKC. 

Preparation for ship recycling 
General: 
- Under EU SRR the obligations are for the shipowners (of EU-
flagged ships) whereas under HKC the obligations are on all ships 
intended to be recycled in a facility located in a party.  
- The HKC requires a ship to use a SRF authorized in accordance 
with the Convention, while the EU SRR requires end-of-life ships to 
be dismantled in a facility on the European List (i.e. compliant with 
EU requirements) and applies an export ban to non OECD countries 
if these vessels became waste in the national jurisdiction of 
a Member State. 
- Under EU SRR shipowners retain responsibility in case the operator 
of the SRF declines to accept the ship for recycling if the condition of 
the ship does not correspond substantially with the particulars of the 
IHM. 
- Shipowners are required to prepare similar Ready for Recycling 
Certificates under the HKC as under the EU SRR but (potentially) 
issued for different regimes.  
- In the case of a tanker, HKC stipulates that it should arrive at the 
SRF with cargo tanks and pump room(s) in a condition that is ready 
for certification as Safe-for-entry, or Safe-for-hot work, or both, 
according to national laws while the EU SRR does not refer to ‘safe-
for-entry’ and applicable laws.  

Ship recycling plan 
- The EU SRR is more detailed in its description of requirements for 
the ship recycling plan, namely on ship-specific considerations or 
special procedures (if not included in SRFP), consistency with IHM, 
information about preparatory work location, about where the ship 
will be placed during recycling operations, concise plan for the 
arrival and safe placement of the specific ship to be recycled, 
reminding of taking into account structure, configuration and 
previous cargo when monitoring safe recycling , storage of hazardous 
waste and waste. 

146 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Art 9, 
Art 10, 
Art 12, 
Art 13 

Reg 
11, 
Reg 
14, 
Appen
dix 3, 
4, 5, 6, 
7 

Art 10 

Art 
22, 
Art 15 
ECD 

Reg 
23, 24, 
25, 
Art 12 

Art 6,  
Art 7,  
Art 13, 
Art 14, 
Art 21 

-HKC defines a 14-day review period for tacit approval of the SRP, 
while the EU SRR points to national regulations for the duration of 
review period. 
Certificates and reporting forms 
- The EU SRR requires the ‘Certificate on inventory of hazardous 
materials’ for EU-flagged ships following model adopted under 
Decision 2016/2325 and consistent with  Appendix 3 to HKC.  A 
‘statement of compliance’ is the equivalent document requested for 
non-EU-flagged ships calling at EU ports) that may be modelled on 
Appendix 3 to HKC (model proposed by EMSA). If the models set 
by HKC and EU SRR are similar, they refer to different legal 
frameworks (EU or HKC) and the list of hazardous materials to be 
included in the IHM required under the EU SRR contains two more 
materials. Therefore, an IHM certificate issued for compliance with 
the EU SRR would be in substance compliance with the HKC but not 
the other way around. 
-According to HKC, the validity of IHM certificates shall cease to be 
valid upon transfer of a ship to the flag of another State. The new 
State can request the former flag state to transmit copies of 
certificates and if available, copies of the relevant survey. There is no 
similar provision in the EU SRR. 
- The EU format of the ‘Ready for recycling certificate’ (Decision 
2016/2321) is very similar to the HKC format, but are issued by 
virtue of two different instruments and their annexes (IHM and SRP 
have additional requirements under EU SRR) 
- There is no form for the authorisation of ship recycling facilities 
under EU SRR. 
-  In addition to the fact that they refer to different legal frameworks, 
HKC and EU SRR (Decision 2016/2324) formats for Report of 
Planned Start of Ship Recycling are similar. Minor differences exist 
however as HKC includes additional data (State that has issued the 
DASR, Place of authorization and full designation of the Competent 
Authority). 
- HKC form and the EU SRR format (Decision 2016/2322) on 
Statement of Completion of Ship Recycling are very similar, only 
difference being that they refer to different legal frameworks. 
Violations/sanctions 
Both frameworks provide for members to establish sanctions that 
must be adequate in severity to discourage violations.  However, 
COM role regarding control (and therefore sanctions/de-listing) of 
third country facilities on the European List is a difference as well as 
the fact that illegal recycling of ships should constitute a criminal 
offence (through Directive (EU) 2024/1203 [Environmental Crime 
Directive (ECD)). 
Reporting requirements 
- On the notification by the shipowner of the intention to recycle a 
ship to flag state, EU SRR specifically ask for the name of the SRF, 
the IHM and detailed ship-specific information. HKC does not. 
- It is optional under EU SRR for EU flag states to send to the 
competent authority of the recycling state the information provided 
by the shipowner part of the notification of its intent to recycle a ship 

147 

Flag 
states, 
Shipow
ners 

All 

All 

 
 
 
 
 
 
 
and further details.  Under HKC, there is a requirement for the SRF 
to inform its Competent Authority about the intent the recycle the 
ship, with similar details. 
- The HKC requires the SRF to report to its Competent Authority the 
planned start of the recycling while the EU SRR requires the SRF to 
report this to flag state 
- The HKC requires SRFs to send the Statement of Completion to its 
Competent Authority and that the latter send a copy to the 
Administration that issued the (International) Ready for Recycling 
Certificate (flag state). The EU SRR asked the SoC to be sent only by 
the SRF to the flag state. 
- The HKC requires SRF to report to the Competent Authority, on 
incident, accident, occupational diseases, or chronic effects, whilst 
the EU SRR require that the SRFs to establish records. 
- The Commission and the IMO require information to be submitted 
from their members. The information required is similar but there are 
differences in substance, Also the format and frequency are different. 

148 

 
 
 
 
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150