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  COM(2025) 52 final  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 {SWD(2025) 40 final}  
 
 
1.  INTRODUCTION  

Ship dismantling makes a significant contribution to the circular economy as it leads to  the 
reuse,  preparation  for  re-use  and  recycling  of  large  amounts  of  valuable  resources  (in 
particular high-quality steel, which typically  makes up between 75% and 85% of a vessel’s 
weight,  as  well  as  other  metals  and  equipment).  But  ships  also  contain  large  amounts  of 
hazardous  materials  such  as  asbestos,  polychlorinated  biphenyls  (PCBs),  heavy  metals,  oil, 
mercury, ozone-depleting substances (ODS). These substances, if not handled, removed and 
disposed  of  in  a  safe  and  environmentally  sound  way,  pose  significant  risks  to  both  human 
health and the environment.  

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. Before the SRR was adopted, 95% of 
the  volume  of  large  EU-flagged  and  EU-owned  ships  were  dismantled  outside  the  OECD2, 
mostly in South Asia (India, Bangladesh and Pakistan) using the so-called ‘beaching method’.  

The SRR achieves its aim with three specific objectives: (i) ensuring  that EU-flagged ships 
are  dismantled  in  safe  and  environmentally  sound  facilities,  (ii)  ensuring  the  proper 
management  of  hazardous  materials  on  ships,  and  (iii)  facilitating  the  ratification  of  the 
International  Maritime  Organisation’s    2009  Hong  Kong  International  Convention  for  the 
Safe  and  Environmentally  Sound  Recycling  of  Ships  (the  Honk  Kong  Convention)3.  The 
SRR 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 complying with the SRR requirements on protecting the environment and 
human health. The SRR covers seagoing vessels above 500 gross tonnage4.  

The  SRR  contains  a  review  clause  requiring  the  Commission,  5  years  after  the  date  of 
application  of  this  Regulation5,  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’.  
In  line  with  this  clause,  the  Commission  has  launched  an  evaluation  process  for  the  SRR6. 
This report, accompanied by the Commission Staff Working Document on the evaluation of 
the  Regulation,  is  the  result  of  this  process.  If  appropriate,  the  Commission  might  table  a 
proposal for a subsequent revision of the Regulation, supported by an impact assessment in 
accordance with the Commission’s Better Regulation Guidelines and Toolbox7. 

1 https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=CELEX:32013R1257  
2 Impact Assessment 2012. 74% in India, Pakistan and Bangladesh, 22% in China, Gross Tonnage-based, data 
from 2009. 
3 The Honk Kong Convention will enter into force in June 2025. 
4  The  scope  is  similar  to  the  Honk  Kong  Convention’s  scope.  It  excludes  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.  

5 The general date of application of the SRR is 31.12.2018, as specified in Article 32(1) point (b), so this means 

by 31.12.2023. 

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

Regulation-evaluation_en  

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

regulation-guidelines-and-toolbox_en 

1 

 
 
 
 
2.  METHODOLOGY 

The  report  and  its  accompagying  evaluation  are  based  on  extensive  consultation  with 
stakeholders.  This  included  a  public  consultation,  targeted  surveys  and  interviews  (with 
expert stakeholders and with Member States), a stakeholder workshop and discussion in the 
Commission  Expert  Group  on  ship  recycling.  A  wide  range  of  stakeholders  contributed, 
including  Member  State  authorities,  non-governmental  organisations  (NGOs)  and  research 
organisations,  industry  stakeholders  and  their  associations  (e.g.  shipowners  and  ship 
management  companies,  ship  recycling  facilities,  steel  industries),  classification  societies, 
consultancy  firms  and  financial  institutions.  Literature  reviews,  databases  and  legal  texts 
were also extensively used to gather additional expertise and information.  

This report is also based on Member States’ reports required under Article 21(2) of the SRR 
covering  the  first  triannual  reporting  period  from  2019-2022.  Annex  IX  to  the  evaluation 
makes  available  the  content  of  the  report  for  2019-2022  and  provides  a  summary,  in 
accordance with the second and third paragraphs of Article 21. 

The  evaluation  was  carried  out  in  line  with  the  European  Commission’s  Better  Regulation 
principles  and  methodology,  using  its  five  established  criteria:  effectiveness,  efficiency, 
relevance,  coherence  and  EU  added  value.  External  contractors  did  a  support  study  for  the 
evaluation report.  

