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Deadline approaches for new EU Ship Recycling Regulations

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New European ship recycling regulations enter into force at the end of the year – but the current tough market conditions compounded by the delay in decision making caused by the work-from-home situation in the Coronavirus pandemic, has meant that many shipowners are still to undertake the necessary work to be compliant with the legislation.

The EU Ship Recycling Regulation (EUsRR) stipulates that all ships over 500 GRT - which call at EU ports - must have a Statement of Compliance (SoC) demonstrating that they have an Inventory of Hazardous Materials (IHM) onboard. 

Current estimates indicate that, of the expected 20,000 ships which will need to comply with the Regulation before 31 December 2020, more than a third have yet to begin on the road to compliance.

Obtaining an IHM for a vessel requires an expert company to sample the ship for hazardous materials. A “mini-industry” of individuals and small expert companies has emerged, offering IHM services. For shipowners, the challenge is how to carry out adequate due diligence to find a suitable IHM company, while meeting the requirement to get the job done as soon as possible.

​One company which has gained considerable industry recognition in this field by a number of major shipowners is Centre Testing International (CTI). Experts in the supervision of ship recycling, the company specialises in surveying and removing asbestos from ships, as well as assisting shipowners with IHM preparation.

CTI has over the years undertaken numerous projects for several major shipowners such as CMA CGM, Euronav, Maersk Line, Maersk Drilling, Pioneer Marine and Stolt Tankers. For CMA CGM, CTI provided a ‘one-stop shop’, carrying out a full range of essential services, including newbuilding surveys, targeted sampling during docking periods, removal of asbestos, IHM preparation, ship recycling supervision and asbestos management audits of suppliers. The quality of CTI’s expertise was praised by CMA CGM’s Safety Officer, who highlighted “the excellent work and assistance provided by CTI teams since we started working together”.

Greek Shipowner Pioneer Marine, in complimenting CTI on their work, reiterated their satisfaction with the CTI service quality and professionalism, together with their ability to meet deadlines and to respond to the various operational constraints.

Commenting on the accolades received from these two customers, Mr. John Ren Di, General Manager of CTI said: “As a third-party Marine Expert, CTI Marine Services has a highly qualified motivated marine technical team and always pursues high quality service with positive action. We appreciate our clients’ continuing support - and we welcome reciprocity initiatives to further mutual advantage.”

BACKGROUND INFORMATION ON EUSRR

About the Regulation

The EU pursues an ambitious policy to make ship recycling greener and safer. Currently, a vast majority of large vessels are dismantled in poor social and environmental conditions in South Asia.

The Ship Recycling Regulation (EUsRR) adopted in 2013 by the European Parliament and the Council of the European Union aims to reduce the negative impacts linked to the recycling of ships flying the flag of Member States of the Union. The Regulation lays down requirements that ships and recycling facilities have to fulfil in order to make sure that ship recycling takes place in an environment sound and safe manner.

The Regulation first prohibits or restricts the installation and use of hazardous materials (such as asbestos or ozone-depleting substances) on board ships.

New European ships and EU-flagged ships going for dismantling must also have on board an inventory of hazardous materials (IHM) verified by the relevant administration or authority and specifying the location and approximate quantities of those materials. This obligation will also apply from 31 December 2020 to all existing ships sailing under the flag of Member States of the Union as well as to ships flying the flag of a third country and calling at an EU port or anchorage. This will facilitate the recycling of vessels and reduce the presence of toxic materials on board ships.

What does the Regulation do?

The Regulation aims to prevent, reduce and minimise accidents, injuries and other negative effects on human health and the environment when ships are recycled and the hazardous waste they contain is removed.

Which vessels must comply?

• The legislation applies to all ships flying the flag of an EU country and to vessels with non-EU flags that call at an EU port or anchorage. The only exceptions are warships, other vessels on non-commercial government service and ships below 500 gross tonnes. It sets out responsibilities for ship owners and for recycling facilities both in the EU and in other countries.
• Every new ship has to have on board an inventory of the hazardous materials (such as asbestos, lead or mercury) it contains in either its structure or equipment. The use of certain hazardous materials is forbidden.
• Before a ship is recycled, its owner must provide the company carrying out the work with specific information about the vessel and prepare a ship recycling plan. This, for instance, identifies the type and amount of hazardous materials and waste that will be generated from the obsolete vessel.
• Recycling may only take place at facilities listed on the EU ‘List of facilities’. The facilities may be located in the EU or in non-EU countries. They must comply with a series of requirements related to workers' safety and environmental protection.
• These requirements are designed to prevent health risks to the workers involved and the neighbouring population and to minimise any adverse effects on the environment. They also provide for specific training and protective equipment for employees dismantling the vessels and require a record to be kept of any incidents or accidents.
• The legislation contains an authorisation process for ship recycling yards within the EU. Those in other countries must submit an application to the European Commission and demonstrate that they fulfil all the criteria in the regulation.
• In 2014, the Council Decision 2014/241/EU was adopted, authorising EU countries having ships flying their flag or registered under their flag to ratify or to accede to the Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships. The Convention covers the design and construction of ships so as to facilitate safe and environmentally-sound recycling without compromising ship safety and operational efficiency. It also requires ship recycling facilities to operate in a safe and environmentally friendly manner, and for mechanisms to be set up to ensure that ship recycling rules are complied with.

Source：

1. https://ec.europa.eu/environment/waste/ships/

2. Document 32013R1257 “SUMMARY OF: Regulation (EU) No 1257/2013 on ship recycling