Ship recycling - European list of ship recycling facilities (16th edition)

61 submissions in the snapshot (52 from organisations), portal total 61. Feedback list on the portal.

51 of 52 organisation submissions analysed; the model reads them as: opposes 18 supports 13 wants changes 10 10 held back for review (low confidence). 1 without readable text, so not analysed.

• SOLUTION OVERALL FOR SHIPPING SOS INDIA PRIVATE LIMITED Company, IND model reads as: supports source
  • Include YSI Recyclers LLP and Shree Ram Vessel Scrap on the European List.

    I support the inclusion of YSI Recyclers LLP (Plot 59), India and Shree Ram Vessel Scrap Pvt. Ltd/Shree Ram Shipping Industries Pvt. Ltd.(Plot 78/81), India in the European List.

  • Give due weight to the multi-year assessment record and recognize yard investments in meeting EU standards.

    We ask the Commission to give due weight to this multi-year, evidence-based assessment record in its final decision, and to recognize the sustained investment these facilities have made to meet EU standards.

• Royal Association of Netherlands Shipowners Business association, NLD model reads as: supports source
  • Adopt the proposed inclusion of the two Indian recycling facilities on the European List.

    KVNR welcomes the proposed inclusion of YSI Recyclers LLP and Shree Ram Vessel Scrap Pvt. Ltd./Shree Ram Shipping Industries Pvt. Ltd. in India.

• Danish Shipping Business association, DNK; register: Trade and business associations model reads as: supports source
  • Support the proposed inclusion of the two Indian ship recycling facilities on the European List.

    Danish Shipping welcomes the European Commissions proposal and calls on the EU Member States and the European Parliament to support the proposed inclusion of the two Indian ship recycling facilities on the European list of ship recycling facilities.

  • Continue assessing and recognising facilities that meet applicable requirements regardless of geography.

    Danish Shipping encourages the Commission to continue assessing and recognising facilities that meet the applicable requirements.

• Transport & Environment (T&E) NGO, BEL; register: Non-governmental organisations, platforms and networks and similar model reads as: opposes source
  • Reject the inclusion of beaching yards from India on the European List.

    T&E is particularly concerned by the inclusion on the list of two shipbreaking yards in India, YSI Recyclers LLP and Shree Ram Vessel Scrap Pvt., which rely on the beaching method for dismantling vessels.

  • Prohibit beaching as an acceptable method for dismantling EU ships in third countries.

    This method is not allowed in any EU Member State and should not be allowed as a licit method for dismantling EU ships in third countries either.

• Kishorn Port Ltd Company, GBR model reads as: opposes source
  • Reject the proposed inclusion of YSI Recyclers LLP and Shree Ram Vessel Scrap Pvt. Ltd on the European List.

    The proposed inclusion of YSI Recyclers LLP and Shree Ram Vessel Scrap Pvt. Ltd on the European List should be rejected because both yards operate within the Alang-Sosiya beaching system, where vessels are dismantled directly on tidal mudflats.

  • Support only facilities that deliver genuinely equivalent environmental and safety outcomes without legitimising beaching operations.

    The European List should support facilities that deliver genuinely equivalent environmental and safety outcomes, not legitimise beaching-based operations that externalise pollution and undermine high-standard ship recycling capacity within Europe and the United Kingdom.

• Micro company, ESP Environmental organisation, ESP model reads as: opposes source
  • Exclude Indian beaching shipbreaking yards from the EU list of approved ship recycling facilities.

    Sustainable Life Foundation opposes the inclusion of Indian beaching Shipbreaking yards on the EU list of ship recycling facilities.

    machine translation by the Commission, original in ES
  • Do not approve recycling practices in third countries that are prohibited within the European Union.

    The EU must not rubberstamp practices in third countries that they would not allow in their own country.

    machine translation by the Commission, original in ES
• European Shipowners | ECSA Business association, BEL; register: Trade and business associations model reads as: supports source
  • Add the two proposed Indian yards to the updated European list of approved ship recycling facilities.

    European Shipowners | ECSA (ES|ECSA) strongly welcomes the European Commissions proposal to add two Indian yards to the updated European list of approved ship recycling facilities (16th edition).

• LEGAMBIENTE NGO, ITA model reads as: opposes source
  • Remove Indian beaching facilities from the proposed list.

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

  • Ensure consistency with Basel Convention obligations regarding hazardous waste trade.

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

  • Apply uniform standards across all listed facilities regardless of their geographical location.

