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

On Thursday 30/04, the final stakeholder workshop on the European Commission's impact assessment for the Circular Economy Act (CEA) on the Circular Economy Act assessment was held. NGO Shipbreaking Platform is concerned that the current proposal risks squandering one of Europe's most significant untapped material banks, end-of-life ships, and with it, a concrete opportunity for steel decarbonisation and material resilience.

 

NAVALEO - Les Recycleurs Bretons ship recycling yard, Brest, France

 

The CEA is expected to build a Single Market for secondary raw materials and stimulate demand for high-quality recycled content. Yet, without unlocking new material streams such as ship recycling, it will fall short its objectives. 

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 workshop revealed a critical blind spot of the proposed Act. The impact assessment focused almost exclusively on waste management measures: extensions to the WEEE Directive, construction and demolition waste, and harmonisation of End-of-Waste and EPR schemes. Higher levels of the circularity hierarchy, prevention, reuse, repair and refurbishment, were largely absent.

Primary focus on waste narrows down the Circular Economy Act simply to the waste management legislation, neglecting the very need of addressing material use throughout their lifecycle before they become a waste.

NGO Shipbreaking Platform finds the measures in the proposed Act too narrow, and urges the European Commission to address material overuse, overconsumption, and material reuse beyond the proposed prioritised recycling framework. 

Together with Recycling Europe and EUROFER, the NGO Shipbreaking Platform recently published a joint statement calling on the EU to recognise the strategic importance of the European ship recycling sector and to adopt concrete measures to keep valuable scrap steel within Europe.

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

The NGO Shipbreaking Platform will continue to follow the Commission's proposals closely and calls on EU decision-makers to deliver a Circular Economy Act that is ambitious, enforceable and fit for the realities of global ship recycling.

 

For the NGO Shipbreaking Platform's position on the Circular Economy Act, click here.

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

As the European Union positions itself as a global leader on ocean governance during the EU Ocean Days in Brussels and publishes its new Maritime Industrial Strategy, civil society organisations working on ocean environmental protection, labour rights, transparency, and maritime security warn that a major governance gap remains unaddressed: the widespread use of flags of convenience (FoCs).

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.

The study highlights how FoCs rely on opaque ownership structures, weak oversight, and poor enforcement of international rules, enabling harmful practices that directly contradict EU standards, global commitments, and put responsible flag States at an unfair disadvantage. Serious concerns related to how FoCs facilitate pollution and illegal dumping, the exploitation of seafarers and shipbreaking workers, and contribute to tax avoidance and illegal fishing, are raised in the report.

The co-signing organisations stress that it is not acceptable for the EU shipping and fishing sectors to continue operating under structures that directly undermine EU environmental, fisheries, fiscal and safety policies, while at the same time benefiting from access to EU markets and resources.

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.

The Commission’s own findings make clear that flags of convenience are not an enforcement anomaly but a structural governance failure driven by a prioritisation of profits, which results in reduced effectiveness of regulatory frameworks and lenient oversight.

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.

The co-signing organisations urge the EU to act without delay to discourage, disincentivise or dismantle those structures that enable such practices and to secure the long-term sustainability, integrity, and credibility of EU maritime governance.

Benedetta Mantoan, Policy Manager, NGO Shipbreaking Platform

Irene Campmany Canes, Senior Communications Officer, Oceana in Europe

Amélie Giardini, Global Lead for Transparency, the Environmental Justice Foundation (EJF)

Aoife O’Leary, CEO, Opportunity Green

Jacob Armstrong, Policy Manager, WWF European Policy Office

 

NOTES

 

[1] A flag of convenience is used when a vessel is registered in a country with which its owner has no genuine link, allowing operators to benefit from low costs and taxes, weak controls and limited enforcement. This practice creates regulatory havens at sea and enables environmental damage, labour exploitation and illegal fishing.

 

 

Press Release – Turkish civil society organisations reiterate their call to remove Aliağa shipbreaking yards from the EU list amid environmental damage and systemic negligence

Members of Turkish organisations raise alarm about critical levels of pollution in Aliağa, as well as severe systemic mismanagement, and continue their call to remove Turkish shipbreaking yards from the EU list of ship recycling facilities until necessary improvements are introduced by the Turkish authorities and the yards.

