Legality of EU Proposals on Ship Recycling

The Center for International Environmental Law (CIEL) asserts that end-of-life ships are hazardous waste and that the EU's Ship Recycling Regulation (SRR) illegally exempts EU-flagged vessels from the Waste Shipment Regulation (WSR). CIEL argues that listing ship recycling facilities in developing countries on the 'European List' or entering into Article 11 agreements to facilitate such exports violates the Basel Ban Amendment, which prohibits hazardous waste exports from Annex VII countries (including the EU) to non-Annex VII countries.

• End-of-life ships are classified as hazardous waste under the Basel Convention, a position affirmed by the Basel Conference of the Parties (COP) in Decision VII/26 of October 2004.
• The EU's Ship Recycling Regulation (SRR) creates an illegal exemption by removing EU-flagged ships from the scope of the Waste Shipment Regulation (WSR), which implements the Basel Convention.
• Including ship recycling facilities in developing countries on the 'European List' under the SRR would violate international law because the Basel Convention does not allow for unilateral reservations or derogations.
• The SRR does not qualify as a valid Article 11 agreement under the Basel Convention because it is not a bilateral, multilateral, or regional agreement with the destination states, nor does it provide an equivalent level of environmental protection to the Basel Ban Amendment.
• Proposed bilateral or multilateral agreements between the EU and developing countries to export end-of-life ships would violate Article 4A and Article 11 of the Basel Convention, as they would circumvent the absolute ban on hazardous waste exports to non-Annex VII countries.

APA

Azoulay, D., & Eisen, N. (n.d.). Legality of EU Proposals on Ship Recycling. Center for International Environmental Law. https://www.ciel.org/wp-content/uploads/2020/09/Legality-of-EU-Proposals-on-Ship-Recycling-2020.pdf

Chicago

Azoulay, David, and Nathaniel Eisen. Legality of EU Proposals on Ship Recycling. Center for International Environmental Law, n.d. https://www.ciel.org/wp-content/uploads/2020/09/Legality-of-EU-Proposals-on-Ship-Recycling-2020.pdf.

Wikipedia

{{cite report |last1=Azoulay |first1=David |last2=Eisen |first2=Nathaniel |title=Legality of EU Proposals on Ship Recycling |publisher=Center for International Environmental Law |url=https://www.ciel.org/wp-content/uploads/2020/09/Legality-of-EU-Proposals-on-Ship-Recycling-2020.pdf |access-date=17 August 2026 |via=Climate Insights Directory}}

BibTeX

@techreport{azoulayndlegality, author = {Azoulay, David and Eisen, Nathaniel}, title = {{Legality of EU Proposals on Ship Recycling}}, institution = {Center for International Environmental Law}, url = {https://www.ciel.org/wp-content/uploads/2020/09/Legality-of-EU-Proposals-on-Ship-Recycling-2020.pdf}, urldate = {2026-08-17}, note = {Indexed by Climate Insights Directory} }