WSC response to the European Commission's Public Consultation on "Ship recycling – European list of ship recycling facilities (15th edition)”

The World Shipping Council (WSC), representing over 90% of global liner shipping capacity, welcomes the opportunity to comment on the draft 15th edition of the European List of Ship Recycling Facilities. We appreciate the Commission’s continued work to strengthen environmental and safety outcomes in ship recycling and recognise the complexity of maintaining a robust and globally relevant List.

Ensuring global capacity to meet fleet recycling needs

WSC acknowledges the proposed updates to the list. At the same time, it appears that the current geographic distribution and capacity of approved facilities would not be sufficient to meet the long-term recycling needs of the global liner fleet, particularly large container and vehicle carriers.

A predictable and efficient process for evaluating facilities globally, and listing those that meet the requirements of the EU Ship Recycling Regulation (EU SRR), would help ensure that compliant, safe, and environmentally sound recycling capacity is available where it is needed. Such predictability allows shipowners to plan with confidence and reinforces the European Union’s role in shaping higher standards worldwide.

Consistent and transparent assessment standards

WSC appreciates the Commission’s commitment to applying high environmental and safety standards. Consistency and transparency in the assessment and monitoring of facilities are important for maintaining confidence in the integrity of the list.

Applying the same rigorous and evidence-based criteria to all facilities, whether located in the European Union or outside it, strengthens the credibility of the list, ensures a level playing field and supports continuous improvement across regions. This alignment enhances stakeholder confidence and underscores the European Union’s commitment to high standards rather than geography.

Alignment with the global regulatory framework

The entry into force of the Hong Kong International Convention for the safe and environmentally sound recycling of ships (HKC) in 2025 represents a major milestone for global ship recycling. WSC recognises the important role of European Union leadership in supporting revisions to the Hong Kong Convention, which are essential for strengthening international ship recycling safety and sustainability standards.

As global frameworks evolve, ensuring coherence between the EU SRR, the HKC and Basel Convention obligations becomes increasingly important. Reducing unnecessary regulatory overlap enhances effectiveness, provides clarity for shipowners and authorities and supports the objective of establishing a strong and globally relevant standard.

Supporting the implementation and evolution of the Hong Kong Convention as the primary global framework remains an essential step toward improving ship recycling outcomes worldwide.

Ship recycling as part of fleet renewal and decarbonisation

Safe and sustainable ship recycling underpins the broader energy transition. Access to compliant recycling capacity is critical for enabling fleet renewal and accelerating the introduction of vessels capable of operating on low and zero greenhouse gas fuels.

Expanding access to facilities that comply with the EU Ship Recycling Regulation at global level, together with alignment under a strengthened Hong Kong Convention, supports both environmental protection and decarbonisation objectives.

Read WSC’s full response here.

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