About
Under the EU Ship Recycling Regulation, ships exceeding 500 GT (with a few exceptions) flying the flag of EU/EEA member states are only allowed to be recycled at certain pre-approved safe and sound ship recycling facilities included in the European List.
- On 18 February 2025, the European Commission adopted the 14th edition of the European List of ship recycling facilities. The European List currently contains 43 shipyards, of which 31 are within the EU/EEA and the UK, 11 are in Turkey, and 1 is in the USA. No yards in India, Pakistan or Bangladesh have so far obtained EU approval.
- The 15th edition of the European List of ship recycling facilities is scheduled for Commission adoption in the fourth quarter of 2025 but has not yet been adopted as of early December 2025.
For a ship recycling facility to be included in the European List, it must, irrespective of its location, comply with several safety and environmental requirements. The European Commission has issued technical guidelines on these requirements.
Further, all EU/EEA flagged vessels and non-EU ships calling at an EU port or anchorage must carry on board an Inventory of Hazardous Materials ('IHM'), which in short is a document listing all possible hazardous materials contained on the vessel.
Who does it impact?
The Regulation applies to ships of above 500 GT flying the flag of EU/EEA member states (with a few exceptions), and all EU-flagged ships as well as ships from third countries calling at an European port or anchorage. There are certain exceptions including e.g., warships and ships operating throughout their life only in waters subject to the sovereignty or jurisdiction of the member state whose flag the ship is flying.
After the UK left the EU, the requirements of the EU Ship Recycling Regulation has been retained in UK domestic legislation.
The Regulation affects ship-owners and ship recycling facilities.
Status: In force
The EU adopted the Ship Recycling Regulation on 20 November 2013. Certain provisions of the Regulation went into effect on 1 January 2015, but the Regulation entered fully into force from 2019.
The EU Ship Recycling Regulation was incorporated into the EEA Agreement on 6 December 2018.
Relation to other initiatives and regulations
- The relation between the EU Ship Recycling Regulation and the EU Waste Shipment Regulation is established in such a way that the EU Waste Shipment Regulation does not apply to ships covered by the EU Ship Recycling Regulation. However, if ships are sent directly from the jurisdiction of a Member State for scrapping in a non-OECD country, it will apply. Currently, there are no shipyards on the European List in non-OECD countries.
- The Regulation has been implemented into Norwegian law by the Regulations of 6 December 2018 No. 1813 on ship recycling and by amendments to the Regulations of 24 November 2014 No. 1458 on port State control (together referred to as the Norwegian Ship Recycling Regulation). Ships exceeding 500 GT (with a few exceptions) flying a NOR and NIS flag may only be recycled at recycling facilities on the European List.
Participants
EU/EEA States
Thommessen's comments
Although the EU Ship Recycling Regulation is broadly in line with the Hong Kong Convention, there are some important differences:
EU-flagged ships covered by the EU Ship Recycling Regulation are excluded from the scope of the EU Waste Shipment Regulation, but only if the ship is outside of the jurisdiction of an EU Member State.
Some legal precedent from courts in EU Member States suggests that the relevant point in time for determining when a vessel is considered "waste" is the moment the decision is made to scrap it. Consequently, if this decision occurs while the vessel is within EU territory, the EU Waste Shipment Regulation applies—even if the vessel continues to operate for some time before being sent for scrapping. It is the flag of the vessel at the time it is sold for recycling that will determine whether the EU Ship Recycling Regulation is applicable. Thus, there have been concerns among authorities that ship-owners potentially may change the flag of an ageing vessel to a non-EU/EEA state before selling the vessel for recycling, to try to circumvent the EU Ship Recycling Regulation.
In practice, the application of the EU Waste Shipment Regulation to vessels exported from an EU Member State currently has no implications if the vessel is also subject to the EU Ship Recycling Regulation, as there are currently no yards on the European List of ship recycling facilities ('European List') in non-OECD countries.