News: UK Ship Recycling Regulation (UK-SRR)

Further to club's previous news item, members of UK flag ships (of 500GT and over) are advised that from 1 January 2021, the UK Ship Recycling Regulation (UK-SRR) retains the requirements of the EU Ship Recycling Regulation 1257/2013 (EU-SRR) in UK domestic legislation.

The UK Maritime and Coastguard Agency (MCA) has issued attached Marine Guidance Note (MGN 633 (M+F) Amendment 1) that provides guidance and clarification on certain aspects of both the EU-SRR and the UK-SRR.

Application

The UK-SRR does not apply to:

• ships of less than 500GT
• UK ships operating throughout their life only in UK waters
• 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.

However, the EU-SRR will apply to UK ships operating throughout their life only in UK waters if/when they go to a recycling facility in an EU/EEA member state.

Inventory of Hazardous Materials (IHM)

It is a statutory requirement that the IHM for UK ships must be verified by a surveyor from a UK authorised Recognised Organisation (RO) or by MCA surveyor. Once the IHM has been verified, an Inventory Certificate (IC) will be issued.

From 1 January 2021, UK flagged ships will be classed as third country ships by EU member states, and under the EU Regulations, third country ships are required to have a Statement of Compliance (SoC) when arriving at port or anchorage of an EU member state.

EU member states may require UK ships which are subject to EU Port State Control, to carry a SoC onboard. As such, the MCA advises that UK flagged ships of 500GT and over, which are subject to Port State Control (PSC) inspections at EU ports, to carry a SoC in addition to an IC onboard.

Surveys

UK ships within scope shall be subject to the following surveys:

• initial survey
• renewal survey
• additional survey
• final survey
  
  

Ship recycling facilities

The UK will maintain its own list of ship recycling facilities (the UK list, which is yet to be published). It is expected that this will include all facilities located in the UK (including those in Northern Ireland) and the EU list of approved ship recycling facilities.

 The ship recycling facilities in Northern Ireland will be treated in the same way as an EU ship recycling facility; while the facilities on the UK mainland will have to reapply for inclusion on the EU list as a third country.

 
Intent to recycle

Owners of UK flagged ships, wishing to recycle their ship in a recycling facility which is in the UK list, will need to comply with the certification requirements of the UK-SRR. However, owners of UK flagged ships, wishing to recycle their vessel in an EU/EEA recycling facility which is in EU list, will need to comply with the certification requirements of both EU-SRR and UK-SRR.

Owners of EU/EEA flagged ships wishing to recycle their vessel in a UK recycling facility, which is both in EU and UK list, will need to comply with the requirements of the EU-SRR. They will not be able to be recycled in a facility that is not in a EU-list.