EU Ship Recycling Regulation: Evaluation and European List

The European Union’s Ship Recycling Regulation was designed to move end-of-life ships away from unsafe and environmentally damaging dismantling practices and into facilities that meet defined standards for worker safety, hazardous materials and pollution control. The European Commission’s 2025 evaluation concluded that the regime has largely achieved those objectives, but it also identified a weakness that goes to the heart of enforcement: a ship can change flag before recycling and thereby move outside the rules that would otherwise require an EU-listed facility.

For the superyacht sector, the issue is not theoretical. Regulation (EU) No 1257/2013 generally applies to ships of 500 gross tonnage and above flying the flag of an EU Member State, subject to specified exclusions. That brings many larger private and commercial yachts within the regime and makes the European List of ship recycling facilities relevant when an EU-flagged yacht reaches the end of its operating life.

The EU says the Regulation has largely worked

The evaluation found that the Ship Recycling Regulation had, to a large extent, achieved the objectives that could reasonably have been expected from EU action. Central to that conclusion was the creation of a controlled list of approved recycling facilities, backed by authorisation requirements in Member States and Commission assessment and inspection of facilities in third countries.

At the end of the evaluation period, the 12th edition of the European List contained 45 facilities: 35 in Europe, nine in Türkiye and one in the United States. The Commission concluded that inclusion on the list, together with the prospect of inclusion for applicant yards and the use of inspections, had contributed to higher environmental and social standards in ship recycling and had become a reference point beyond the EU itself.

The Regulation also helped drive implementation of the 2009 Hong Kong Convention. The Commission noted that the threshold for the Convention to enter into force was reached in 2023 and that almost half of the ratifications contributing to that threshold came from EU Member States, reinforcing the argument that the EU regime influenced standards beyond its own flag fleet.

Reflagging remains the biggest weakness

The strongest criticism in the evaluation concerns ships that change from an EU Member State flag to a third-country flag shortly before recycling. Once reflagged, those vessels are no longer caught by the core EU-flag recycling obligation and can be sold to facilities outside the European List, including yards offering higher prices for end-of-life tonnage.

The Commission quantified the problem by comparing the EU flag’s position in the world fleet with its presence at end of life. In 2023, EU-flagged vessels represented about 13% of the world fleet, but EU-flagged ships accounted for less than 7% of vessels at the point of recycling. The Commission linked that gap in part to pre-recycling flag changes.

Price is a major driver. The evaluation says facilities in South Asia have consistently been able to offer higher purchase prices for scrap ships, citing lower internalisation of environmental and social costs and strong demand for steel that can be re-rolled. As a result, the economic incentive to move a ship out of the EU flag regime can conflict directly with the environmental objective of the Regulation.

Hazardous-material inventories are the second enforcement gap

The Regulation requires ships within scope to maintain an Inventory of Hazardous Materials, or IHM, identifying regulated substances in the ship’s structure and equipment. For recycling, that information matters because dismantling teams need to know where asbestos, PCBs, heavy metals, oils, ozone-depleting substances and other hazards are located before cutting and removal begin.

The evaluation found significant weaknesses in this area. Voluntary data from port-state-control inspections between 2021 and 2023 indicated that 45% of inspected ships did not comply with the Regulation’s IHM-related requirements, and in most non-compliant cases the required inventory certificate or equivalent documentation for a third-country ship did not exist.

Even where an inventory is available by the time a ship reaches a recycling facility, the Commission found that quality and completeness are often insufficient. Its proposed direction is therefore not merely to demand more paperwork, but to strengthen the chain of responsibility covering the experts preparing inventories, supplier declarations, methodological guidance and the tools available to enforcement authorities.

The European List now contains 41 facilities

The European List is not static. The Commission updates it as facilities are added, renewed or removed, and the current 15th edition was adopted on 27 February 2026. According to the Commission, the updated list contains 41 ship recycling facilities: 30 in Europe, including the EU, Norway and the United Kingdom, 10 in Türkiye and one in the United States.

