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.