Ship Recycling (previous End of Life Ships)

Project description and aims

In 2017, 65% of ships/vessels worldwide were sold to South-Asian beaching yards for dismantling (e.g. India, Pakistan and Bangladesh) which translates into significant environmental and health impacts, especially if it is taken into account that those vessels amounted 80% gross tonnage of all dismantled ships beached in 2017. The illegal export of ships for beaching in South Asia is still going on, as well as the circumvention of the waste shipment and ship recycling regulations. Bangladesh, India and Pakistan amounting almost 90% of the gross tonnage dismantled globally in 2019, and some of these ships has been either exported illegally from Europe, or “legally” by circumvention of the regulations.

This IMPEL project does not focus on beaching itself, but how we can prevent illegal export of ships in the EU and how we as authorities can follow up illegal cases where ships already have been beached.

Regulation (EC) No 1013/2006 on shipments of waste (WSR) implements at European level the requirements of the Basel Convention. The ship recycling regulation (EU) No 1257/2013 (SRR) brings forward the requirements of the Hong Kong Convention, and regulates EU-flagged ships sent for recycling. The SRR claims that EU-flagged ships must be recycled at facilities authorised by the country of destination in the member states countries, or by the Commission in third countries. Shipments of ships under non-EU-flag shall be subject to the procedure of prior written notification, under the WSR.

Ship owners systematically circumvent WSR, and the regulation is difficult to enforce, due to the practice of rename, reflagging and change of owners before the ships are sent for dismantling and recycling. The SRR are easy to escape as long as the practice of change to a non-EU flag continues. The Hong Kong Conventions will apply for all ships (no matter EU or non-EU-flag), but the convention is not yet ratified, and it can take ages before it happens.

The challenge is to prevent illegal ship recycling by following up ships and shipowners where we suspect circumvention of the regulations, and preferably take actions on beforehand. To make it easier for case handlers and inspectors it will be important to:

• Clarify the differences between Waste Shipment Regulation and Ship Recycling Regulation
• Share practical knowledge (court cases, documents, reports, experiences)
• Develop guidance/leaflets on how to detect and reduce illegal shipment of ships
• Use IMPEL’s intranet as a knowledge sharing platform and knowledge exchange, and gather best practise

The final report will give the state of actual situation and synthesize guidelines and guidance on enforcement practices on WSR vs SRR.