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

• Micro company, POL NGO, POL model reads as: opposes source
  • Do not include Indian shipyards practising beaching on the European List.

    we expect that the Commission, or the EU Member States, will not place these shipyards on the List, which aims to bring together shipyards with the best and safest ship recycling practices.

    machine translation by the Commission, original in PL
  • Refrain from legitimising ship recycling methods that are not permitted within the European Union.

    the European Union cannot legitimise methods that it does not allow on its own territory;

    machine translation by the Commission, original in PL
  • Promote best practices aligned with environmental protection and worker safety without disadvantaging compliant EU shipyards.

    We believe that the European Union should seek to promote best practices in line with the stated objectives of the Regulation - environmental protection and worker safety.

    machine translation by the Commission, original in PL
• European Environmental Bureau (EEB) NGO, BEL model reads as: opposes source
  • The European Environmental Bureau calls for the immediate withdrawal of the proposal to include beaching yards in the 16th European list.

    the European Environmental Bureau calls for the immediate withdrawal of the European Commissions proposal to include beaching yards in the 16th European list of ship recycling facilities.

• Recycling Europe Business association, BEL; register: Trade and business associations model reads as: opposes source
  • Oppose the addition of the two Indian beaching yards to the European List.

    Recycling Europe strongly opposes the inclusion of two beaching yards located in India, YSI Recyclers LLP and Shree Ram Vessel Scrap Pvt.

• Wirtschaftsvereinigung Stahl Business association, DEU; register: Trade and business associations model reads as: opposes source
  • Do not include the two Indian beaching facilities in the European List.

    The Wirtschaftsvereinigung Stahl (German Steel Association) calls on the Commission not to include the two Indian beaching facilities in the European List.

  • Strengthen existing European ship recycling capacities operating under the highest standards.

    strengthen the existing European ship recycling capacities which are working on the highest standards and secure valuable secondary raw materials for European steel production.

  • Retain valuable steel scrap within Europe by establishing a monitoring system for scrap flows and boosting domestic sources.

    The EU should pursue the strategic objective of retaining valuable steel scrap within Europe by establishing an effective monitoring system for scrap flows and by increasing the domestic scrap sources.

• Micro company, CYP Business association, CYP model reads as: supports source
  • Explicitly allow EU-flagged vessels to be recycled in compliant non-OECD facilities on the EU list even if the recycling decision occurs in EU waters.

    the Chamber proposes that it should be explicitly possible for EU-flagged ships, when the decision for recycling is taken while the ship is in EU waters, to be recycled in facilities located outside the OECD, provided that such facilities are compliant with EU SRR and have been added to the EU list.

  • Continue cooperating with the IMO and adding compliant non-OECD yards to the EU list.

    Continuing cooperation with the IMO to ensure high standards in non-OECD facilities, and supporting their evaluation and inclusion on the EU list, is of utmost importance to address the lack of sufficient and geographically realistic capacity.

• Merchant Shipping Directorate Public authority, MLT model reads as: supports source
  • Support the inclusion of non-OECD ship recycling facilities in the European List.

    We support the Commission's proposal to include, for the first time, ship recycling facilities located in a non-OECD country.

• NABU (Naturschutzbund Deutschland) e.V. NGO, DEU; register: Non-governmental organisations, platforms and networks and similar model reads as: opposes source
  • Exclude Indian ship recycling facilities YSI Recyclers LLP and Shree Ram Vessel Scrap Pvt. from the 16th EU list.

    NABU opposes the inclusion of the Indian ship recycling facilities YSI Recyclers LLP and Shree Ram Vessel Scrap Pvt. in the 16th EU list of ship recycling facilities.

    machine translation by the Commission, original in DE
  • Ensure ships are recycled in Europe to secure raw materials and maintain high environmental standards.

    Recycling European ships within Europe can make an important contribution to securing the EU’s raw materials.

    machine translation by the Commission, original in DE
• Ministry for Sustainable Mobility, MALTA Public authority, MLT model reads as: supports source
  • Include ship recycling facilities located in non-OECD countries on the European List.

    Malta supports the Commission's proposal to include, for the first time, ship recycling facilities located in a non-OECD country.

  • Recognise high-quality facilities that comply with environmental, safety, and operational standards.

    Malta has consistently advocated for a pragmatic and evidence-based approach to the implementation of the EU Ship Recycling Regulation, including the recognition of high-quality recycling facilities that demonstrably comply with the Regulation's environmental, safety and operational requirements.

• Government of Malta Public authority, MLT model reads as: supports source
  • Include ship recycling facilities located in non-OECD countries on the European List.

