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

Please find attached AF Offshore Decoms consultation response regarding the European Commissions proposal to include two Indian ship recycling facilities on the European List of approved ship recycling facilities.

International Ship Recycling Association Subject Comments as part of the “Have your say” -procedure related to the draft Implementing Decision, 16th update, of the European Commission. This update, amongst other things, proposes to admit two Indian-based facilities on the EU-List of approved ship recycling facilities (EU-List). The facilities concerned are: • Shree Ram Vessel Scrap Pvt. Ltd; • YSI Recyclers L.L.P.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

29 August 2026 Position EISAP – Ship Recycling: On the current draft update of the EU list of approved recycling sites according to EU Ship Recycling Regulation ((EU) 1257/2013) and replacement of Annex to Implementing Decision (EU) 2016/2323. Members of EISAP are European and international shipowners with at least one ship of their fleet registered in Madeira and operating under the flag of Portugal.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

This significant achievement reflects the dedicated hard work, visionary guidance, and proactive support of the Prime Ministers Office (PMO), the Ministry of Ports, Shipping and Waterways (MoPSW), the Directorate General of Shipping (DG Shipping), and the Gujarat Maritime Board (GMB), working side-by-side with SRIA.

The Malta Sociological Association (MSA) notes the proposed update to the European List of Ship Recycling Facilities and recognises its importance in promoting environmentally sound and safe ship recycling across the European Union.

Gujarat Maritime Board, Government of Gujarat, India, welcomes the opportunity to place its views on the draft Implementing Decision concerning the 16th Edition of the European List of Ship Recycling Facilities. GMBs feedback in support of the proposed inclusion of the two Alang ship recycling facilities is attached.

Owners of ships sailing under the flag of an EU country are legally obliged to have them dismantled (at the end of their operational life) in yards that are approved under EU health and environmental standards. This initiative updates the list of recycling sites approved with the requirement to publicly report on recycled content for each ship.

Filed in Italian · English published by the European Commission

Feedback from Green Yard Group AS, operator of two Norwegian ship recycling yards currently on the European List (Green Yard Feda; Green Yard Kleven). Full argumentation and sources are in the attached PDF. 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.

The Directorate General of Maritime Administration, Ministry of Ports, Shipping and Waterways, Government of India appreciates the opportunity to provide feedback on the draft Implementing Decision concerning the 16th edition of the European List of Ship Recycling Facilities. Feedback is attached herewith.

Marine Metals welcomes the opportunity to comment on the European Commissions public consultation regarding the draft Implementing Decision for the 16th update of the European List of Ship Recycling Facilities, in particular the proposed inclusion of YSI Recyclers LLP and Shree Ram Vessel Scrap Pvt. Ltd., two ship recycling facilities located in India.

The industriAll European Trade Union aims to develop common views and positions with its affiliates in order to build up efficient strategies to defend the economic, social and cultural interests of the workers in these industries on a basis of solidarity, mutual respect and common principles.

The NGO Shipbreaking Platform, a global coalition of human rights and environmental organisations, works to ensure safe and environmentally sound ship recycling world-wide. We welcome the opportunity to contribute to this public consultation and call on the European Commission to hold facilities in third countries accountable to the same standards as those applicable in the EU.

Ship recycling MT feedback on draft 16th edition of the EU list Malta thanks the European Commission for the draft implementing act concerning the 16th update of the European list of ship recycling facilities and would like to provide the following feedback.

Ship recycling MT feedback on draft 16th edition of the EU list Malta thanks the European Commission for the draft implementing act concerning the 16th update of the European list of ship recycling facilities and would like to provide the following feedback.

28 August 2026 INTERTANKO is pleased to comment on the proposed inclusion of Indian yards in the 16th European List of approved ship recycling facilities. This represents a significant and positive development. Signal to Asian yards The inclusion of two Indian yards on the EU Ship Recycling List provides a clear and constructive indication to high-quality yards across Asia that EU listing is attainable.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

NABU (Naturschutzbund Deutschland) e.V. is grateful for the opportunity to comment on the draft implementing decision. 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.

