Our Submission on EU Ship Recycling Regulation review

Leviathan's Submission on the EU Ship Recycling Regulation review

Leviathan is passionate about recycling ships in a sustainable way, supplying low carbon steel to our customers.

Europe needs green steel to meet the goals of the Green Deal. But for that to happen, European Ship Recyclers need a level playing field.

Click Here to Read Our Full Submission

The key points of our submission are:

  • The playing field is not level. The EUSRR expects EU List facilities to 'reflect' the safety and environmental values of Europe. But the outcome of the regulation is struggling to ensure this expectation.
  • The intentions of the EU Ship Recycling Regulation have not been met. European owned and controlled vessels are still being recycled in non-EU List recycling yards, predominately in India, Pakistan, and Bangladesh. Therefore, the regulations need to be changed so that the intended outcomes are reflected in the regulations and are able to be enforced. 
    • The rules need to be based on the Ultimate Beneficial Owners, not Flag State, of vessels, to prevent end of life Flags of Convenience circumventing the intended outcomes of the EUSRR. 
    • There needs to be clear sanctions against those breach the regulations. Facility operators and vessel owners.
    • There needs to be consistent audits and inspections all EU List recycling facilities by independent auditors.
  • The yards in south Asia who are applying to be on the EU List have not completed adequate Environmental Impact Assessments (EIA'S) to enable them to be included on the list. But based on the publicly transparent information to date, the current assessments conducted by EU's contractor have not adequately assessed the environmental impact of these sites.
    • For example the environmental data presented before the Indian Courts regarding the legality of the beaching method of ship recycling, clearly shows that there is an impact on the environment, but...
      • The Indian courts have somehow not addressed these points.
        EU Auditors also appear to have not addressed these points.
    • Those environmental impacts that are documented in India regarding the beaching method are not acceptable in Europe, therefore in principle no facility using the beaching method should be able to be on the EU List. 
  • The EUSRR does not contain detailed enough minimum safety and environmental standards, to result in consistent safety and environmental outcomes in non-Annex VII countries. 
    • Auditors have nothing to audit against, therefore outcomes will be inconsistent across the world.

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