The findings of the evaluation 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 on 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 shipyards covering the period before their application and 
it is not easy to separate the impact of the SRR from the impact of multiple external factors. 
More  effective  reporting  obligations  accompanied  by  harmonised  methodology  and 
indicators would therefore be needed to perform a more quantified evaluation of the SRR.  

The  evaluation  period  runs  from  January  2013  to  December  2023.  As  most  of  the  SRR 
requirements started to apply on 31 December 2018, December 2018 was used as the main 
point of comparison. The evaluation covers the Member States and European Economic Area 
countries, as well as the impact of the SRR on ship recycling practices in non-EU countries. 

3.  EVALUATION FINDINGS 

The  evaluation  findings  show  that  the  SRR  has to  a  large  extent  achieved  all  its  objectives 
compared  to  what  could  have  been  expected  had  the  EU  not  intervened  in  this  area.  The 
Regulation’s effectiveness has however been significantly undermined through the practice of 
shipowners  changing  the  ship’s  flag    from  a  Member  State’s  flag  to  a  third  country’s  flag 
shortly before the ship is being recycled and, to a lesser extent, through weak enforcement of 
the  measures  related  to  the  inventory  of  hazardous  materials.  This  report  outlines  the 
evaluation’s main findings and suggests areas for improvement. 

3.1.  EFFECTIVENESS 

First objective: Ensuring EU-flagged ships are dismantled in safe and environmentally sound 
facilities 

The SRR’s main operational objective is that at the end of their life, ships flying the flag of a 
Member  State  are  dismantled  in  facilities  that  are  approved  by  the  EU  and  are  on  the 
European  List  of  ship  recycling  facilities.  To  be  on  this  list,  a  ship  recycling  facility  must 

2 

 
 
meet  the SRR’s safety  and environmental requirements. For facilities in the EU, competent 
national  authorities  must  check  that  these  requirements  are  met,  and,  if  they  are,  tell  the 
Commission  that  the  facility  in  question  should  be  listed.  Ship  recycling  facilities  in  third 
countries  must  submit  an  application  to  the  Commission  to  be  put  on  the  European  List  of 
ship  recycling  facilities.  The  Commission  assesses  how  these  facilities  meet  the  SRR 
requirements,  including  through  onsite  inspections,  before  deciding  whether  or  not  to  put 
them on the list. The first European List of ship recycling facilities was adopted in December 
2016, with 18 facilities in the EU on it. At the end of the evaluation period, the 12th edition 
of  the  list8  contained  45  ship  recycling  facilities,  including  35  facilities  in  Europe  (EU, 
Norway  and  the  UK),  9  in  Türkiye  and  1  in  the  USA.  Applications  from  other  facilities, 
notably from India, are being assessed.  

Overall, the inclusion of these  facilities on the European List, and the prospect of joining it 
for  the  applicants,  in  conjunction  with  the  control  mechanisms  with  independent  oversight, 
have  contributed  to  higher  environmental  and  social  standards  in  ship  recycling  practices. 
The reports from over 55 Commission inspections of 25 facilities worldwide are a valuable 
source of information9 in that regard, notably on the mitigation of the externalities that affect 
the  industry.  The  European  List  is  also  a  reference  point  for  sustainable  ship  recycling 
practices in and outside the EU. 

The SRR’s effectiveness has however been considerably undermined by the practice of EU 
companies  re-flagging  ships,  shortly  before  being  recycled.  These  re-flagged  ships  are  no 
longer subject to the SRR and can be recycled anywhere, once they become waste outside of 
the EU.  In most cases, they are dismantled in  South  Asia.  In 2023, while the share of EU-
flagged  ships  was  around  13%  of  the  total  world  fleet,  the  percentage  of  end-of-life  ships 
with  an  EU  flag  at  the  time  of  recycling  was  below  7%,  compared  to  the  number  of  ships 
recycled worldwide.  

The main determining factor for shipping companies choosing a ship recycling facility is the 
price a facility offers for dismantling their ships. The prices facilities in South Asia offer have 
been consistently higher than in the rest of the world due to (i) the lack of internalisation of 
the  environmental  and  social  costs  (externalities)  of  ship  recycling  practices  in  these 
facilities,  and  (ii)  their  ability  to  offer  high  prices  for  steel  scrap,  given  the  strong  demand 
from  their  construction  sector  and  the  use  of  re-rolling  to  process  steel  scrap,  cheaper  than 
other forms of steel recycling generally used elsewhere.  

