Nicola Mulinaris, Author at NGO Shipbreaking Platform

Press Release – Industrial associations, trade unions and NGOs urge the European Commission not to greenlight beaching yards

Posted on 15/09/202615/09/2026 by Nicola Mulinaris

The decision to allow beaching yards on the EU List would undermine responsible ship recyclers who made significant investments to meet high environmental, health, safety, and labour standards, and would expose them to unfair competition from substandard facilities. It runs against the EU Industrial Maritime Strategy and Clean Industrial Deal, which call for expanding European ship recycling capacity and securing material strategic autonomy. Most critically, it greenlights the exports of hazardous waste to countries lacking equivalent protections, a practice at odds with the EU Waste Shipment Regulation and the Basel Ban Amendment.

The demands from the signing parties are clear:

- Do not approve beaching facilities on the EU List;

- Further develop the technical guidance not approving the beaching method under the EU Ship Recycling Regulation;

- Lead international advocacy for a global beaching ban at the International Maritime Organisation level;

- Close legal loopholes enabling the re-flagging of vessels and ensure that all EU-owned vessels are recycle in line with the EU standards;

- Implement concrete measures to expand European ship recycling capacity in line with the best available practices.

Press Release – Most EU ships are being scrapped in South Asia despite sufficient domestic recycling capacity, confirms new study

Posted on 31/08/202631/08/2026 by Nicola Mulinaris

- Between 2019 and 2025, only 22% of EU ships were recycled in an EU facility, representing just 5% of the total recycling tonnage;

- Nearly half were beached in India, Bangladesh and Pakistan - representing 66% of total tonnage. 102 ships swapped their EU flag to another flag shortly before dismantling to avoid stricter EU rules;

- In 2020, EU recycling capacity stood at 2.1 million Light Displacement Tonnes (LDT). Yet of the 1.4 million LDT of EU-owned tonnage dismantled that year, over two-thirds ended up on South Asian beaches;

- EU facilities can accommodate large vessels, with at least 6 to 8 yards capable of recycling ships up to 330 meters long.

The vast majority of EU-owned or EU-flagged ships are being scrapped under poor conditions in India, Pakistan and Bangladesh, while EU-located ship recycling facilities operate under capacity, a new study from the NGO Shipbreaking Platform and T&E shows. This is both an environmental scandal and a loss of high-quality materials for the EU economy, say the NGOs, who issued a report concluding that the EU has enough domestic capacity to recycle all EU-flagged and EU-owned vessels.

Between 2019 and 2025, 706 EU-flagged and/or EU-owned ships were dismantled worldwide. Only 22% were recycled in EU-located facilities, representing just 5% of the total tonnage. Nearly half were beached in India, Bangladesh and Pakistan - 66% of total tonnage. The remaining ships were dismantled mostly in Turkish shipbreaking yards.

"This is not just an environmental issue. It is a profound failure of EU industrial strategy, prioritising strategic resilience and material autonomy on paper, while in reality letting valuable steel be lost to third markets. The EU speaks of reducing dependence on imported critical materials, yet, it lets its shipowners evade regulations and export millions of tonnes of recoverable steel that could be processed domestically. This is not strategic autonomy."

Philippine Bernard - Policy Officer - NGO Shipbreaking Platform

South Asian shipbreaking relies on beaching, with ships being dismantled directly on the beach with no containment. This practice leads to water and ground contamination through the discharge of hazardous materials. Additionally, dangerous working conditions due to operating on a tidal mudflat are also a major concern.

The EU Waste Shipment Regulation prohibits ships becoming waste in EU waters from being exported to a non-OECD country, while the EU Ship Recycling Regulation requires EU-flagged vessels to use an EU-approved facility. In reality, most of the EU-owned fleet continues to be scrapped in substandard yards in South Asia, with shipowners either reflagging their ships or fraudulently claiming to continue operations to evade waste export restrictions. As a result, the EU continues to export toxic waste in the form of end-of-life vessels. As many as 102 ships swapped their EU flag for another flag shortly before dismantling to avoid EU restrictions.

