Ensuring global capacity to meet fleet recycling needs

WSC acknowledges the proposed updates to the list. At the same time, it appears that the current geographic distribution and capacity of approved facilities would not be sufficient to meet the long-term recycling needs of the global liner fleet, particularly large container and vehicle carriers.

A predictable and efficient process for evaluating facilities globally, and listing those that meet the requirements of the EU Ship Recycling Regulation (EU SRR), would help ensure that compliant, safe, and environmentally sound recycling capacity is available where it is needed. Such predictability allows shipowners to plan with confidence and reinforces the European Union’s role in shaping higher standards worldwide.

Consistent and transparent assessment standards

WSC appreciates the Commission’s commitment to applying high environmental and safety standards. Consistency and transparency in the assessment and monitoring of facilities are important for maintaining confidence in the integrity of the list.

Applying the same rigorous and evidence-based criteria to all facilities, whether located in the European Union or outside it, strengthens the credibility of the list, ensures a level playing field and supports continuous improvement across regions. This alignment enhances stakeholder confidence and underscores the European Union’s commitment to high standards rather than geography.

Alignment with the global regulatory framework

The entry into force of the Hong Kong International Convention for the safe and environmentally sound recycling of ships (HKC) in 2025 represents a major milestone for global ship recycling. WSC recognises the important role of European Union leadership in supporting revisions to the Hong Kong Convention, which are essential for strengthening international ship recycling safety and sustainability standards.

As global frameworks evolve, ensuring coherence between the EU SRR, the HKC and Basel Convention obligations becomes increasingly important. Reducing unnecessary regulatory overlap enhances effectiveness, provides clarity for shipowners and authorities and supports the objective of establishing a strong and globally relevant standard.

Supporting the implementation and evolution of the Hong Kong Convention as the primary global framework remains an essential step toward improving ship recycling outcomes worldwide.

Ship recycling as part of fleet renewal and decarbonisation

Safe and sustainable ship recycling underpins the broader energy transition. Access to compliant recycling capacity is critical for enabling fleet renewal and accelerating the introduction of vessels capable of operating on low and zero greenhouse gas fuels.

Expanding access to facilities that comply with the EU Ship Recycling Regulation at global level, together with alignment under a strengthened Hong Kong Convention, supports both environmental protection and decarbonisation objectives.

Read WSC’s full response here.

Spain’s initiative to strengthen environmental protection in internal and port waters forms an important part of regional progress under OSPAR. Ensuring clarity on the scope, evidence base and implementation approach of the proposed measures would reinforce this progress and support effective compliance.

1. Clarification of the geographical scope of application

A clear and precise definition of the areas in which the prohibition applies is essential for legal certainty and operational planning. Article 3 refers to aguas interiores marítimas (maritime internal waters), aguas de las zonas de servicio de los puertos (port service-area waters) and zonas de fondeo y detención designadas por la Autoridad Marítima (anchorage and detention areas designated by the Maritime Authority).

To support coherent implementation aligned with OSPAR Decision 2025/01:

• Confirmation is sought that the measure applies exclusively to internal waters, port-service areas and anchorage/detention zones located within the Spanish territorial sea (12 Nautical Miles).

• Further confirmation is sought that the prohibition does not apply in the Exclusive Economic Zone (EEZ) or any maritime areas beyond the territorial sea unless expressly provided for.

Such clarity will ensure consistent application across Spanish ports and maintain alignment with the geographical scope envisaged in OSPAR.

2. Request for access to the underlying evidence base

The draft Royal Decree references “numerous recent studies” indicating acidity, heavy metals and organic contaminants in EGCS discharge water, and cites cumulative risks for marine ecosystems.

To support transparency and enable stakeholders to fully understand the basis for the accelerated Spanish implementation (entry into force 1 July 2026), WSC asks the Ministry to make available, or indicate where to access:

• The full set of scientific studies evaluated by the Ministry;

• Any impact assessment or technical report supporting the decision to apply both 2027 and 2029 OSPAR prohibitions immediately from 2026;

• Any port readiness assessment, particularly regarding the availability and capacity of port reception facilities for closed-loop residues;

• Any economic or operational analysis assessing impacts on ship operators and ports.

A clear understanding of this evidence will reinforce confidence in the measure and ensure that environmental objectives are achieved effectively.

3. Consistency with OSPAR timelines and coordination with other States

In the explanatory memorandum, Spain notes that it has “optado por anticipar su aplicación… desde la entrada en vigor de esta norma” (“chosen to advance its application from the moment this regulation enters into force”), grounded in accumulated evidence and the need for regulatory coherence.

