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May 16

EU Ship Recycling Regulation “Inventory Of Hazardous Materials”

Formal Regulation– EU Ship Recycling Regulation (EC 1257/2013) 2013

The ship recycling industry – which dismantles old and decommissioned ships enabling the re-use of valuable materials – is a major supplier of steel and an important part of the economy in many countries, such as Bangladesh, India, Pakistan and Turkey. The recycling of scrap metals from ships also reduces the need for mining, an environmentally damaging practice. In this way, it is a vital part of the circular economy – which purports to minimise waste and recycle some materials infinitely.

The term ‘End-Of-Life Boats’ and the business prospects for a form of organised yacht recycling network have come to prominence recently as part of the narrative in yachting circles, due to a perfect storm brewing. The boom years of the 70s and 80’s, mass producing GRP yachts from long-life composite construction materials, are now presenting the yachting industry with some economic and environmental challenges.

The International Council of Marine Industry Associations (ICOMIA) has estimated that there are more than 6 million recreational craft in Europe alone, and as we all know, the larger percentage of these are constructed from GRP. The study revealed that present disposal methods are crude, and generally involve chopping up composite structures and reducing them to fragments that can be sent to landfill.

This approach is considered unsustainable in the long run; already certain countries, such as Germany and the Netherlands, have regulations restricting the disposal of GRP to landfill. So, recycling will become the only realistic option.

The EU is pursuing 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.

Moreover, some shipbreaking practices have highly concerning environmental and human impacts, releasing materials such as oil, asbestos and toxic paints into the local environment, and disrupting biodiversity. There have been local attestations of significant pollution to the surrounding environment and its resultant impacts on wildlife, farming and communities.

There is little consideration throughout the Superyacht industry when a yacht comes to the end of their ‘Natural life’.  Where is the ‘graveyard’ for expired ‘Superyachts’ and how much of the materials are recyclable?

In an effort to address the environmental issues caused by ‘Ship Dismantling’ the EU has released a directive that every new-build ship of 500 GT and above, contracted on or after 31 December 2018, and flying the flag of an EU member state will need to be issued with a Certificate of Compliance supplemented by a verified Inventory of Hazardous Materials (IHM).

By 31 December 2020 any shipof 500 GT and above of any flagcalling at an EU port or anchorage will need to have a Certificate of Compliance (if EU) or Statement of Compliance (if non-EU) supplemented by a verified IHM.

Flag States have advised that Shipowners or Companies start planning to comply with the EU Ship Recycling Regulation (EU SRR) well ahead of 31 December 2020 due to the number of ships that will require compliance at the same time.

So, what are ‘Hazardous Materials’.  The European Maritime Safety Agency (EMSA) has published ‘Guidance on the Inventory of Hazardous Materials’ which can be downloaded from here:

EMSA Guidance on the Inventory of Hazardous Materials

How to start the process:

Many Flag States have delegated the authority for the ‘Verification of Compliance’ to their respective ‘Recognised Organisations’ (i.e. Class Societies – ABS, BV, ClassNK, DNV-GL, LR and RINA)

Contact the yachts ‘Class Society’ for further guidance

Written by Divergent Yachting Head of Compliance David Goldie

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