In July, the European Commission announced plans to add the first beaching ship recycling facilities to the EU’s approved list. This will make it easier to dump ships overseas, say the Shipbreaking Platform and T&E. EU-based yards operate under high environmental and labour standards. Approving substandard beaching yards would penalise responsible European industry and reward harmful practices that are effectively not approved in EU Member States.

In 2020, the year with the biggest number of ships dismantled worldwide, EU facilities had an overall recycling capacity of 2.1 million light displacement tonnes (LDT) while the total of EU-owned ships dismantled that year amounted to 1.4 million LDT. Over two-thirds of EU-owned tonnage was dismantled on beaches in India, Bangladesh and Pakistan. Every vessel beached could have been accommodated by a minimum of 6 to 8 EU yards.

Up to 95% of the weight of a ship can be recycled as high-quality scrap steel. In a previous report, the Shipbreaking Platform concluded that almost 12,000 EU-owned ships would reach end of life in the next decade, which could yield up to 12 million tonnes of steel yearly. Shipbreaking in Europe represents a major economic opportunity.

Persisting policy gaps prevent the ship recycling from aligning with the strategic plans of the Union. Beaching, considered the most dangerous shipbreaking method, must be explicitly banned, not authorised based on shipowners’ false claims of insufficient EU capacities. The EU must align the reality with its declared circularity and decarbonisation pledges. Without closing gaps such as the re-flagging to flags of convenience, ambitious plans will be more of the Commission's wishful thinking. Finally, the EU must continue its efforts to actively promote and support the best practices in the ship recycling sector to ensure a global level playing field.

The report is available under this link.

Press Release – Nine shipbreaking workers killed in Bangladesh

Posted on 17/08/202602/09/2026 by Nicola Mulinaris

The NGO Shipbreaking Platform condemns yet another tragic accident on the shipbreaking beaches of South Asia.

On 14 August, nine workers died after exposure to toxic gas inside the LNG carrier MT RASI (IMO 9176008) at Ferdous Steel in Chattogram, Bangladesh. Among those killed was a 17-year-old. Several other workers were injured.

The tragedy occurred at a yard certified as compliant with the Hong Kong Convention (HKC). Only one month earlier, Bangladesh's Department of Inspection for Factories and Establishments had taken legal action against Ferdous Steel following repeated occupational safety failures. Following the deaths, the Bangladesh Environmental Lawyers Association (BELA) issued a notice demanding an independent investigation and the shutdown of the yard.

The scale of this tragedy is shocking, but fatal and serious accidents in the sector are far from exceptional. According to The Daily Star, 84 accidents have occurred at Bangladeshi yards since the HKC entered into force in June 2025, leaving 15 workers dead and 81 injured.

These figures expose the gap between certification on paper and conditions on the ground. They also underline the limits of the HKC itself. The Convention establishes a weaker global baseline than the obligations of the Basel Convention, which is designed to prevent hazardous waste from being exported to countries unable to manage it in an environmentally sound manner.

Accountability does not stop at the yard gate. Shipowners and cash buyers decide where vessels are dismantled and must bear responsibility for those choices.

The RASI is the former HL RAS LAFFAN, owned by South Korean H-Line Shipping and linked by shipping databases to cash buyer GMS. In March 2025, the Platform specifically warned that H-Line was preparing to retire the vessel, while denouncing the company's continued disposal of end-of-life ships on South Asian shores.

The Platform calls on Bangladeshi authorities to ensure an independent and transparent investigation into the nine deaths, hold those responsible to account, schedule regular unannounced inspections, and enforce safety and environmental requirements.

The tragedy should also serve as yet another warning to regulators elsewhere. As the European Commission considers approving shipbreaking facilities that continue to dismantle vessels directly on beaches, the costs of accepting certification in place of genuinely safe and contained recycling infrastructure could not be clearer.

