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:
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:
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.
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:
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.
If you have any questions or comments please don't hesitate to contact us