 

On 24 February, representatives of Turkish civil society organisations [1] met with representatives of the European Commission from DG ENV. Supported by Brussels-based NGO Shipbreaking Platform and the European Environmental Bureau, the organisations informed the Commission about the severe environmental degradation caused by shipbreaking activities in Aliağa, as well as pending legal cases [2] addressing systemic issues in the sector. 

An open letter requesting the removal of Aliağa-based shipbreaking yards was sent to the European Commission in November last year, in which the parties requested the removal of Turkish yards from the EU list based on de facto double operating standards and significant environmental and health risks. 

According to a recent report, the area is heavily contaminated with Persistent Organic Pollutants (POPs). These pollutants, some of which are currently regulated or banned under the Aarhus Protocol and the Stockholm Convention, come from industrial activities, and are very difficult to remove from the environment once they have been released. The findings show that the shipbreaking area contains the highest levels of POPs, clearly pointing to the ship recycling yards as the main source of contamination.  

Several serious incidents at Aliağa shipbreaking yards have occurred these past months, including at yards that remain on the EU List. On 20 February, during the dismantling of the LILY HA (IMO 8116972) at Avşar Ship Recycling yard, an EU-listed facility, unidentified liquid substances were discharged directly into the sea. The incident was reported by a local whistleblower, who alerted the NGO Shipbreaking Platform, as well as the European Commission. Avşar has stated to the NGO Shipbreaking Platform that the liquid thrown overboard the LILY HA was a biochemical cleaner used to remedy pollution originating from outside their yard, and in line with the facility's relevant procedures. No incident report is, however, available. 

Another accident happened on 8 January at the EU-listed Leyal yard, where GNV Antares (IMO 8503797) collided with an oil platform in the neighbouring Metaş yard, causing serious damage and flooding at the stern, including the engine room.  Since then, oil residue, likely mixed with other pollutants, has been continuously and deliberately being discharged into the sea through pipes. 

As seen in a video taken on 28 January, the tower of the oil rig that crashed into the GNV Antares was pulled down and dropped directly into the sea during dismantling operations.

The problems caused by the shipbreaking activities in Aliağa, including incidents such as those mentioned above, were thoroughly examined in the report on Turkish yards written by the NGO Shipbreaking Platform. 

NGO Shipbreaking Platform supports the Turkish civil society organisations and backs their call to cancel the EU approvals for Aliağa-based shipbreaking yards, and furthermore requests that the EU thoroughly investigate the recent incidents that have occurred at EU approved facilities. We also call on Turkish authorities to effectively monitor, take action to clamp down on breaches, and support the transitioning of the sector to industrial solutions that can ensure full containment. The recent incidents illustrate the inherent risks of using the landing method which should be phased out.  

"NGO Shipbreaking Platform supports the Turkish civil society organisations and backs their call to cancel the EU approvals for Aliağa-based shipbreaking yards, and furthermore requests that the EU thoroughly investigate the recent incidents that have occurred at EU approved facilities. We also call on Turkish authorities to effectively monitor, take action to clamp down on breaches, and support the transitioning of the sector to industrial solutions that can ensure full containment. The recent incidents illustrate the inherent risks of using the landing method which should be phased out. "
Ekin Sakin - Policy Officer - NGO Shipbreaking Platform

The EU List of ship recycling facilities currently contains 10 ship recycling yards in Turkey. Since 2016, 4 Turkish yards have been removed from the EU list. 

 

NOTES

 

[1] Representatives of the following organisations were present: Izmir Medical Chamber, Istanbul Health and Safety Watch, Aegean Environment and Culture Platform, Izmir Living Spaces, Foça Environmental Platform, Turkish Medical Association, Foça Platform Against the Plundering of History and Nature, İzmir Chambers of Environmental Engineers. 

 

[2] Shipbreaking facilities in Turkey are exempt from the Environmental Impact Assessment (EIA) procedure, which is mandatory for the EU-located yards. The exemption issue is currently pending before the Constitutional Court of Turkey. 

