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Miljø- og Planlægningsudvalget 2008-09
KOM (2008) 0767 Bilag 2
Offentligt

Contribution by Denmark on the Communication by the Commission COM(2008) 767 final

An EU strategy for better ship dismantling

Denmark is generally positive towards the Commission’s communication. Denmark approves of the

Commission’s overall aim of improving the possibilities for ship dismantling to be carried out in an

environmentally sound manner that is not linked to unhealthy working conditions in the EU and

globally.

It is crucial to ensure that all EU Member States ratify the Convention as soon as possible, so that it

can enter into effect quickly, and that EU Member States are not the ones blocking the process.

Denmark is sceptical, however, that a unilateral and early implementation of the Convention aimed

at EU Member States’ ships will lead to a global environmental benefit. Denmark is not convinced

that regional EU regulation of this area is able to solve the global problem by leading to the

responsible dismantling of the large ocean-going ships in a manner that is environmentally sound

and not linked to unhealthy working conditions.

Denmark considers it to be of great importance that once the new Convention enters into force the

double regulation of large ships in the Basel Convention and the EU Regulation on shipments of

waste be abolished.

Concerning the specific proposals:

1) The Dismantling of ships

Effort should be put into ensuring that EU ships are dismantled in an environmentally sound

manner not linked to unhealthy working conditions

2) Voluntary agreements

Denmark agrees with the Commission that until the Convention enters into force voluntary industry

action should be encouraged by various measures, such as public campaigns on environmentally

sound and socially responsible ship dismantling and guidance in the form of a list of “green” ship

dismantling facilities.

In addition, campaigns and guidance should also be aimed at dismantling facilities.

3) Improved Enforcement

Denmark considers it to be imperative that a durable solution for ship dismantling be reached.

Consequently solutions that ensure that ship dismantling occurs in accordance with the

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requirements of the Convention should be prioritised. The EU Regulation on shipments of waste

prohibits the export of hazardous wastes from the EU to non-OECD countries. Ships contain

materials and substances that cause them to be classified as hazardous waste when they are to be

dismantled. This is inexpedient for ships because the dismantling facilities for large ocean-going

ships are located in Asia – Bangladesh, India, China and Pakistan, all countries that are not

members of the OECD. For that reason it is vital that an operative transition model that can deal

with the problems be created, so that it can be ensured that ships are dismantled responsibly in Asia

to the benefit of the environment globally. The prohibition on the transport of hazardous wastes

from the EU to non-OECD countries must be softened up, so that it does not include ships going for

dismantling; conversely enforcement requirements must be established specifying that ships must

be dismantled responsibly (environmentally, health- and safetywise) in accordance with the

guidelines set out by the Convention on Ship Dismantling.

4) Improving the ship recycling facilities

Denmark agrees that the feasibility of developing a certification and audit scheme for ship recycling

facilities worldwide should be assessed and that it should be ensured that a maximum number of

ships, including ships flying the flags of Member States, go for dismantling to facilities certified

and audited under this scheme. However, Denmark considers that a certification scheme cannot

stand alone as it relates to national legislations that may be inadequate. It is vital that an audit

scheme be linked to the specific requirements of the Convention.

Moreover, an overview of “green” dismantling facilities should be prepared as guidance for ship

owners.

5) Creation of a Ship Dismantling Fund

The idea of a ship dismantling fund should be explored further. Any such system should in any

event be in accordance with the principles of producer responsibility and “polluter pays.” It will

furthermore be important that such a system be global and functional, so that it is ensured that all

ship owners are included and that the fund’s means will go towards improving ship dismantling

globally.