Press Release – European Commission Must Not Approve Beaching Yards on the Updated EU List

Posted on 30/07/202630/07/2026 by Nicola Mulinaris

The European Commission has launched a public consultation on its proposed 16th update of the EU List of ship recycling facilities. While the proposal includes the removal of yet another Turkish shipbreaking yard due to recurring deficiencies, two beaching yards: Shree Ram and YSI Recyclers, located in Alang-Sosiya, India, are proposed to be included. This represents a significant shift from previous editions of the List and raises serious concerns on the future direction of the EU Ship Recycling Regulation (EU SRR).

The objective of the EU SRR is to ensure safe and environmentally sound ship recycling. If the Commission's assessment methodology allows the approval of facilities that pose serious risk to coastal ecosystems, workers and surrounding communities, the Regulation's objectives are clearly not met. Beaching, the dominant shipbreaking method in South Asia, is not allowed in the EU [1]. This method involves dismantling vessels directly on tidal mudflats without any infrastructure to contain pollutants. Debris and toxic contaminants, such as oil, fuel, and liquid chemical residues, land directly in the seawater, largely contributing to the degradation of ecosystems [2].

Recent incidents reinforce these concerns. In June 2026, a heavy fuel spill occurred at the Priya Blue shipbreaking yard, contaminating vast parts of the Gujarati coast. The spill was visible 10 kilometres from the yard. Despite claims of immediate response, the incident demonstrates fundamental inability to contain pollutants when dismantling occurs on tidal mudflats.

These operations violate coastal regulation zone boundaries, and while Indian courts have generally pursued regulation over prohibition, environmental groups argue this framework remains insufficient to ensure safe and environmentally sound practices given the inherent ecological and health risks linked to beaching [3].

The EU and its Member States are furthermore signatories to the Basel Convention on the control of transboundary movements of hazardous waste, a category that includes end-of-life ships. The Convention's goal is to prevent the dumping of hazardous waste in countries that lack adequate capacity to manage it safely. The Basel Ban Amendment specifically prohibits hazardous waste trade from OECD to non-OECD countries.

"While the EU has a responsibility to ensure that it does not export harm to third countries, the standards of the EU SRR cannot change based on the location. Every yard on the EU List should be subject to the same rules and procedures. If not, compliant yards in the EU will continue to face unfair competition. We urge the EU to close the door on harmful practices that would never be allowed in the European Union’s territory and put a stop to the shipping industry’s exploitation of weaker environmental and OHS standards."

Ingvild Jenssen - Executive Director and Founder - NGO Shipbreaking Platform

Join us and call on the European Commission to:

- Remove the Indian beaching facilities from the proposed list as they do not ensure safe and environmentally sound recycling of vessels;

- Ensure consistency with the Basel Convention's obligations on hazardous waste trade;

- Apply uniform standards across all listed facilities regardless of geographic location – the standards cannot change based on the location;

- Prioritise the EU SRR's core objectives of environmental protection, worker safety.

The consultation on the EU List is open until 30 August. NGO Shipbreaking Platform is currently thoroughly reviewing the inspection reports from the beaching yards. We urge all stakeholders that share our commitment to environmental justice to contribute to the consultation.

The EU List should serve as a benchmark for best practices, not as a tool that legitimises greenwashing. Beaches and tidal mudflats, regardless of location, are not acceptable areas to recycle ships.

NOTES

[1] Beaching per se is not explicitly prohibited in the EU Ship Recycling Regulation. However, Article 13(1) of the Regulation states that safe and environmentally sound management of ship recycling includes handling of hazardous materials, and of waste generated during the ship recycling process, only on impermeable floors with effective drainage systems. Beaching a vessel on an intertidal mudflat, where pollution incidents such as an oil spill cannot be effectively contained, is therefore incompatible with this requirement.