 

 

Press Release – EU Industrial Maritime Strategy: Commitment to boost EU-based ship recycling capacity must be backed by concrete funding and measures and a true level playing field

The European Commission published on Wednesday 5 March its Industrial Maritime Strategy, an important milestone in supporting the European maritime industry. While the strategy acknowledges the importance of ship recycling and the need to strengthen the sector within the EU, it lacks actionable measures to scale up capacity. The strategy’s reference to cooperating with India moreover risks accentuating the unfair competition currently faced by EU yards which today remain underutilised. Without clear targeted support, and an unambiguous plan to boost domestic capacity, the EU risks missing a critical opportunity to meet its climate and circularity objectives.

Although EU/EFTA shipping companies own over 35% of the global fleet, only 1% of EU-owned ships are today dismantled in the EU. According to our research, about 12 000 EU/EFTA-owned vessels will become eligible for scrapping in the next decade. Boosting European capacities for ship recycling is therefore timely and will provide key sectors with access to high quality scrap steel, as recently called for by the NGO Shipbreaking Platform, EUROFER and Recycling Europe.

In this context, the NGO Shipbreaking Platform welcomes the European Commission’s commitment to “explore ways to support the expansion of domestic EU ship recycling capacity. As outlined in our report Scrap Steel at Sea, ship scrap steel represents a valuable feedstock for steel producers, who, by using scrap instead of virgin materials, can achieve substantial savings in water and energy, reduction of CO2 emissions, while also reducing reliance on imported raw materials vulnerable to geopolitical disruptions. 

While the Industrial Maritime Strategy signals a step in the right direction, clear commitments are, however, needed to ensure that the targeted funds announced for the maritime industry give specific attention to developing a competitive European ship recycling sector.

The announced EU Industrial Maritime Value Chains Alliance could in that regard play a pivotal role by mapping existing ship recycling capacities, identifying the investments required to scale them up in response to the forthcoming surge of end-of-life vessels, and assessing the associated job creation potential.  

The strategic importance of the EU ship recycling sector in strengthening the bloc’s material resilience should furthermore be explicitly aligned with the other key policies, such as the Industrial Accelerator Act and Circular Economy Act. Finally, to effectively enable broader uptake of low-carbon maritime scrap-based or upcycled steel in lead markets, binding criteria for recycled content in public procurement [1] should be adopted.

The NGO Shipbreaking Platform supports the European Commission’s commitment to engage at the international level to strengthen the Hong Kong Convention [2] and align it with the EU Ship Recycling Regulation. However, while ensuring fair competition with third countries is one of the Commission’s main objectives, the Strategy does not address the unfair competition faced by EU ship recycling yards, including from substandard non-EU yards approved under the EU Ship Recycling Regulation. Also, as the Commission commits to "work with trading partners with ship-recycling capacity, starting with India [3], to foster high environmental and social standard”, the NGO Shipbreaking Platform warns that Indian shipbreaking yards still rely fully on the beaching method and that any rubberstamping of this lowest standard in ship recycling, not allowed in the EU, would undermine efforts aimed at boosting EU capacity and a level playing field that fosters fair competition.  

"India currently does not have the capacities to recycle ships in a safe and environmentally sound manner. EU cooperation with third countries, including India, on ship recycling, must be based on the enforcement of strict social, occupational health and environmental standards as applied in the EU, clearly banning harmful practices such as beaching or landing as practiced in South Asia and Turkey respectively. Besides, international and EU waste laws are clear on the illegality of exporting hazardous waste, including end-of-life ships, from the EU to India."
Ingvild Jenssen - Founder and Executive Director - NGO Shipbreaking Platform

The NGO Shipbreaking Platform stands ready to collaborate with the Commission and maritime stakeholders to implement the Industrial Maritime Strategy and go beyond to ensure that effective measures are in place to foster the safe and environmentally sound dismantling of all European ships. 

 

NOTES

 

[1] Additionally, as the Commission plans to leverage public procurement in relevant segments, such as ferries or research vessels, it should also consider making it mandatory for public vessels to be recycled within the EU. Notably, Germany currently sends its military ships for recycling in Aliağa, Turkey. 

[2] The Hong Kong Convention does not provide for safe and environmentally sound ship recycling as it lacks robust safety, environmental and labour protection standards, fails to prohibit the beaching method, and ignores the management and accountability of hazardous wastes downstream, rubber-stamping with that unsafe and polluting shipbreaking practices that continue to harm workers, local communities and fragile coastal ecosystems. 

[3] This only comes a few weeks after the EU announced planning to “pursue cooperation [with India] to support sustainable ship recycling activities.”