In this context, despite the greater awareness of social and environmental responsibility and 
the fact that the European List provides for sufficient capacity to deal with end-of-life ships 
flying an EU flag, many ships owned by EU shipping companies are not dismantled in ship 
recycling facilities that are on the European List. Due to re-flagging just before recycling, it is 
often just not possible to enforce the SRR provisions on shipowners’ obligation to have the 
ship dismantled in a facility on the European List.   

Second objective: ensuring the proper management of hazardous materials on ships 

Shipping companies are required to establish an inventory of hazardous materials  for each of 
their  ships.  The  inventory’s  quality  and  completeness  are  essential  for  ensuring  safe  and 
sustainable  dismantling  practices.  However,  data  reported  on  a  voluntary  basis  over  the 
period 2021-2023 on SRR related port state control inspections that verified the inventory of 

8 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=OJ:L_202302726   
9 https://environment.ec.europa.eu/topics/waste-and-recycling/ships/site-inspection-reports_en 

3 

 
 
 
hazardous materials show that 45% of inspected ships did not comply with the SRR and that, 
in  most  of  these  cases,  an  inventory  certificate,  or  its  equivalent  for  ships  flying  a  third 
country’s  flag,  did  not  exist.  However,  the  certificate  with  the  inventory  of  hazardous 
materials    is  generally  available  at  the  recycling  stage,  when  they  are  given  to  the  ship 
recycling facility to make it easier to dismantle the ship concerned. Nevertheless, inventories 
of  hazardous  materials    quality  and  completeness  are  often  insufficient.  It  is  therefore 
generally acknowledged that they need to be more reliable.  

Third objective: facilitating the ratification of the Hong Kong Convention 

The evaluation shows that the SRR has made a positive contribution to the ratification of the 
Hong Kong Convention. The minimum number of ratifications to trigger its entry into force 
was reached in 2023, with almost 50% of them by Member States. Besides what the analysis 
of the ratification figures  shows, what  is clear is  that  for many years  the SRR has been the 
only international legal instrument setting out specific ship recycling requirements and that it 
was an important benchmark used by many stakeholders and authorities outside the EU. 

3.2.  EFFICIENCY 

On  the  basis  of  the  opinions  and  data  obtained  from  the  surveys  and  interviews  done,  the 
costs  of  implementing  the  SRR  requirements  are  considered  to  have  generally  been  low  to 
moderate  over  the  evaluation  period.  Tangible  improvements  were  made  in  EU-listed 
facilities,  so  that  they  could  operate  in  line  with  the  requirements  of  the  SRR,  so  it  is 
reasonable  to  believe  that  the  SRR  resulted  in  a  positive  impact  on  health  and  the 
environment. The lack of a clear baseline of what would have happened in the absence of the 
SRR  and  the  limited  availability  of  quantitative  data  mean  it  is  not  possible  to  do  a  fully 
quantified  cost  benefit  analysis  and  monetisation,  with  the  result  that  the  overall  general 
positive conclusions on efficiency are largely based on qualitative data.  

Moderate costs are attributed to authorisations of ship recycling facilities by Member States 
and to surveys of ships. Costs associated with the port state controls related to the SRR are 
considered  low.  For  these  controls  to  be  effective,  several  EU  Member  States  nevertheless 
said more resources, specific guidance and investigation tools were needed. Costs vary from 
one EU Member State to another, depending firstly on the importance of shipping and ship 
recycling  in  the  Member  State  in  question,  but  also  on  different  enforcement  practices  and 
powers,  as  well  as  on  the  resources  allocated  to  enforcing  the  SRR.  Recycling  facilities  in 
third countries report high costs for upgrading their infrastructure and practices to bring them 
into line with the SRR and for them to be put on the European List. However, being on the 
list confers reputational benefits that lead to a positive impact on revenues and investments. 
For shipowners, the inventories of hazardous materials -related costs vary depending on the 
ship  and  the  quality  of  the  service  provided,  but  they  remain  negligible.  The  negative 
economic impact of the SRR on shipowners, linked to the loss of revenues from selling end-
of-life ships  to  EU-listed facilities did  not  materialise as  expected at  the time the SRR was 
adopted, due notably to  its being circumvented. For the same reason, the SRR did not alter 
the competitive disadvantages of EU ship recycling facilities, as the EU share in the recycling 
market remained limited.   