[2] The EU site inspection reports from Alang-Sosiya record pollution and debris in the yards and their surrounding area. Similarly, inspections in Aliağa, Turkey, found debris left in the foreshore and water. Recent studies confirm persistent contamination of Alang's seawater and sediments with heavy metals, petroleum hydrocarbons, PAHs, and other contaminants from fuel leakage, cutting, welding, and paints. Alang-Sosiya sits in the Gulf of Khambhat, a coastal system already characterised by high tides, strong currents, cyclones and river discharge. Mitigation measures, such as concrete floors and drainage channels in the secondary cutting zones, and embankments only partially offset pollution pathways that are inherent to beaching, and since yards share a single tidal cluster, no plot's performance can be assessed in complete isolation.

[3] Indian shipbreaking yards operate under a built-in regulatory exemption. Although the sector legally requires EIA and Coastal Regulation Zone clearance, it's been exempted from both since operations predate those regulations. Oversight is weak by the regulator's own admission, the Gujarat Pollution Control Board's 2022 audit by India's Comptroller and Auditor General found chronic understaffing, weak technical capacity, and poor transparency undermining its function. In 2025 the GPCB furthermore downgraded shipbreaking's pollution classification from Red to Orange despite acknowledging the sector releases hazardous materials, stretching permits from 5 to 10 years and halving inspections. Yards also remain legally entitled to resell recovered asbestos, while downstream treatment capacity is already exhausted, with no wastewater management capacity and standard for the sector.

Press Release – Turkish Civil Society Organisations Respond to New ‘Sham’ EIA Process and the Ship Recycling Regulation

Posted on 09/07/202609/07/2026 by Nicola Mulinaris

The public consultation of the EIA procedure was held on 23 June. The Turkey Ship Recycling Monitoring Coordination stated that the revised EIA fails to provide a real environmental assessment of ship recycling activities in Aliağa, and cannot be accepted as such. The Coordination condemned the new EIA document, calling it a legal cover for existing unlawful practices and past environmental harm in Aliağa caused by the shipbreaking industry.

What are the problems with the new EIA that the civil society groups highlight?

- The EIA application features an “increase in the operational area,” although the referred additional coastal land created by “sediment accumulation” is already being used to store metal waste, ropes, equipment and vehicles, as shared.

- The application therefore appears to seek approval for an existing situation. Nevertheless, it provides no maps, boundaries, measurements or clear explanation of how the areas were formed and are currently used.

- It contains no field studies, facility-level assessments or current pollution measurements. Risks related to land formation, geology, earthquakes, biodiversity, agriculture and the marine environment are not assessed.

- Hazardous waste, wastewater and drainage systems are not meaningfully addressed. No facility-level data is provided on the types and quantities of waste generated, stored, transferred or disposed of.

- Finally, the application was submitted by the Ship Recyclers’ Association, which does not itself operate the facilities. This appears contrary to Turkey’s EIA Regulation, which requires the application to be made by the project owner.

"This EIA application fails to assess the key environmental, technical and occupational risks of ship recycling in Aliağa, despite previous studies identifying ship recycling as a serious source of pollution in the region. In light of four worker deaths in the last eight months and the lack of transparent data on injuries, occupational health and safety risks also require a holistic assessment, together with environmental aspects. Yet the data shared during the meeting remain incomplete, misleading and far from reflecting the reality on the ground."

Selma Akdoğan - Chamber of Environmental Engineers, İzmir Branch

The critique comes amid serious concerns over occupational safety. Since October 2025, four workers have lost their lives in fatal incidents in Aliağa ship recycling facilities, two of which occurred in EU-listed yards. Most recently, on April 25 2026, 65-year-old Galip Avcı lost his life at the EU-listed Sök Denizcilik yard after being crushed by a heavy metal part during cutting operations. Further concerns regarding oversight at the same yard arose on 26 June, when customs authorities reportedly discovered a large quantity of illegal fuel on board a vessel that had arrived for dismantling.