Filed in German · English published by the European Commission

CMA CGM Group’s contribution on the proposed 16th European List of Ship Recycling Facilities As the world’s third-largest container shipping company and a major operator of EU-flagged vessels, CMA CGM is fully committed to ensuring that its ships are recycled in facilities meeting the highest environmental, occupational safety and social standards.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

We thank the European Commission for the draft implementing act concerning the 16th update of the European list of ship recycling facilities. The continued expansion of the European List of ship recycling facilities is essential to ensuring sufficient ship recycling capacity for EU-flagged vessels, supporting the effective implementation of the EU Ship Recycling Regulation.

The Steel Union of the Czech Republic welcomes the opportunity to respond to the public consultation launched by the European Commission on the update of the list of approved recycling sites for ships sailing under the flag of an EU country.

The Cyprus Shipping Chamber strongly welcomes the European Commissions proposal to add two Indian yards to the updated European list of approved ship recycling facilities (16th edition). The Chamber has been advocating for the inclusion of compliant Indian yards, and this proposal, beyond its practical significance for European shipowners, sends a strong political signal: non-OECD yards that meet the EU SRRs safety…

The European steel industry is transforming towards low-carbon production, making steel scrap a critical strategic resource for decarbonisation. As demand for scrap is projected to grow from 88 million tonnes in 2021 to over 100 million tonnes by 2030 , securing domestic scrap availability is essential.

The Ship Recycling Group of Recycling Europe welcomes the opportunity to provide feedback on the 16th edition of the European List of ship recycling facilities. The process of adding and removing yards from the EU List should ensure a level playing field across the sector and uphold high standards for ship recycling. This is, however, not reflected in the draft 16th EU List.

EUROFER welcomes the update of the European List of ship recycling facilities set out in the draft Commission Implementing Decision amending Implementing Decision (EU) 2016/2323. The European steel industry has a direct interest in ship recycling, because steel recovered from dismantled ships is a high-quality secondary raw material for EU steelmaking.

WSC response to the European Commission's Public Consultation on "Ship recycling – European list of ship recycling facilities (16th edition)” August 2026 The World Shipping Council (WSC), representing over 90% of global liner shipping capacity, welcomes the opportunity to comment on the draft 16th edition of the European List of Ship Recycling Facilities.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

We fully support EUROFER's position and recommend the commission and the Member States to reconsider the inclusion of the two Indian facilities in this update, and to 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…

EEB welcomes the opportunity to provide input to the public consultation on the 16th European list of ship recycling facilities and would like to share its recommendations, more specifically on the proposed inclusion of two beaching recycling facilities, YSI Recyclers LLP and Shree Ram Vessel Scrap Pvt, located in Alang, India.

The Sustainable Development Policy Institute (SDPI), a Pakistani non-profit organisation providing expertise in policy analysis, development, intervention, and advisory services by promoting sustainable development, strongly call upon the European Commission to undo its proposal to include two beaching facilities in the 16th update of the EU List of ship recycling facilities.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

A.P. Moeller-Maersk A/S response to the European Commission’s proposal to amend Implementing Decision (EU) 2016/2323 as regards updates to the European List of ship recycling facilities Maersk welcomes the opportunity to provide feedback on the proposed inclusion of the two Indian ship recycling facilities on the European List of Ship Recycling Facilities.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

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. First assess how the existing list can strengthen European recycling capacity, retain strategic materials and develop green industrial value chains in alignment with overall existing and proposed strategies, as well as technological…

Ship recycling 16th EU list Public consultation – August 2026 Executive Summary The process of adding and removing yards to the EU List should guarantee a level playing field across the sector and uphold high standards of ship recycling. This is, however, not reflected in the draft of the 16th EU List.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Our attached submission focuses particularly on the practical differences between ship recycling at an EU facility such as Fornæs in Denmark and recycling methods involving beaching and intertidal dismantling. We also address downstream waste treatment, regulatory supervision and the assessment of the two proposed Indian facilities.