The SRR has a limited number of reporting obligations, all of which were analysed and found 
to be broadly proportionate. Efforts are being made to reduce reporting costs, for example, to 
ensure  reporting  synergies  with  the  Hong  Kong  Convention  in  accordance  with  the  ‘once 
only principle’. A way of reducing the administrative burden would be to increase the period 
of  validity  of  inclusion  on  the  European  List  (currently  5  years,  after  which  it  can  be 
renewed). 

4 

 
 
3.3.  COHERENCE 

Overall,  the  SRR  is  considered  internally  coherent  and  consistent.  However,  detecting  and 
addressing infringements of it is difficult due to the global nature and limited transparency of 
shipping  and  recycling  operations,  a  complex  supply  chain  involving  various  stakeholders 
and intermediaries and the fact that a ship can change flags  easily. This makes it difficult to 
identify  a  ship  destined to  be  recycled,  to  trace  its  journey  and  to  hold  the  actual  decision-
makers  to  account  for  their  actions,  which  makes  matters  difficult  for  enforcement 
authorities. Determining which Regulation applies due to the dual legal status of an end-of-
life  ship  as  hazardous  waste  and  as  a  ship  can  also  be  problematic.  In  this  respect,  the 
coherence between the SRR and the Waste Shipment Regulation10, both of which can apply 
to end-of-life ships depending on the circumstances, is sometimes seen as confusing too.  

Also,  although  the  SRR  is  largely  consistent  with  the  Hong  Kong  Convention,  as  it 
implements  it  into  EU  law,  a  few  public  authorities  and  the  shipping  industry  are  worried 
about  the  implementation  difficulties  that  will  arise  once  both  frameworks  are  in  force. 
Shipowners and public authorities also point to legal inconsistencies between the Hong Kong 
Convention  and  the  Basel  Convention  on  the  Control  of  Transboundary  Movements  of 
Hazardous  Wastes  and  their  Disposal,  which  need  to  be  addressed  in  the  relevant 
international fora. 

3.4.  EU ADDED VALUE 

In  the  absence  of  an  operational  dedicated  global  instrument  addressing  the  problems  with 
ship  recycling  at  international  level,  a  large  majority  of  participants  in  the  consultation 
process believed that the SRR has provided a much-needed EU framework for implementing 
the Hong Kong Convention in the EU. 

Arguments  about  what  level  of  legislation  (EU or  international)  is  the most  appropriate  for 
addressing ship recycling matters differ amongst stakeholders. Shipping industry stakeholders 
and some EU Member States believe that it would be better addressed at international level 
through the HKC, underlining the need for a level playing field globally. On the other hand, 
arguments  in  favour  of  continuing  to  work  on  this  at  EU  level  point  to  the  higher  level  of 
ambition and scrutiny of the SRR compared to the Hong Kong Convention. These are notably 
supported by NGOs, trade unions and ship recycling associations.  

These  stakeholders  unanimously  support  a  possible  revision  of  the  HKC  after  it  enters  into 
force,  whereby  the  EU  should  promote  its  higher  standards  at  the  International  Maritime 
Organisation’s level. This includes setting higher health and environmental requirements and 
putting stronger monitoring and control mechanisms in place, including independent scrutiny 
of  the  compliance  of  ship  recycling  facilities  with  adequate  environmental  and  workers’ 
safety requirements. 

3.5.  RELEVANCE 

The ship  recycling  market  is  expected to  grow substantially in  the  near future. The need to 
ensure  safe  and  sustainable  dismantling  practices,  as  well  as  proper  management  and 
identification of hazardous materials on board ships, will therefore remain relevant.  

10 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32024R1157.    

5 

 
 
 
The  SRR’s  relevance  should  also  be  assessed  in  the  light  of  the  EU  policy  and  regulatory 
landscapes  that  have  considerably  evolved  since  its  adoption.  Focusing  as  it  does  on  the 
environmentally sound management and storage of hazardous materials and waste, leading in 
turn  to  increased  energy  and  resource  efficiency  through  the  recycling  of  material  (in 
particular scrap steel), the SRR is  consistent with the objectives  of the EU Green Deal,  the 
Circular  Economy  Action  Plan,  the  Zero  Pollution  Action  Plan,  the  Sustainable  Blue 
Economy Communication and the green transition under the EU taxonomy. 