    Malta supports the Commission's proposal to include, for the first time, ship recycling facilities located in a non-OECD country.

  • Recognise high-quality facilities that comply with environmental, safety, and operational standards.

    Malta has consistently advocated for a pragmatic and evidence-based approach to the implementation of the EU Ship Recycling Regulation, including the recognition of high-quality recycling facilities that demonstrably comply with the Regulation's environmental, safety and operational requirements.

• NGO Shipbreaking Platform NGO, BEL; register: Non-governmental organisations, platforms and networks and similar model reads as: opposes source
  • Withdraw the proposal to add the two Indian beaching yards to the European List.

    Urge the European Commission to withdraw the proposal to include two Indian beaching yards on the European List.

  • Exclude all Turkish ship recycling practices that are not authorised in the EU.

    urge the EU to effectively exclude from the European List all practices in Turkey that would not be authorised in the EU.

  • Base the inclusion of third-country yards on the revised and updated Technical Guidance Note.

    inclusion of any new third country yard should furthermore be based on the revised and updated Technical Guidance Note to effectively ensure equivalency with existing EU obligations and standards.

• Micro company, BEL Company, BEL model reads as: opposes source
  • Refrain from adding YSI Recyclers LLP and Shree Ram Vessel Scrap Pvt. Ltd. to the European List.

    Marine Metals therefore respectfully urges the Commission to refrain from including the proposed facilities of YSI Recyclers LLP and Shree Ram Vessel Scrap Pvt. Ltd. on the European List.

• Green Yard Group AS Company, NOR model reads as: opposes source
  • Do not include the two Indian beaching yards in the 16th edition of the European List.

    We urge the Commission NOT to include the two Indian beaching yards (Shree Ram, plot 78/81; YSI Recyclers, plot 59) in the 16th edition of the European List.

  • Defer the decision until key issues are transparently documented and enforce identical physical containment criteria across all yards.

    Alternatively, defer the decision until key matters are documented transparently and verifiably, and require that the same physical containment requirements apply to every listed facility, regardless of location.

  • Keep beaching facilities off the European List, apply consistent physical requirements, and prioritise European capacity-building.

    We ask the Commission to keep beaching off the European List, apply the same physical requirements to all facilities wherever located, and prioritise European capacity-building.

• Micro company, IRL NGO, IRL model reads as: wants changes source
  • Consider complementary measures to improve accessibility and support for small-scale fishing vessel owners.

    The Commission should consider whether future implementation of the Ship Recycling Regulation could be complemented by measures that improve accessibility for small-scale fishing vessel owners, including support for transport, regional recycling capacity where appropriate, or targeted assistance for environmentally responsible vessel disposal.

• Lisnave Estaleiros Navais S.A. Company, PRT model reads as: opposes source
  • Do not certify or include non-compliant facilities on the European List.

    Certifying non-compliant facilities presents an unacceptable case of unfair competition against any compliant yard anywhere in the world.

  • Base approval of ship recycling facilities strictly on technical and legal criteria.

    The approval of any Ship Recycling facility must be based on strict technical and legal criteria, not on geographic location.

• Danske Maritime Business association, DNK; register: Trade and business associations model reads as: wants changes source
  • Ensure continuous compliance over time through strengthened and unannounced monitoring.

    Listing should guarantee continuous compliance over time, not com-pliance at a single point of inspection, backed by strengthened and, where necessary, unannounced monitoring;

  • Establish a level playing field encompassing the full regulatory and economic framework.

    A level playing field should cover the full regulatory and economic framework under which facilities compete, not merely the minimum listing criteria;

  • Strengthen the traceability of recovered materials to retain strategic resources within European value chains.

    Circularity and supply security call for stronger traceability of recov-ered materials, so that these strategic resources are, where possible, retained within European value chains;

• ARMATEURS DE FRANCE Business association, FRA; register: Trade unions and professional associations model reads as: supports source
  • Include compliant non-OECD facilities on the European List to address the ship recycling capacity gap.

    Armateurs de France supports the inclusion on the European List of facilities located outside the OECD whenever they can demonstrate full compliance with EU requirements.

  • Continue and accelerate the assessment of other non-OECD facilities seeking inclusion on the European List.

    Armateurs de France therefore encourages the Commission to continue and accelerate the assessment of other non-OECD facilities seeking inclusion on the European List and to devote sufficient resources to this process.

  • Promote international harmonisation of the ship recycling regulatory framework around the Hong Kong Convention.

    More broadly, Armateurs de France supports greater international harmonisation of the ship recycling regulatory framework around the Hong Kong Convention, while maintaining ambitious requirements for worker safety and environmental protection.