Apart from the EIA procedure, a new Regulation was published on 22 June 2026, that introduced a new authorisation system in line with the Hong Kong Convention. It requires facility-level and ship-specific recycling plans, and establishes approvals and sanctions in line with guidelines. The Ministry of Environment, Urbanization and Climate Change must also adopt a separate regulation within one year setting out environmental requirements for ship recycling.

However, key requirements remain unclear, as the Regulation relies on unspecified national and international guidelines without clearly defining them, whether they are binding, or where they can be accessed. The Regulation also lacks concrete environmental requirements for permitting, pollution control, monitoring and transparency. Its effectiveness will depend on binding environmental rules and a broader assessment of the risks of landing-based ship recycling.

Following serious incidents that occurred in January and February, the European Commission carried out unannounced inspections at the EU-listed Leyal and Avşar yards in March 2026. The inspection reports, published last month, raise significant concerns about pollution containment, as well as incident documentation and reporting.

In January, GNV Antares (IMO 8503797), being dismantled in Leyal yard, collided with a platform located in the neighbouring Metaş shipbreaking yard. Another incident was reported in February, when unidentified liquid substance was discharged into the sea during the dismantling of the Lily Ha (IMO 8116972) vessel in Avşar.

According to the EU Inspection Report of Leyal, the GNV Antares suffered a hull rupture and uncontrolled flooding on 8 January 2026. Inspectors later observed extensive water and oily residues inside the vessel, but the facility provided no incident report, management records, water samples or sufficient documentation. The extent of any environmental pollution could therefore not be verified or quantified. The findings were categorized as a deficiency.

Concerning Avşar, satellite imagery confirmed that Lily Ha collided with a platform at the neighbouring Metaş yard on 19 February 2026 as well. However, the source of the subsequent marine pollution could not be conclusively attributed to either facility or to the collision. Inspectors found no incident report, root-cause analysis or supporting documentation, and considered the yard’s spill-response method uncertain and potentially impractical. The incident’s cause was concluded as “inconclusive”. The report also identified three inconclusive items, nine deficiencies and five areas for improvement, including repeated worker-safety concerns.

To the best of our knowledge, no public information has been made available on the condition of the platform in Metaş following the collisions or on any damage it may have sustained.

EU-listed yards must be able to identify pollution sources and demonstrate how pollution was prevented, contained, collected and safely disposed of. These findings reinforce the need for fully contained recycling of ships, thorough environmental impact assessments, and strict legal enforcement.

Press Release – Massive Oil Spill at India’s “Best Shipbreaking Yard” Raises Serious Concerns Over Hong Kong Convention Certification. NGOs call for a global ban on beaching

Posted on 02/07/202602/07/2026 by Nicola Mulinaris

A massive oil spill at Priya Blue’s shipbreaking yard plot V1/V2 in Alang-Sosiya, Gujarat, India, raises serious concerns over safety and environmental standards at one of the country’s most heavily promoted shipbreaking facilities, and is a stark reminder of the inherent flaws of the beaching method [1]. Environmental and human rights organisations have for years urged global policy makers and industry stakeholders to phase out this dangerous and polluting method of scrapping ships and now call on urgent action to ban beaching.

The spill occurred on the afternoon of 13 June. According to Priya Blue, an “extremely high tide wave” destabilised the LNG vessel SOHAR (IMO 9210816) which had been beached at their plot only a few days earlier. The vessel then supposedly crashed into the floating crane barge stationed at the yard, reportedly causing severe damage to the SOHAR’s forward fuel tank and releasing large amounts of heavy fuel oil into the sea.

While Priya Blue published an Incident Investigation and Environmental Response Report on 26 June claiming that remediation began immediately, workers in full PPE were mobilised, and containment measures were deployed close to the source of pollution, available evidence tells a very different story.

Local media reports on the environmental disaster and testimonies from affected communities also point to major discrepancies in Priya Blue’s account. The company’s report – which only includes pictures from several days after the incident and no pictures of the impact on the SOHAR – appears to downplay the scale and spread of pollution, while independent documentation shows contamination far beyond the immediate area of the yard. Oil was reported washing ashore along a large stretch of the coastline, including fishing village Mithi Virdi, around 10 kilometres from Priya Blue, directly contradicting any suggestion that the spill remained contained close to the facility.