However, stakeholders generally believe that the SRR does not sufficiently contribute to the 
EU’s industrial strategy, including ensuring a competitive EU steel industry, and that it has 
the potential to play a bigger role in decarbonisation of the shipping industry. Increased ship 
recycling in the EU, with a corresponding higher uptake of steel scrap from ship recycling, 
could provide a steady supply of high-quality scrap, which the EU steel industry could use as 
feedstock to reach its decarbonisation goals. These aspects are of particular relevance in the 
context of the upcoming Clean Industrial Deal, Industrial Maritime Strategy and Steel Action 
Plan. Finally, some stakeholders believe that the SRR does not sufficiently integrate the life 
cycle  approach  into  ship  recycling,  through  cradle-to-cradle  design  and  a  comprehensive 
materials’ passport for each ship.   

4.  LESSONS LEARNED 

Given the SRR’s effectiveness is being considerably undermined by re-flagging, it should be 
considered how to address this problem so that the SRR’s key provisions can be effectively 
implemented. This is crucial for achieving the SRR’s current core objective of ensuring EU-
flagged ships are dismantled in safe and environmentally sound facilities. In this context, it is 
essential  to  clarify  how  it  is  determined  that  a  ship  is  destined  to  be  recycled  or  become 
waste, on the one hand, and who is the responsible owner, on the other hand, considering the 
role cash buyers currently play in trading end-of-life ships. Appropriate mechanisms should 
then  be  considered  to  prevent  the  owners  of  EU-flagged  ships  from  circumventing  their 
obligations to have these ships recycled in EU-listed facilities. Different options in that regard 
could  be  considered.  One  of  them  could  be  to  continue  working  on  developing  a  financial 
incentive as referred to in Article 29 of the SRR. This could take the form of a ship recycling 
licence for all ships calling at an EU port, bridging the revenue gap between dismantling in 
EU-listed facilities and in facilities not operating in a safe and environmentally sound  way. 
Another  option  could  be  to  apply  the  concept  of  a  ship’s  ‘beneficial  owner’,  instead  of  the 
registered  owner  linked  to  a  country’s  flag.  Both  ideas  gave  rise  to  polarised  views  among 
stakeholders.  The  impact  of  such  sensitive  measures  under  the  SRR  deserves  a  dedicated 
analysis in another context.   

The  possibility  of  upgrading  the  Hong  Kong  Convention’s  provisions,  on  the  basis  of  the 
SRR’s  provisions,  is  seen  by  shipowners’  associations  and  some  EU  Member  States  as  a 
possible  promising  step  towards  more  ambitious  and  harmonised  global  standards  for  ship 
recycling.  

At  the  same  time,  clarifying  the  SRR  standards  to  ensure  a  level  playing  field  for  EU 
facilities  could  also  be  considered.  This  could  involve,  for  example,  developing  additional 
and/or  more  specific  criteria  to  evaluate  waste  management  and  steel  recovery  operations, 
implementing  effective  pollution  control  measures  and  using  cleaner  dismantling  and 
recycling technologies and methods. 

6 

 
 
The  evaluation  shows  that  the  SRR  and  its  European  List  have  been  effective  at  ensuring 
there is sufficient capacity for the dismantling of ships within its scope (including ships that 
changed flag in the year prior to dismantling). However, it also concludes that capacity needs 
to keep growing to be able to meet the demand for ship recycling that is expected to increase 
significantly over the next 10 years.  

To  have  more  qualitative  and  reliable  inventories  of  hazardous  materials  s,  consideration 
should  be  given  to  how  the  whole  chain  of  responsibilities  can  be  strengthened:  from  the 
qualifications  of  experts  preparing  inventories  of  hazardous  materials  and  the  way  the 
Materials  Declaration  and  Suppliers’  Declaration  of  Conformity  are  obtained 
to 
methodological guidance and investigation tools that are necessary for carrying out effective 
controls under the SRR. 

To  properly  enforce  the  SRR,  all  EU  Member  States  should  have  specific  provisions  on 
penalties for infringing it and ensure that the penalties are severe enough to discourage non-
compliance. The interplay of the SRR with other legal instruments also needs to be clarified. 
To avoid there being an unnecessary administrative burden once the Hong Kong Convention 
enters into force, consideration should be given to how to streamline reporting or certification 
requirements arising from the co-existence of the SRR and Hong Kong Convention. 

Finally, any future revision could further assess the opportunity for the SRR to be made more 
relevant  to  the  EU’s  ambitions  in  terms  of  EU’s  competitiveness,  resilience,  and  climate 
neutrality, including through efficient and circular use of resources.  

7