• Fornæs ApS Company, DNK model reads as: wants changes source
  • Postpone the inclusion of Shree Ram and YSI Recyclers until compliance is proven during operations and throughout downstream treatment.

    We therefore recommend that their inclusion on the European List is postponed until full compliance has been demonstrated during actual ship recycling operations and throughout the complete downstream waste-treatment chain.

• NOVA HUT Company, CZE model reads as: wants changes source
  • Reconsider the inclusion of the two Indian facilities in the current update.

    recommend the commission and the Member States to reconsider the inclusion of the two Indian facilities in this update

  • Condition any future listing of facilities using the beaching method on verified, on-site evidence of compliance with Article 13 of Regulation (EU) No 1257/2013.

    make any future listing of facilities using the beaching method conditional on verified, on-site evidence that the requirements of Article 13 of Regulation (EU) No 1257/2013 are met at the time of the decision, including the environmentally sound management of the steel and hazardous waste streams leaving the yard.

• The European Steel Association (EUROFER) Business association, BEL; register: Trade and business associations model reads as: wants changes source
  • Reconsider the inclusion of the two Indian facilities in this update.

    EUROFER invites the Commission and the Member States to reconsider the inclusion of the two Indian facilities in this update

  • Require verified, on-site proof of Article 13 compliance before listing any beaching facilities in the future.

    make any future listing of facilities using the beaching method conditional on verified, on-site evidence that the requirements of Article 13 of Regulation (EU) No 1257/2013 are met at the time of the decision, including the environmentally sound management of the steel and hazardous waste streams leaving the yard.

• Steel Union of the Czech Republic Business association, CZE model reads as: wants changes source
  • Reconsider including the two Indian facilities in the current update.

    recommends the commission and the Member States to reconsider the inclusion of the two Indian facilities in this update

  • Make future listings of beaching facilities conditional on verified on-site evidence of compliance with Article 13 requirements.

    make any future listing of facilities using the beaching method conditional on verified, on-site evidence that the requirements of Article 13 of Regulation (EU) No 1257/2013 are met at the time of the decision, including the environmentally sound management of the steel and hazardous waste streams leaving the yard.

• International Association of Independent Tanker Owners (INTERTANKO) NGO, GBR model reads as: supports source
  • Support the inclusion of Indian yards in the 16th European List.

    This proposal represents a significant and positive development.

• GUJARAT MARITIME BOARD Public authority, IND model reads as: supports source
  • Include the two Alang ship recycling facilities in the European List.

    support of the proposed inclusion of the two Alang ship recycling facilities

• AF Offshore Decom AS Company, NOR model reads as: opposes source
  • Do not include the proposed Indian facilities on the EU list at this stage, or postpone the decision until matters are transparently documented.

    AF Offshore Decom recommends that the proposed facilities are not included on the EU list at this stage, or alternatively that a decision is postponed until key environmental, HSE and operational matters have been documented in a more transparent and verifiable manner.

  • Apply the same environmental, safety, and pollution control standards to all facilities regardless of location.

    Our response emphasises that the same environmental, safety and pollution control standards should apply to all facilities, regardless of location.

  • Prioritise measures strengthening European ship recycling capacity, secondary raw materials access, and circular value chains.

    AF Offshore Decom also emphasises that Europe should prioritise measures that strengthen European ship recycling capacity, secure access to secondary raw materials, and support circular value chains in line with the EUs objectives for the circular economy, industrial policy and raw materials security.

• Bangladesh Environmental Lawyers Association NGO, BGD model reads as: opposes source
  • Withdraw the proposal to include two Indian beaching yards on the European list.

    we strongly urge the withdrawal of this proposal and reconsider the inclusion of these two yards.

  • Promote high standards for ship recycling industries worldwide and ensure compliance in third countries.

    We call on the European Commission to be a standard bearer around the world in promoting high standards for ship recycling industries and ensuring compliance with those standards even in third countries.

• Micro company, NOR Company, NOR model reads as: wants changes source
  • Reconsider the inclusion of the two Indian ship recycling facilities in the updated European List.

    Nordic Circles respectfully invites the Commission and the Member States to reconsider the inclusion of the two Indian facilities in this update.

  • Build decommissioning capacity within the EU instead of exporting end-of-life vessels.

    EU should build capacity in decommission, not export it.

  • Support the scaling up of circular and decarbonisation-driven innovations in ship steel upcycling.

