Facilitating ratification of the IMO’s Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships, the EU Ship Recycling Regulation (EU SRR) aims to regulate the ship-recycling industry to ensure that end-of-life vessels are dismantled safely, with minimum impact to human health and the environment.

The regulation requires that any ship of 500gt and above, of any flag calling at an EU port or anchorage, will require a Certificate of Compliance (if EU flagged) or Statement of Compliance (if non-EU flagged) supplemented by a verified Inventory of Hazardous Materials (IHM) by the 31 December 2020.

The Certificate of Compliance means, among other things, that the vessel shall only be sent to recycling facilities included in the European List of Ship Recycling Facilities at the end of its life. The IHM provides ship-specific information on the actual hazardous materials present on board in order to protect health and safety and to prevent environmental pollution at ship-recycling facilities.

Many flag states have delegated the authority for the verification of compliance to their respective classification societies. As such, Lloyd’s Register has been supporting stakeholders throughout the recycling supply chain to ensure all activities are environmentally sound, compliant and safe.

Lloyd’s has reported an enormous uptake in on-board IHM certification as a consequence of the regulation and states that the demand put on certified material samplers will grow significantly in the near future. However, Lloyd’s advises that those requiring certification should make sure there is no conflict of interest, which has become apparent with some offerings of IHM certification.

“Flag and port states might be wary of IHM certification or statements, particularly when the required sampling of materials and certification is done by the same company – it is recommended to keep these clearly separate,” explains Engel de Boer, yacht segment manager at Lloyd’s Register.

“One also needs to check whether or not a certificate or statement is required to be issued on behalf of a flag state. If so, it needs to be realised that some flag states only allow statements to be issued by classification societies on their own classed yachts and not on those of competitors. The best advice is to contact the classification society or flag state prior to embarking on the IHM certification trail.”

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