The 2026 update added Germany’s first listed facility, EWD Benli Recycling GmbH & Co. KG in Emden, and renewed the inclusion of facilities in Denmark, Estonia, Lithuania, Spain and Türkiye. It also removed three facilities: Turku Repair Yard in Finland after the facility chose not to renew its authorisation, Harland and Wolff in Belfast because the Commission had not received the information required for renewal, and Dortel in Türkiye after an inspection failed to confirm continued compliance.

The Dortel removal shows why the list is more than a directory. The Commission said inspectors observed primary hull cutting on the shoreline without an impermeable floor or slag collector and found insufficient measures to prevent waste generated during recycling from escaping to the sea and surrounding area. Removal therefore followed a specific compliance assessment rather than a simple expiry of paperwork.

What the list actually tells an owner or manager

Each entry in the European List sets out much more than a facility name and address. The annex records the recycling method, the types and maximum dimensions of ships that can be accepted, operational limitations, hazardous-waste conditions, the process for approval of a ship-specific recycling plan, maximum annual recycling output and the expiry date of the facility’s inclusion.

Those details matter for large yachts because a facility that is legally approved may still be unsuitable for a particular vessel. Length, beam, draught, lightweight, berth or dock dimensions and local handling methods can all determine whether an individual superyacht can physically and lawfully be accepted. An owner cannot assume that every yard on the list can take every yacht within the Regulation’s scope.

The current list includes facilities with very different capacities. For example, the 2026 annex records maximum ship lengths of 366 metres for NV Galloo in Belgium, 415 metres for FAYARD in Denmark and 200 metres for Smedegaarden in Denmark, while smaller facilities have much lower dimensional limits. That diversity means the list provides regulatory eligibility, but project feasibility still requires a yard-specific technical review.

Why the Regulation matters specifically to superyachts

The Regulation excludes ships below 500 GT, so many smaller yachts fall outside its main scope. Larger superyachts, however, increasingly exceed that threshold, and an EU-flagged yacht above 500 GT can therefore face the same end-of-life recycling obligations as a commercial vessel, notwithstanding the very different way in which it has been operated during its life.

For a non-EU-flagged yacht, the position is different. Article 12 applies to third-country ships calling at an EU port or anchorage and brings hazardous-material inventory obligations into play, but the requirement to use a facility on the European List when the vessel is recycled is tied to ships flying a Member State flag. Flag choice therefore has practical regulatory consequences long before a yacht is physically dismantled.

That distinction also explains why the Commission is concerned about reflagging. A flag change can be entirely legitimate during a yacht’s operational life, but if it occurs shortly before recycling and has the effect of moving the vessel outside the EU regime, it can undermine the environmental and worker-safety objectives that the Regulation was created to enforce.

The next pressure point is enforcement, not capacity

The evaluation found that the European List provided sufficient capacity for ships within scope during the period studied, including enough capacity to cover ships that had changed flag in the year before dismantling. The Commission’s concern is therefore less about whether listed yards exist and more about whether owners actually use them when the law requires it.

Capacity will still matter in the longer term because the volume of ship recycling is expected to increase significantly over the next decade. The Commission said the list will need to keep growing, while standards may need further clarification so that facilities inside and outside the EU are assessed against a consistent level of pollution control, waste management and steel-recovery performance.

What owners should take from the evaluation

For superyacht owners, family offices, managers and technical teams, the practical lesson is that end-of-life planning should begin before a yacht is marketed for recycling. Flag status, gross tonnage, hazardous-material documentation, the condition of the vessel and the acceptance limits of potential recycling yards can all determine what options remain legally available when the yacht is no longer viable to operate or sell.

The 2025 evaluation does not suggest that the European system has failed. Instead, it presents a framework that has raised standards and created a transparent pool of approved facilities, while acknowledging that enforcement can be defeated when ships leave the EU flag regime before recycling and when hazardous-material inventories are missing or unreliable.

The current 41-facility European List gives owners a defined starting point, but not an automatic solution. For a large superyacht approaching the end of its life, responsible recycling still requires matching the individual vessel to a suitable listed facility, preparing accurate hazardous-material information and maintaining a regulatory trail that can withstand scrutiny from the decision to recycle through to final dismantling.