    The Commission and Member States should support the scale-up of this kind of circular, decarbonisation-driven innovation, in line with the objectives of the EU Clean Industrial Deal and the forthcoming Circular Economy Act.

• BIMCO Business association, DNK; register: Trade and business associations model reads as: supports source
  • Include the two Indian ship recycling facilities on the European List.

    BIMCO welcomes the proposed inclusion of two additional Indian ship recycling facilities on the European List, while underlining the need for the EU framework to better recognise facilities authorised under the IMO Hong Kong International Convention and avoid duplication and regulatory fragmentation.

• Maritime & Offshore NL Business association, NLD; register: Trade and business associations model reads as: opposes source
  • Refrain from adding further yards to the European List at this stage.

    Maritime & Offshore NL welcomes the oppertunity to contribute to this draft act but urges the European Commission to refrain from adding further yards to the European List at this stage.

  • Conduct a thorough market and value-chain assessment aligned with European green industrial policies.

    Maritime & Offshore NL recommends a thorough market and value-chain assessment aligned with overall industrial green policies, such as the European Industrial Maritime Strategy (EIMS), Critical Raw Materials Act (CRMA) and Industrial Accelerator Act (IAA), structured around three mutually reinforcing pillars:

• industriAll Europe Trade union, BEL model reads as: wants changes source
  • Include and retain facilities on the European List only if full compliance in practice is demonstrated throughout the listing period.

    industriAll Europe calls on the Commission to ensure that facilities are included on, and remain on, the European List only where they can demonstrate full compliance in practice and throughout their period of listing.

  • Ensure frequent and rigorous inspections with prompt corrective action or removal for recurring deficiencies.

    Inspections should be sufficiently frequent and rigorous, with recurring deficiencies leading to timely corrective action and, where necessary, removal from the List.

  • Ensure ship recycling promotes worker and environmental protection, a level playing field, and European capacity rather than outsourcing to weaker standards.

    The EU must ensure that sustainable ship recycling contributes to worker protection, environmental protection, a level playing field and the development of European industrial capacity, rather than encouraging the continued outsourcing of ship recycling to lower-cost facilities operating under weaker standards.

• Micro company, MLT NGO, MLT model reads as: wants changes source
  • Incorporate Social Impact Assessment explicitly alongside environmental and technical criteria in the Ship Recycling Regulation.

    The MSA recommends that the implementation and future evaluation of the Ship Recycling Regulation explicitly incorporate Social Impact Assessment (SIA) alongside environmental and technical criteria.

  • Promote high standards of workers' rights, occupational health and safety, and decent working conditions within approved facilities.

    The MSA also encourages the European Commission to continue promoting high standards of workers' rights, occupational health and safety, and decent working conditions within approved ship recycling facilities.

  • Consider the wider social impacts of ship recycling in future evaluations.

    The MSA further recommends that future evaluations consider the wider social impacts of ship recycling, including employment quality, community wellbeing, environmental justice, and the protection of vulnerable workers.

• Ship Recycling Industries Association (India) Other, IND model reads as: supports source
• Micro company, NLD Other, NLD model reads as: opposes source
  • Reconsider adding Shree Ram and YSI to the EU List of approved ship recycling facilities.

    ISRA requests the European Commission to reconsider the two Indian ship recycling facilities , Shree Ram and YSI , to be placed on the EU List of approved ship recycling facilities.

• Micro company, FRA NGO, FRA model reads as: wants changes source
  • Include ship recycling facilities only when verified compliance and strong performance are demonstrated.

    Green Marine Europe calls for the inclusion of shiprecycling facilities only when they demonstrate verified compliance with EU requirements and strong environmental and social performance.

  • Establish higher-ambition criteria including enhanced transparency, continuous improvement, and complementary certifications.

    We advocate for higherambition criteria, including enhanced transparency, continuous improvement mechanisms, and complementary certifications that attest to operational excellence.

• Verband für Schiffbau und Meerestechnik e.V. Business association, DEU model reads as: opposes source
  • Ensure the European List update does not grant EU-listed status to lower-cost facilities operating under conditions disallowed in the EU.

    VSMs key concern is that the update of the European List of ship recycling facilities must not intensify the uneven playing field by granting EU-listed status to significantly lower-cost facilities whose competitive advantages are largely based on practices and regulatory conditions that would not be permitted in the EU.

  • Ensure EU listing decisions support a level playing field to maintain viable European ship recycling capacity.

    Europe needs economically viable ship recycling capacity for strategic autonomy, raw material resilience and circular industrial value chains. This will only be possible, if EU listing decisions support a level playing field.