Two days after the incident, Gujarati TV channel TV9 reported from the site, and according to their sources, more than 30 hours after the massive oil spill, responsible authorities, including the Gujarat Maritime Board and Gujarat Pollution Control Board, appeared not to have taken any action. While public outrage grew after videos of heavy fuel oil washing ashore began circulating on social media, little information about the origins of the spill was available, showcasing a serious lack of transparency, enforcement, and accountability in the Alang-Sosiya shipbreaking region. According to a Gujarati-language newspaper, Gujarat Samachar, the Gujarat Pollution Control Board collected liquid and sediment samples along a 200–300 meter stretch of coastline only three days after the spill.

Priya Blue is not a marginal operator in Alang-Sosiya, and is linked to cash buyer Best Oasis. Widely promoted as one of India’s most advanced shipbreaking yards, Priya Blue has operated for 40 years and its yard at plot V1/V2 is one of the first to have obtained a certificate from Indian authorities as being compliant with the IMO’s Hong Kong Convention. Priya Blue has also sought inclusion on the European List of approved ship recycling facilities under the EU Ship Recycling Regulation — a framework intended to reflect high standards on worker safety, environmental protection, and downstream waste management. Vocal at international maritime conferences and highlighted by shipping stakeholders as evidence that beaching yards can meet global standards, Priya Blue was recently presented in the Sustainable Shipping Initiative’s Alang in Transition: From Compliance to Capability report as a showcase for improvements in Indian shipbreaking. The incident, and subsequent management of the oil spill by Priya Blue, now casts serious doubt on those claims.

Many issues surrounding the oil spill remain unclear, including why the LNG SOHAR was carrying 1.800 tonnes of fuel. The NGO Shipbreaking Platform has sent several questions to Priya Blue of which it so far has not received a response. [3] The LNG SOHAR was sold for scrapping in Alang by Japanese MOL and Oman’s Asyad Shipping who jointly owned the vessel. Vessels owned by Japanese NYK (LNG JAMAL – IMO 9200316) and offshore drilling contractor Transocean (DISCOVER LUANDA – IMO 9456068) were also present at Priya Blue when the incident occurred.

Having informed global policy makers about the oil spill on 23 June at a UNEP Basel Convention meeting, the NGO Shipbreaking Platform calls for a ban on the beaching method, also under the IMO’s Hong Kong Convention which currently is under review. Ship recycling must take place in facilities capable of controlling spills, protecting workers, and preventing toxic releases from reaching coastal communities and the sea. When vessels are dismantled on tidal flats, no infrastructure can contain spills of toxic substances.

In light of the above, the NGO Shipbreaking Platform calls on:

- The Gujarat Maritime Board and the Gujarat Pollution Control Board to conduct a fully transparent investigation, publish all sampling results, and disclose the volume of oil released and the full extent of contamination;

- The European Commission to take this serious incident into account in its assessment of beaching yards that have applied for inclusion on the European List, and clearly recognize that the beaching method does not guarantee the requirements for containment under the EU Ship Recycling Regulation;

- Shipowners, including MOL, NYK and Transocean,to immediately cease sending vessels to beaching yards and instead use only facilities that provide impermeable surfaces and engineered containment provided by industrial platforms, including adequate drainage;

- The International Maritime Organization to recognize the inherent risks and structural flaws of beaching and ban the beaching method under the Hong Kong Convention.

"A Hong Kong Convention certificate is not proof that a yard is preventing harm across the full chain of dismantling and disposal. Not a single yard in Alang-Sosiya would be allowed to clone its activities on a beach in the EU. That’s why the beaching method must never be rubberstamped by the EU. The method is already banned in all large ship-owning countries - it’s high time that the shipping industry stops defending a method they would never allow on their own shores."

