What Separates Approved Ship Yards From the Rest: Inside 22 EU Inspections

Every year, hundreds of aging cargo ships, tankers, and container vessels reach the end of their working lives, and what happens to them next has become one of the most contentious questions in global environmental governance. A new study published in Environmental Science and Pollution Research offers an unusually detailed answer, drawing on the confidential world of official European Union inspections to reveal exactly why some ship recycling facilities earn a place on the EU’s approved list while others are turned away. The research, led by Newton Narciso Pereira of Federal Fluminense University in Brazil together with colleagues at São Paulo State University, analyzed 22 official inspection reports prepared by the classification society DNV on behalf of the European Commission, providing the first systematic comparative look at the compliance patterns that separate listed from non-listed yards.

The stakes could hardly be higher. Under the EU Ship Recycling Regulation, known formally as Regulation No. 1257/2013, ships flying the flag of an EU member state may only be dismantled at facilities included on the European List of Ship Recycling Facilities. Inclusion demands far more than a paved yard and a crane: applicants must pass detailed technical audits covering infrastructure, hazardous waste control, environmental monitoring, worker safety, and legal authorization. Yet ship recycling remains concentrated in South Asia, particularly India, Bangladesh, and Pakistan, where the beaching method—running vessels aground at high tide and cutting them apart on tidal flats—keeps costs low but raises persistent concerns about toxic releases, worker exposure, and contamination of coastal sediments.

The Brazilian team’s approach was archival and qualitative. They collected the publicly available DNV inspection reports on 1 July 2025, developed a structured framework of analytical categories and subcategories based on the EU regulation and its implementing decisions, and then coded each facility’s performance as compliant, partially compliant, non-compliant, or not validated. The not-validated classification, the researchers stress, reflects gaps or ambiguities in the documentary evidence rather than confirmed non-compliance, but in a regulatory process built on auditable records, such gaps matter in their own right. One facility had to be excluded entirely after the researchers discovered that a downloaded report did not correspond to the Turkish yard it was supposed to describe—a small but telling illustration of the documentation problems that can plague even official regulatory processes.

The headline numbers are striking. Of the 22 facilities assessed, 12 made it onto the European List and 10 did not. Aggregated across all analytical categories, compliant classifications accounted for 90.26 percent of subcategory-level observations among listed facilities and 82.59 percent among non-listed ones—a gap of less than eight percentage points. That narrow overall difference conceals a far more revealing story about where the non-conformities actually cluster. Both groups scored remarkably well on infrastructure: in the project design and infrastructure category, compliance reached 97.92 percent for listed facilities and 95.00 percent for non-listed ones. Physical improvements, it turns out, have become widespread across the industry, with impermeable flooring, drainage systems, and designated cutting areas now common even among yards that failed to win EU approval.

The real dividing lines appear elsewhere. In the health, safety, and environmental performance category, listed facilities achieved compliant classifications in 88.89 percent of observations, while non-listed facilities managed only 63.33 percent—and recorded non-compliance in 15.56 percent of cases where listed facilities recorded none at all. This category covers soil, water, air, and noise monitoring, intertidal zone control, emergency response planning, medical surveillance, and training documentation. Recurring failures in environmental monitoring emerged as a signature weakness of non-listed yards: facilities that had invested in paved surfaces and modern cutting equipment nonetheless could not demonstrate consistent, verifiable measurement of the pollutants their operations might release into soil, water, and air.

Governance told a similar story. In the management and organizational structure category, listed facilities achieved 97.22 percent compliance against 83.33 percent for non-listed facilities, with a further 13.33 percent of non-listed observations classified as not validated. The shortcomings documented among non-listed yards included absent or incomplete recycling facility plans, unclear organizational charts and allocation of responsibilities, and insufficient evidence to verify claimed ISO certifications such as ISO 9001, ISO 14001, and ISO 45001. In one Indian facility, documentation was partially redacted and the organizational structure could not be verified; in one Turkish case, the required formal certification was simply not in place. Hazardous waste management showed a parallel pattern, with both groups outsourcing much of the final treatment of dangerous materials, but non-listed facilities more frequently presenting incomplete waste-flow records and limited evidence about where their waste ultimately went.

