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

Abstract Ship recycling plays a central role in the circular economy of the maritime industry, yet significant disparities persist in safety, environmental performance, and regulatory compliance across global Ship Recycling Facilities (SRFs). This study analyzes 22 official inspection reports conducted by DNV for the European Commission under the EU Ship Recycling Regulation (EU SRR 1257/2013), comparing listed and non-listed facilities. Using a structured qualitative framework, the findings suggest that differences between listed and non-listed facilities are reflected not only in overall compliance levels but also in the nature and distribution of non-conformities across regulatory dimensions. While most facilities showed relatively high levels of conformity in infrastructure-related requirements, more pronounced differences between the groups were observed in environmental monitoring, institutional governance, traceability systems, and intertidal zone control. Non-listed SRFs showed recurring deficiencies in environmental monitoring, documentation, emergency preparedness, and hazardous waste management, whereas listed facilities generally showed stronger governance and risk-management capabilities despite minor shortcomings. A sensitivity analysis excluding facilities employing dismantling methods prohibited under the EU SRR identified two non-listed facilities with performance profiles comparable to several listed SRFs, indicating that structural eligibility alone does not account for all observed differences between the groups. The results further suggest that environmental verification, traceability, and institutional governance are among the dimensions in which recurrent differences between the two groups were observed. These findings provide new insights into patterns associated with different listing outcomes and highlight areas that may support the modernization and regulatory alignment of ship recycling facilities.