Ingvild Jenssen - Executive Director and Founder - NGO Shipbreaking Platform

NOTES

[1] Beaching remains the dominant ship dismantling method in South Asia where end-of-life vessels are deliberately run aground on mudflats and cut apart without containment, all while exposed to massive tidal differences. Beaching inevitably causes pollution: debris, heavy metal laden paint flakes, plastics, oil residues, and other hazardous materials can escape directly into the surrounding coastal zone as there is no infrastructure to contain spills, exposing workers, local communities, and fragile coastal ecosystems to unacceptable risks. This recent oil spill at Priya Blue directly counters the claim that beaching can deliver safe and environmentally sound ship recycling.

[2] While Priya Blue omitted information and pictures of the initial response to the oil spill in their report dated 26 June, they later admitted to the NGO Shipbreaking Platform that workers carried out emergency clean-up activities “without safety footwear” but claimed that these were employees of a third-party contractor engaged to conduct emergency operations and stated that they have implemented measures to strengthen contractor management during future emergency response activities. It is not the first time a serious incident has occurred at Priya Blue. In 2022, a fatal accident occurred at their yard V1 while a BW Offshore vessel was being dismantled.

[3] To establish the circumstances of the oil spill, the NGO Shipbreaking Platform has requested a detailed incident timeline from the first indication of loss of containment through source control, containment, recovery, clean-up, and regulatory notification. We also asked for a hydrocarbon mass balance reconciling the reported 63 tonnes spilled, 32 tonnes recovered, tank transfer volumes, contaminated waste quantities, dispersed oil, and any residual or unaccounted quantity, together with documentation on the disposal of recovered contaminated waste. In addition, we requested the third-party marine survey report, or a technical summary, including photos of the damage, damage dimensions, tank identification, contents, and structural findings, as well as the SOHAR’s General Arrangement and Fuel Oil System drawings.

Press Release – EUROFER, Recycling Europe and the NGO Shipbreaking Platform urge the EU to put a stop to the double standards in the shipbreaking sector

Posted on 19/05/202602/06/2026 by Nicola Mulinaris

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.

You can access the Press Release document here.

Press Release – The EU Circular Economy Act risks missing the boat on ship recycling and true circularity

Posted on 04/05/202609/07/2026 by Nicola Mulinaris

Why does ship recycling matter?

- Scale of the opportunity: the Platform's research shows that EU/EFTA-owned ships could supply up to 12 million tonnes of high-quality steel scrap per year to the European economy over the next decade;

- Material recovery: up to 95% of a ship's weight can be recovered as high-quality scrap, representing a major secondary raw material stream for the EU steel industry, and leading to the sector's decarbonisation;

- The EU stake: companies based in the EU and EFTA own about one-third of the world's fleet, placing Europe in a pivotal position to lead the transition.

The Platform calls on the European Commission to use the Circular Economy Act to:

- Work across key waste legislative files to close the re-flagging loophole in the EU Ship Recycling Regulation, extending its scope to the real beneficial owners of vessels and recognising flag-swapping as a practice intended to circumvent EU rules;

- Recognise ship-derived steel as a strategic source of secondary raw material and ship recycling as a key circular sector for steel decarbonisation;

- Accelerate the development of a Ship Material Passport, building on the Digital Product Passport under the ESPR, to track materials from design to dismantling and enable cross-sector reuse;

- Establish appropriate financial incentives for ship-derived materials to remain in the EU, including a ship recycling return scheme as provided for under Article 29 of the EU Ship Recycling Regulation;

- Align shipping sector subsidies, including the tonnage tax regime, with clear circularity obligations, including end-of-life recycling at EU-approved facilities;

- Ensure dedicated investment under LIFE, the Innovation Fund and Horizon Europe to scale EU ship recycling capacity.

