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Ship Recycling – UK exit from the EU and the requirements for IHM certification onboard ships

Applicability: shipowners, ship operators, ship managers, ship builders and existing ships that are required to have a valid Certificate/Statement of Compliance on Inventory of Hazardous Materials on board by 31 December 2020 in compliance with the UK Ship Recycling Regulations 2019 (SI 2019/277) and (SI 2020/1429).

As of 1 January 2021, the United Kingdom (UK) has finished its transition period to leave the European Union (EU). The requirements of the EU Ship Recycling Regulation 1257/2013 (EU SRR) have been retained in UK domestic legislation, referred to as the UK Ship Recycling Regulation (UK SRR). The EU SRR applies in the European Economic Area (EEA) (EU countries plus Iceland and Norway).i

This Class News outlines the requirements for the Inventory of Hazardous Materials (IHM) for compliance with the UK SRR from 1 January 2021, as an owner of a:

  1. UK flagged ship of 500GT and over, calling at an EEAi port or anchorage; or
  2. UK flagged ship of 500GT and over, calling at a port or anchorage in Great Britain (GB); or
  3. Non-UK flagged ship of 500GT and over calling at a port or anchorage in GBii.

In summary, the requirements are as follows (full details available below).

Flag of vessel Calling into GBii Calling into EEAi
EEA flagged EU SRR Inventory Certificate (IC) issued on behalf of Flag
UK flagged UK SRR IC issued on behalf of Flag EU SRR Statement of Compliance (SoC) issued on behalf of Flag
Third country (to UK and EEA) EU SRR SoC issued on behalf of Flag

UK flagged ships

a). For compliance with the UK SRR as per MIN 645 (M+F) Amendment 1, UK flagged ships:

  • i: are required to have onboard an IHM that meets the requirements of the EU SRR.
  • ii: are also required to have a UK SRR specific Inventory Certificate (IC) on board. This should be issued at the next initial or renewal survey. No action is needed by shipowners to replace their existing EU SRR IC prior to its expiry in order to comply.

b). For compliance with the EU SRR as per MIN 645 (M+F) Amendment 1, UK flagged ships entering EEAi ports or anchorages are required to have an EU SRR Statement of Compliance (SoC) issued on behalf of UK Flag, noting the UK is now classed as a third country in the EEA (i.e. not an EEA Member State). This EU SRR SoC should be in addition to the UK SRR IC described above.

  • NOTE 1: The required EU SRR SoC will have been issued to any owners of UK flagged ships who already have an existing EU SRR IC by 31 December 2020.
  • NOTE 2: When entering an EEAi port or anchorage, Masters onboard UK flagged ships are to present the EU SRR SoC to Port State Control (PSC) officers only. When entering GBii ports or anchorages, Masters onboard UK flagged ships are to present either an EU SRR IC or UK SRR IC.

EEA flagged ships

All EEA flagged ships calling at a GBii port or anchorage are classed as a third country flagged ship under the provisions of the UK SRR (i.e. not a UK flagged ship). LR understand that an existing EU SRR IC issued on behalf of Flag is acceptable to UK PSC officers.

Third country flagged ships (to both the UK and EEA)

Any other third country (i.e. non EEA and non UK) flagged ships calling at a GBii port or anchorage needs to have either:

  • i: an EU SRR SoC on board issued by or on behalf of Flag; or
  • ii: an EU SRR SoC on board issued on behalf of their Recognised Organisation (RO) along with a letter (or equivalent) on board from Flag advising that this is their practice.

There will be further information related to the UK’s exit from the EU and the final survey requirements for the issue of a Ready for Recycling Certificate provided in due course.


  • Remark i: Ship recycling is subject to the Protocol on Ireland/Northern Ireland. For the purposes of both UK and EU ship recycling regulations Northern Irish ports and anchorages are treated as EEA ports and anchorages.
  • Remark ii: For clarity, Great Britain is the area of the UK that excludes Northern Ireland.

Source: https://info.lr.org/webmail/12702/879717162/4857f3edf6fcecee1ef732f30ec5220f305cad24733dea36e776826d1d137caa

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