Dismantling method loomed large over the entire analysis. Beaching or intertidal dismantling was the most frequently documented approach across the sample, accounting for 36.4 percent of facilities, followed by ramp or slipway landing at 31.8 percent. Among non-listed facilities, beaching was far more common—indeed, all six assessed Indian facilities employed some form of intertidal landing, stranding, grounding, or beaching, while listed facilities in Turkey, the United Kingdom, and the United States predominantly used ramp-based, floating, dry-dock, or combined methods. The EU regulation does not consider beaching compatible with its requirements, citing concerns about environmental containment, worker safety, and operational control. The environmental literature reinforces the point: studies in Bangladesh have documented chronic contamination of sediments and coastal biota with heavy metals such as copper, lead, and cadmium, along with organotin compounds, in areas where dismantling occurs directly on the shoreline.

Yet the study’s most provocative finding comes from a sensitivity analysis. When the researchers excluded facilities employing dismantling methods prohibited under the EU regulation, two non-listed facilities—Applications 40 and 56 in the report numbering—emerged with compliance profiles broadly comparable to several listed yards across the remaining dimensions. Structural eligibility alone, in other words, does not explain every listing outcome. Even after removing the beaching question from the equation, differences persisted in environmental monitoring, traceability systems, and institutional governance, suggesting that the EU assessment is effectively measuring two distinct things at once: whether a yard’s physical setup is compatible with European standards, and whether its management systems can demonstrate continuous, verifiable control of operational and environmental risks.

The researchers also flag a subtler concern about what their results reveal regarding modern regulation itself. Citing the safety scholar Sidney Dekker’s work on the bureaucratization of safety, they note that documentation-intensive auditing frameworks may progressively prioritize the production of auditable records over the effective management of actual risks, creating a potential gap between formal compliance and practical safety performance. The stronger performance of facilities in the United Kingdom and the United States, they suggest, may partly reflect long-standing institutional experience with complex bureaucratic and certification systems rather than exclusively superior operational conditions. At the same time, the study does not dismiss documentation as unnecessary; rather, it argues that paper compliance should be understood as one component of a broader institutional capability that must also include operational verification and adaptive risk management.

For an industry caught between the circular economy’s promise—recovering tens of thousands of tonnes of steel and valuable metals from end-of-life vessels—and its documented hazards, the study offers a roadmap of sorts. The persistent gaps that keep facilities off the European List are concentrated in a small set of dimensions: environmental monitoring, hazardous waste traceability, intertidal zone control, and institutional governance. Yards in India and Turkey have already made visible progress, installing impermeable flooring, expanding cutting areas, engaging accredited laboratories, and, in some Turkish cases, implementing substantial improvements between first and second inspections. Whether that modernization can extend from concrete and drainage systems into the harder-to-build architecture of verifiable governance may determine not only which facilities appear on the European List in the coming years, but whether the global ship recycling industry can finally reconcile its economic logic with its environmental and human costs.

Subject of Research: Comparative compliance assessment of listed and non-listed ship recycling facilities evaluated for the EU List

Article Title: Compliance and non-compliance patterns among listed and non-listed ship recycling facilities: a comparative assessment of 22 facilities evaluated for the EU List

Article References: Pereira, N. N., da Silveira, C. A. M., dos Santos Paula, K. C., & Diniz, C. A. (2026). Compliance and non-compliance patterns among listed and non-listed ship recycling facilities: a comparative assessment of 22 facilities evaluated for the EU List. Environmental Science and Pollution Research. https://doi.org/10.1007/s11356-026-38259-w

Image Credits: AI Generated

DOI: 10.1007/s11356-026-38259-w

Keywords: ship recycling, EU Ship Recycling Regulation, European List, environmental monitoring, hazardous waste management, beaching, governance, DNV inspections, circular economy, occupational safety, traceability, South Asia