In this context, it would be helpful to understand:

• Whether coordination with other OSPAR Contracting Parties has taken place regarding accelerated implementation under Section 3.3 of the Decision;

• Whether the postponement mechanism under Section 3.2 was considered and what factors informed Spain’s choice of timeline.

This information will make it possible to understand how Spain’s approach integrates with wider regional implementation pathways.

WSC appreciates the opportunity to comment. The clarifications requested aim to support legal certainty, practical implementation, and alignment with international and regional frameworks. WSC stands ready to engage with the Ministry or technical authorities to support the development of clear and workable implementation guidance.

Read the WSC observations here.

Read WSC’s submission here.

WSC welcomes the opportunity to share our global perspective gained through the operations of our members, as well as our consultative status and long-standing participation at the International Maritime Organization (IMO), International Labor Organization (ILO), World Customs Organization (WCO), and complementary industry-led public-private partnerships, on ways the Commission can pursue its objectives.

Read WSC’s comments here.

The present document represents the abovementioned summary report, and is submitted through the referenced website link by the World Shipping Council (WSC) as coordinator of the Group. The main body of the report contains the Group’s discussions and Annexes 1-4 provide drafting options for the IMDG Code.

Read here: Summary report of the informal correspondence group on the safe transport of vehicles

Read the joint letter to the President of Djibouti here.

Read the joint letter to the President of Gabon here.

Read WSC’s submission here.

Read WSC’s Comments here.

Read WSC’s position on revision of EU ETS here.

Read WSC’s submission here.

Read WSC’s submission here.

Read WSC’s submission here.

WSC’s members operate approximately 90 percent of the world’s liner vessel services. The global liner shipping industry includes over 6,000 ocean-going vessels. Each year, approximately 1,100 liner vessels sail into U.S. ports, making over 18,000 U.S. port calls. Transporting $1.5 trillion in U.S. trade, the liner shipping industry supports over 6.4 million U.S. jobs and contributes over $1.1 trillion to the U.S. Gross Domestic Product. WSC reiterates its support for the Administration’s goal of building a strong and vibrant U.S. shipbuilding and maritime sector. A strong U.S. maritime sector will have positive effects across the entire maritime industry.

However, WSC continues to believe that port fees and export carriage restrictions are not the way to achieve this objective. The fees and export carriage restrictions imposed in Annexes I-IV of the April 17th Notice of Action will increase costs for U.S. consumers and exporters and introduce supply chain inefficiencies, all while failing to incentivize China to alter its acts, policies, and practices.

Without prejudice to WSC’s overall opposition to the fees and export carriage restrictions, and WSC’s position that section 301 does not provide legal authority for the Trade Representative to impose those fees and export carriage restrictions, WSC requests that USTR address certain issues related to Annexes I, II, and III.

Read WSC’s comments on the proposed Action in the Section 301 Investigation here.

This document is submitted in accordance with the provisions of paragraph 6.12.5 of the Organization and method of work of the Maritime Safety Committee and the Marine Environment Protection Committee and their subsidiary bodies (MSC-MEPC.1/Circ.5/Rev.5), taking into account the draft amendments to MSC-MEPC.1/Circ.5/Rev.5 approved at MSC 109; and provides comments on paragraph 3.2 of document MSC 110/16 (Secretariat).

Read the full submission here.

These proposals would cause significant harm to U.S. consumers and exporters. The requirements for exportation on U.S.-built and U.S.-flag vessels, moreover, could prove impossible to meet. Further, the proposals are disconnected from the goal of Section 301: obtaining the elimination of actionable foreign trade policies and practices. Instead, they appear designed to raise revenue and to generate the renewal of the U.S. shipbuilding industry. This falls outside of the U.S. Trade Representative’s remedial authority.

Download the final submission here

Read more about the USTR proposal and WSC comments on our dedicated resource page here

WSC supports the goal of building a strong and vibrant U.S. shipbuilding and maritime sector. A strong U.S. maritime sector will have positive ripple effects across the entire maritime industry. However, WSC strongly opposes the proposals in this proceeding for port fees and for requirements to use U.S.-flagged or U.S.-built vessels. These proposals will result in increased costs for U.S. exporters and consumers as well as supply chain inefficiencies, while failing to provide China with effective incentives to alter its acts, policies, and practices.

Download the full testimony here.