First of all, the ship recycling industry and the shipping sector would gain the most from internationally applicable regulations for the safe and environmentally friendly recycling of ships. For this reason, it is of the utmost importance that the Hong Kong Convention is ratified and comes into effect as soon as possible in order to achieve an international level playing field.
Also of great importance is that, in its approval procedures for ship recycling companies, the European Commission should not automatically exclude the ‘beaching’ method from correct recycling standards. The KVNR believes that it is not the location or method, but the actual operational procedures in which the ship recycling process is carried out that determines whether activities are carried out in a safe and environmentally friendly manner. To this end, the ‘beaching’ method does not necessarily have to be classed as a poor ship recycling method.
In accordance with EVOA Article 60, the European Commission must perform an evaluation of EVOA norms by 31 December 2020 and, if necessary, make proposals for legislative changes. It is important that the EVOA be amended so that it no longer applies to ships that are going to be recycled, and that this is explicitly defined in the EVOA itself.
This is of particular interest because, since 2013, there has been a specific European ship recycling regulation 1257/2013 in effect, which clearly states that the EVOA is no longer applicable on vessels subject to the European Ship Recycling Regulations.