The European Parliament formally adopted the new EU Ship Recycling Regulation (EU SRR) on 22 October 2013. The text was then adopted by the European Council and published in the Official Journal of the EU to become legally binding. The EU Ship Recycling Regulation entered into force on 30 December 2013.

This Regulation is aimed at facilitating early ratification of the Hong Kong Convention 2009 - both within the EU and in other countries outside the EU - by applying controls to ships and
ship recycling facilities on the basis of the Convention. It aims to ensure that vessels are recycled in EU-approved facilities worldwide.

The new EU Ship Recycling Regulation means that EU-flagged vessels of 500 GT and over will be required to carry an Inventory of Hazardous Materials (IHM). When calling at EU ports, vessels from non-EU countries will also be required to carry an IHM identifying all the hazardous materials on board. EU-flagged vessels must also be scrapped in an approved ship recycling facility.

Inventory of Hazardous Materials (IHM) requirements
■■EU-flagged newbuildings are required to have onboard a verified IHM with a Statement of Compliance at the earliest by 31 December 2015 and at the latest by 31 December 2018.

■■Existing EU-flagged vessels are required to have onboard a verified IHM with a Statement of Compliance at the latest by 31 December 2020 (or if the ship is to be recycled, the IHM
should be on board from the date when the European list of ship recycling facilities is published, expected to be by the end of 2016).

■■Non-EU-flagged vessels calling at EU ports are also required to have onboard a verified IHM with a Statement of Compliance at the earliest by 31 December 2020. The industry is waiting for a guideline indicating the development and approval of the IHM to comply with the EU SRR.

However, the EU SRR requirements are expected to be similar to the Hong Kong Convention 2009 and its guidelines. A known difference is in the material declarations (MD) for the EU SRR, which will include two additional hazardous materials.

■■PFOS (Perfluorooctane sulfonic acid) shall be prohibited PFOS is chronically toxic, injurious to reproduction, carcinogenic, toxic to aquatic organisms and widely distributed in
the global environment. In the marine industry, it can be found in fire-fighting foams of the type AFFF on vessels carrying inflammable fluids and those with helicopter decks, rubber and plastic materials (ie, cable sheaths, PVC flooring, gaskets and seals) and coatings
(ie, paint).

■■HBCDD (Brominated Flame Retardant) is to be listed in the IHM HBCDD is very persistent, bioaccumulative and toxic to aquatic organisms; it causes long-term adverse effects on the aquatic environment. It is classified and labelled as dangerous for the
environment. In the marine industry, this can be found in expanded polystyrene
(EPS) used for cryogenic insulation, such as for liquefied gas tanks (LGT), refrigerated areas, thermal insulation boards (ie, foam materials), rubber and plastic materials (ie, cable
sheaths, PVC flooring, gaskets, seals) and coatings (ie, paint).

Future development and approval of IHM – EU SRR DNV GL will provide further guidance on the development and approval of IHMs following the EU SRR in the near future. In the
meantime, IHMs will be approved in accordance with the Hong Kong Convention 2009 and its guideline MEPC.197(62) for NB and FiS.
Source: DNV GL