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Ship Recycling - UK exit from the EU and the requirements for final survey and recycling facilities.

Class News 04/2021.

02 February 2021 

Applicability: shipowners, ship operators, ship managers and ship masters. ​​​Advice for owners of ships going for recycling and recycling facilities wishing to be included in the UK and EU maintained lists of recycling facilities.

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

This Class News summarises the information contained in MGN 633 (M+F) Amendment 1 regarding requirements for final surveys and ship recycling facilities under the UK SRR, as well as further direct correspondence with the UK Administration.

The UK SRR does not apply to:

  • Ships of less than 500 GT;
  • UK ships operating throughout their life only in UK waters; and
  • Any warships, naval auxiliary, or other ships owned or operated by a state and used, for the time being, only on government non-commercial service.

Note that the EU SRR still applies to UK ships operating throughout their life only in UK waters when they go to a recycling facility in an EEA member statei.

A. Final survey requirements

These are required for compliance with the UK SRR (from 1 January 2021) as an owner of:

1. a UK flagged ship going for recycling at an EEArecycling facility; or 
2. a UK flagged ship going for recycling at a recycling facility in Great Britain (GBii); or
3. an EEA flagged ship going for recycling in a GBii recycling facility; or
4. a third country flagged ship (to both the EEA and UK) going for recycling in a GBii recycling facility.

In summary:

Flag of vessel Calling into GBii Calling into EEAi
UK flagged
  • UK SRR Inventory of Hazardous Material (IHM) Inventory Certificate (IC) issued on behalf of Flag.
  • UK SRR Ready for Recycling Certificate (RfRC) issued on behalf of Flag.
  • UK SRR IHM IC issued on behalf of Flag
  • EU SRR IHM Statement of Compliance (SoC) issued on behalf of Flag
  • UK SRR RfRC issued on behalf of Flag
  • Demonstrate compliance with Regulation (EC) No 1013/2006 (EU Waste Shipment Regulation) – check with the Administration in country of recycling for specific details of paperwork requirements.
EEA flagged
  • EU SRR IHM IC issued on behalf of Flag.
  • EU SRR RfRC issued on behalf of Flag.
Third country (to both the EEA and UK)
  • EU SRR IHM SoC issued on behalf of Flag; and:
  • Check additional specific recycling requirements with the local Administration of the country of recycling ahead of Final voyage*.

*Noting compliance may be required against either EU SRR or Regulation (EC) No 1013/2006 (EU Waste Shipment Regulation), or Statutory Instrument No. 590, International Waste Shipments (Amendment) (EU Exit) Regulations 2019. 

1. UK Flagged ships

Owners of UK flagged ships, wishing to recycle their vessel in an EEAi recycling facility which is EU Listed, will need to comply with the certification requirements of the EU SRR and the UK SRR. See the summary table above for specific certification requirements.

Owners of UK flagged ships, wishing to recycle their vessel in a GBii recycling facility which is UK Listed (see section B below), will need to comply with the certification requirements of the UK SRR. See the summary table above for all specific certification requirements, which includes a UK SRR Ready for Recycling Certificate (RfRC).

In order to obtain a UK SRR RfRC, a Final Survey as specified in MGN 633 (M+F) Amendment 1 will need to be completed. 

2. EEA flagged ships

Owners of EEA flagged ships wishing to recycle their vessel in a GBii recycling facility, which is both EU and UK Listed (see section B below), will need to comply with the requirements of the EU SRR. See summary table above for specific certification requirements.

Note: If the GBii recycling facility is not also EU Listed, the EEA flagged vessel will not be able to be recycled in GB.
​​​​​​
3. Third country flagged ships (to both the UK and EEA)

Owners of non-EEA and non-UK flagged ships may recycle their ship in a facility of their choosing. However, if they leave an EEAi or GBii port or anchorage to sail to a recycling facility, their ships will need to have the relevant IHM certification (see summary table above).

B. Ship Recycling Facility requirements

The UK will maintain its own list of ship recycling facilities – the UK List, which is yet to be published – but this will automatically include the EU List of approved ship recycling facilities. 

In addition to the EU Listed facilities, the UK List will also include all facilities located in the UK (including those in Northern Ireland (NI)) that have a valid ship recycling permit, even if the facility is not on the EU List.

Operators of any UK ship recycling facilities who would like their facility to be included in the EU List, including both GBii and NI recycling facilities, will need to apply to the European Commission (EC) while noting:

  • NI recycling facilities will be treated as an EU recycling facility. As such, any NI recycling facilities will need to be authorised by their competent authority, who will be responsible for communicating this to the European Commission in order to be EU Listed.
     
  • GBii recycling facilities will need to apply to the EC for inclusion in the EU List as a third country. This application should be made with the support of a third-party independent verifier, who has provided inspections and certification against the EU SRR requirements. Should operators of any GB recycling facilities be interested in Lloyd’s Register (LR) Independent Verifier services to support an application to be on the EU List, they should contact their local LR office, who can provide more information.

UK SRR IHM requirements

For information on UK SRR Inventory of Hazardous Material (IHM) Requirements, please see Class News 01/2021.

i Ship recycling is subject to the Protocol on Ireland/Northern Ireland. For the purposes of ship recycling, Northern Irish ports and anchorages are treated as EEA ports and anchorages, and ship recycling facilities in Northern Ireland will be considered as EEA ship recycling facilities.

ii For clarity, Great Britain is the area of the UK that excludes Northern Ireland.

Further information

For more details please contact your local Lloyd’s Register group office or Statutory support

Click here to download a PDF copy of 04/2021 Class News.