Following our initial joint statement calling to boost ship recycling capacity in the EU, we welcome the European Commission’s initiative to review the technical guidelines for ship recycling yards located in third countries. Acting as an interpretation of the EU Ship Recycling Regulation, these guidelines are used by auditors to inspect and authorise ship recycling yards located in third countries to recycle EU-flagged vessels and ensure yards’ compliance. Their revision represents a key opportunity to fix the double standards embedded in the EU Ship Recycling Regulation’s current implementation.

In particular, we suggest the following improvements to guarantee a level playing field for ship recyclers in the EU and in third countries: 

- The guidelines must clearly ban beaching and landing as dismantling methods and only authorise dismantling in facilities ensuring full containment. 

- Ship recycling facilities in third countries should be obliged to acquire authorisations and permits needed for inclusion in the European list that are equivalent to the ones required in the EU, such as the Environmental Impact Assessment (EIA) and operational permits clearly defining yards’ conditions and activities (1). Currently in Turkey, despite its high-risk profile, the shipbreaking sector is exempt from the Environmental Permit and Licence Regulation and EIA procedures. The lack of a clear legal framework and weak monitoring schemes in third countries, compared to those applicable to ship recycling yards in the EU, leads to many of the operational problems observed on the ground and reported by EU inspectors, including poor waste management and unsafe working conditions in both Turkey and India. 

- A clear timeframe for inclusion or removal of ship recycling yards must be established, including a procedure for provisional suspension of non-compliant yards.

- Obligations to shipowners or states coming from other regulations, such as the Basel Convention, should be included in the guidelines.

- The Commission’s assessment of third countries yards should also cover facilities receiving and processing secondary raw materials from these yards, including steel processing installations (2). Such facilities should apply appropriate emission control measures and operate at a level of environmental performance considered equivalent to EU standards.

Acknowledging the constant serious problems occurring namely in yards located in Aliağa, Turkey, together with Turkish civil society organisations, we reiterate the call to remove Turkish facilities from the EU List until necessary improvements are properly implemented. The current situation not only puts the environment and workers’ health at risk but also undermines the very objective of the List to act as the role model for best practices for the ship recycling sector. Lack of proper environmental permitting and monitoring framework in the country’s shipbreaking sector cannot be ignored by EU decision-makers anymore.

“The current situation, where permitting and monitoring frameworks differ between EU/EFTA Member States and third countries, are the reason why double standards persist in the shipbreaking sector. European waste, wastewater, emissions and pollution rules, as well as safety standards, should serve as the benchmark against which all ship recycling facilities in third countries are assessed, in order to ensure that no EU-flagged vessel is dismantled in substandard yards.” – Ingvild Jenssen, Executive Director, NGO Shipbreaking Platform

“The update of the technical guidance note is a crucial opportunity to level the playing field between third country and EU yards and put an end to persistent double standards. Recycling Europe calls on the Commission to seize this opportunity and send a strong signal in support of the European ship recycling sector, while helping raise global ship recycling standards.” – Isabelle Radovan, Policy Advisor, Recycling Europe

“In addition to making sure that European and third country yards operate by the same rules and standards, the Guidance document should also further strengthen the ESM equivalence applicable to downstream facilities, including steel rerollers and processing installations. Such an approach would also help ensure consistency of EU environmental policy and keep up with the ambitions of the Waste Shipment Regulation” - Aurelio Braconi, Director for Stainless and Specialty Steels and Raw Materials, Eurofer

The EU should continue its efforts to raise global standards in ship recycling by clearly defining rules that reflect the Union’s very own pledges to only authorise best available techniques ensuring safe and environmentally sound recycling of vessels. This ambitious mission will fail if we don't ensure that practices that would never be allowed in the EU, such as beaching or landing, are accepted on the European list.