By keeping valuable steel within the EU, these actions will:

- Accelerate decarbonisation – each tonne of recycled ship steel avoids up to 1.5 tonnes of CO₂ compared with primary production, while using 72% less energy and reducing air pollution by 86%;

- Strengthen strategic material autonomy – reducing reliance on imported iron ore and coal in line with Europe's Critical Raw Materials Act objectives;

- Create green jobs – modern ship recycling yards and green steel production generate skilled employment in engineering, environmental management and advanced manufacturing;

- Uphold Europe's global leadership – reinforcing the EU as a front-runner in environmental stewardship, worker safety and circular economy policy.

"Bringing ship recycling back to Europe is also a matter of environmental justice. End-of-life ships contain asbestos, PCBs, heavy metals and toxic paints. Too many EU-owned vessels are still exported for dismantling on South Asian beaches, despite severe risks to workers, coastal communities and ecosystems, and despite international prohibitions on such exports. The EU must take responsibility for its own waste."

Benedetta Mantoan - Policy Manager - NGO Shipbreaking Platform

Save The Date – Ship Recycling Lab 2026: Transformation Through Innovation

Posted on 07/04/2026 by Nicola Mulinaris

Press Release – Environmental NGOs urge action after European Commission study exposes abuse of vessel flagging rules

Posted on 24/03/2026 by Nicola Mulinaris

The call follows the publication of a recent European Commission study on the use of open registries as flags of convenience, which confirms that this system allows regulatory evasion and undermines the EU’s environmental, social, fiscal and security objectives. Yet, despite a week of high-level discussions on Europe’s maritime future and the release of the EU’s strategy to strengthen the competitiveness of the maritime sector, the issue of flags of convenience and the study’s findings have so far received little political attention and no clear follow-up.

Oceana: “Flags of convenience are a major enabler of illegal fishing worldwide. They allow operators to hide their identity, evade sanctions and continue fishing illegally under new flags. The European Commission’s study confirms what civil society has long demanded: without full transparency on who owns, controls and profits from fishing vessels, the EU cannot credibly combat illegal fishing and protect the marine environment.”

WWF European Policy Office: “By its very nature, illegal fishing is hard to detect and monitor. Flags of convenience make that job exponentially harder, harming the fishers who follow the rules but suffer when fish stocks run low. As one of the world’s top seafood importers, the EU must lead by example and maintain a zero-tolerance approach to illegal fishing, including flags of convenience.”

Opportunity Green: "International shipping benefits from multiple gaps in international governance, allowing it to have large climate impacts without even paying the standard taxes paid by most corporations. The EU needs to look at the entire shipping industry and ensure that, instead of companies earning billions without paying taxes, they are subject to the same standard regulations as all other industries. The flag of convenience regime is an unnecessary exemption from usual rules given to a polluting industry."

NGO Shipbreaking Platform: “The study’s findings expose severe governance failures at the end of a ship’s life. Flags such as St Kitts and Nevis, Comoros, Palau and Tuvalu are widely used for last voyages to the shipbreaking beaches in South Asia, to circumvent EU regulations on the scrapping of toxic ships. The Commission has already recognised flag-swapping as the key obstacle to implementing the Ship Recycling Regulation. Yet, no further action has been taken to fix this issue and hold shipowners accountable.”

In light of the study’s evidence, the co-signing organisations call on the European Commission to:

- Close the data gap that allows the proliferation of flags of convenience by requiring comprehensive and reliable data on vessel beneficial ownership, flag history, and compliance records across all maritime sectors, including mandatory disclosure for foreign-flagged vessels owned or controlled by EU interests;

- Collaborate with EU Member States to systematically collect and regularly share relevant vessel information with international databases and monitoring platforms, including the FAO Global Record of Fishing Vessels, Refrigerated Transport Vessels and Supply Vessels and relevant Regional Fisheries Management Organisation (RFMO) vessel registries to curb illegal fishing;

- Integrate decisive measures across EU maritime and ocean governance frameworks, including the upcoming EU Ocean Act, fisheries policy, tax governance, maritime security and ship recycling rules, to discourage and prevent the use of flags of convenience.

Author: Nicola Mulinaris

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