We welcome the decision to remove the Dörtel ship recycling yard in Aliağa, Turkey. An inspection carried out by the Commission revealed that a ship was being dismantled while still being partially in the water, and the facility was not equipped with an impermeable floor and a slag collector. This could with a high probability lead to contamination of seawater - the main requirements for proper hazardous waste collection and treatment were therefore not met. Therefore, the removal of this facility from the list was indispensable. Although the decision to remove the the Dörtel ship recycling yard in Aliağa, Turkey is a step in the right direction, we find it insufficient.

Dangerous conditions in Turkish yards continue to reap their toll. In November this year, another worked died when tons of ship scrap fell on him, killing him instantly. This happened at the Temurtaşlar yard, which is an EU-approved facility.

Whereas several Indian yards – where ships are cut on unprotected tidal mudflats – have applied to be included on the European list, and were audited by the European Commission in late 2024, none have been proposed to be added to its most recent edition.

Beaching - the current method used by the Indian yards - does not provide full containment of pollutants; it is not allowed in the EU, explicitly banned in China and the UAE, and has even been identified as a method that needs to be replaced by drydocks by the Indian government in its Maritime India Vision 2030.

In their position submitted to the Commission, the European Shipowners (ESCA) states that the facilities on the EU list have very limited capacities, and their ship recycling activities are predominantly limited to small, often inland-sail vessels. Furthermore, the association complains that Indian ship recycling yards are again not included in the proposed new list.

Even though it is true that the EU-located facilities recycle smaller vessels, this is not due to the fact of their limitations in terms of size and technical capacities, but to the lack of stable inflow of ships to recycle. Considering the marine cargo sector’s record profits, we find their lack of willingness to contribute to the capacity building in the EU unjustifiable. The top 9 shipping companies’ profits rose in the 3rd quarter of 2025 to more than $4.3 billion in operating profit (EBITDA).

So far, only a handful of ship owners, including Hoegh, Hapag Lloyd, CMA-CGM and Petrobras, are taking action to build a better future for ship recycling. The vast majority continue to circumvent international environmental laws with ease, and even lobby for the weakening of standards as illustrated by the ECSA’s submission.

The Commission is furthermore urged to lead by example and enhance capacity in the EU to recycle the many ships that will head for scrap in the coming years. As outlined in the NGO Shipbreaking Platform’s recent report, enhancing domestic capacity for ship recycling provides a strategic opportunity for the EU to secure a steady supply of high quality secondary scrap for the decarbonisation of the steel and construction sectors, and provides coherence with EU environmental policies aimed at preventing the export of hazardous materials from the EU.