Overview

The EU Ship Recycling Regulation came into force on 31 December 2020 and effects any in-service ship of 500 GT or over calling at any EEA (i.e. EU countries plus Iceland and Norway) port or anchorage (regardless of flag) . It requires that vessels hold a valid and certified Inventory Hazardous Materials (IHM) on board.

Similarly to the IMO Hong Kong Ship Recycling Convention (HKSRC), the EU SRR lays down requirements:

  • For ships and recycling facilities to ensure that ship recycling takes place in an environmentally safe and sound manner
  • To restrict or prohibit the installation and use of hazardous materials on ships, such as asbestos or ozone-depleting substances; and,
  • Establishes a European list of ship recycling facilities. 

Requirements of the EU SRR 

The EU SRR implements the requirements of the HKSRC, but includes also additional safety and environmental requirements.

  • All in service ships, irrespective of flag and meeting the application criteria, calling at an EU port must have an EU SRR compliant Inventory of Hazardous Materials (IHM) and EU SRR certificate onboard. This requirement has been in place since 31 December 2020.
  • Newbuild EU flagged ships have been required to carry an IHM certificate since December 31, 2018, while existing EU ships needed to comply by December 31, 2020.
  • The EU SRR requires the same hazards to be recorded in the IHM as the IMO HKSRC. However, it places an additional requirement to record the presence of PFOS and HBCDD, when it is contained in the ships structure or fitted equipment.
  • Any EU flagged ships going for recycling must have an EU Ready for Recycling Certificate and only be recycled in an EU listed Recycling Facility.
  • Ship Recycling facilities located in non-EU countries, wishing to be EU listed must apply to the EC using an independent verifier to check for compliance with the EU SRR recycling standards and produce a report stating as such.
  • The EU SRR is largely aligned with the HKSRC requirements for recycling facilities. However, the regulation also requires that EU listed recycling facilities operates from built structures, have access to downstream waste management facilities, and access to medical facilities both of which must meet the required standards. Both the downstream waste management facilities and the medical facilities must be audited as part of the EU list application and assessment process.
  • The EU list is updated periodically by the European Commission based on the latest successful applications and decisions to withdraw or expiration of existing approved applications.
  • Successful applications remain valid on the EU list for up to 5 years. 

Application

The regulation applies to ships of 500 GT and above flying the flag of an EU Member State or a third country, including submersibles, floating craft, platforms, FSUs, and FPSOs. It does not apply to warships or government non-commercial service ships.
 
It also requires ship recycling facilities to be included on the EU List of recycling facilities, if they are to recycle EU flagged vessels.