Statement on the Implementing Decision (EU) 2016/2323 as regards updates to the European List of ship recycling facilities
28 August 2026 | 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[1], securing domestic scrap availability is essential. The EU should pursue the strategic objective of retaining valuable steel scrap within Europe by establishing an effective monitoring system for scrap flows and by increasing the domestic scrap sources. This objective should also be reflected in the forthcoming Circular Economy Act.
The Commission’s Industrial Maritime Strategy and the Council of the EU have explicitly called for strengthening domestic and environmentally sound ship recycling capacity to secure secondary raw materials for steel decarbonisation[2] [3]. This issue is particularly urgent as the Commission is currently preparing an update to the European List of Ship Recycling Facilities, which proposes adding two Indian beaching yards to the list. Their inclusion would allow critical feedstock exports precisely when European steel makers need it most. Ship recycling yields high-quality plate steel required for demanding applications. However, EU ferrous scrap exports reached 19.4 million tonnes in 2021[4] (around 20% of all EU scrap), undermining supply security.
Both facilities dismantle vessels on intertidal mudflats, which is prohibited in EU Member States and incompatible with the EU Ship Recycling Regulation and European spirit of environmental protection. Processing facilities cannot demonstrate compliance with EU Best Available Techniques and BAT-associated emission levels.
The Wirtschaftsvereinigung Stahl (German Steel Association) calls on the Commission not to include the two Indian beaching facilities in the European List. Instead, the Commission should strengthen the existing European ship recycling capacities which are working on the highest standards and secure valuable secondary raw materials for European steel production.
[1] BCG Article: Shortfalls in Scrap will challenge the Steel Industry (2024)
[2] Communication from the Commission to the European Parliament, the Council, the European Economic and Social Committee and the Committee of the Regions on the EU Industrial Maritime Strategy
[3] Council of the EU, Draft Council Conclusions on the EU Industrial Maritime Strategy
[4] Eurostat: What are the main destinations of EU export of waste (2022)
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