Armateurs de France welcomes the update of the European List of ship recycling facilities and stresses the importance of ensuring that EU-flagged ships have access to sufficient, high-quality and geographically realistic recycling capacity.

The Polish Zero Waste Association welcomes the opportunity to express an opinion in the public consultation on the 16th edition of the EU Style Shipyards List. As a public benefit environmental organisation, we were astonished by the initial decision of the European Commission to place two shipyards practising beaching – Shree Ram and YSI Recyclers – on the EU List.

Filed in Polish · English published by the European Commission

Legambiente strongly opposes the European Commissions proposal to include the Indian ship recycling yards Shree Ram and YSI Recyclers, located in Alang-Sosiya, on the EU List of approved ship recycling facilities. Both yards operate using the beaching method, whereby ships are brought directly onto tidal beaches and dismantled there.

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). Please find enclosed our contribution to the consultation.

Danish Maritime is the trade organisation for the Danish maritime industry, repre-senting shipyards and manufacturers of maritime systems, equipment and services. We welcome the opportunity to comment on the proposed 16th update of the Euro-pean List of Ship Recycling Facilities.

Sustainable Life Foundation opposes the inclusion of Indian beaching Shipbreaking yards on the EU list of ship recycling facilities. Both yards, like the entire Indian Shipbreaking industry in Alang-Sosiya, rely on the beaching method whereby vessels are dismantled directly on the intertidal mudflat.

Filed in Spanish · English published by the European Commission

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.

INTENTIONS OF THE EU COMMISSION AGAINST REALITY ON EU-LISTED-BASED YARDS 1.CURRENT EU INITIATIVES: GREEN DEAL, CIRCULAR ECONOMY ACT, EUROPE 2030, INDUSTRIAL MARITIME ACT ETC. The focus of all the above is to keep resources and raw materials in Europe. End-of-live vessels are a perfect example of highly demanded secondary raw materials that must be kept in Europe for the production of good quality steel.

Opening of the attached position paper · the full paper is on the Commission’s record (source link above)

Transport & Environment (T&E) welcomes the opportunity to respond to the public consultation launched by the European Commission on the update of the list of approved recycling sites for ships sailing under the flag of an EU country.

BIMCO is pleased to submit its comments on the draft Commission Implementing Decision concerning the 16th update of the European List of Ship Recycling Facilities. In summary, 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…

Regulation (EU) No 1257/2013 of the European Parliament and of the Council of 20 November 2013 on ship recycling and amending Regulation (EC) No 1013/2006 and Directive 2009/16/EC aim to prevent, reduce and minimize negative effects on human health and the environment related to ship recycling.

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.

The Royal Association of Netherlands Shipowners (KVNR) appreciates the opportunity to comment on the draft Commission Implementing Decision regarding the 16th edition of the European list of ship recycling facilities. KVNR welcomes the proposed inclusion of YSI Recyclers LLP and Shree Ram Vessel Scrap Pvt. Ltd./Shree Ram Shipping Industries Pvt. Ltd. in India.

While the EU has a responsibility to ensure that it does not export harm to third countries, the standards of the EU SRR cannot change based on the location. Every yard on the EU List should be subject to the same rules and procedures. If not, compliant yards in the EU will continue to face unfair competition.

The update of the list of approved ship recycling facilities is welcomed as an important measure to ensure that end-of-life vessels are dismantled in accordance with high environmental and health and safety standards. However, the practical challenges faced by owners of small fishing vessels should also be recognised.

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. Both facilities have been assessed by DNV on behalf of the Commission over multiple site inspections spanning several years (from 2019 till now), evaluated against the technical and legal requirements of Regulation (EU) No 1257/2013, itself…