IHM and ship recycling

Ready for Recycling Certificate

All EU/EEA/UK flagged ships to be recycled after 31 December 2018 are required to have a Ready for Recycling Certificate (RfRC) and shall only be sent to recycling facilities included in the European List of Ship Recycling Facilities (European List). UK, after Brexit, has adopted the requirements of the EU SRR into its national law as EU SRR modified by amendments in SI 2019/277 and SI 2020/1429. Based on it for UK vessels going for recycling, UK list of approved ship recycling facilities shall be used.

For all other vessels, complying with RfR certification is voluntary.

To obtain an RfRC, the ship owner first needs to prepare IHM Parts II and III and find a ship recycling facility listed in the European List. The ship owner shall send IHM Parts II and III to the respective ship recycling facility, together with the up-to-date IHM Part I, so that ship-specific Ship Recycling Plan (SRP) can be prepared by the ship recycling facility.

Once the SRP is ready, the ship owner shall request a final survey from the ship’s flag or from an Recognized Organization for the verification of the following:

• Up-to-date IHM Part I, and approved IHM Parts II and III, have been prepared by the ship owner and are on board
• The approved SRP by the competent authority of the ship recycling facility, is on board and has been developed taking into account the hazmats listed in the IHM
• The agreed ship recycling facility is in the European List / UK List

The Hong Kong Convention will enter into force in June 2025. Until then, end-of-life ships are still regulated by the Basel Convention in international waters. The Basel Ban amendment, which enters into force on 5 December 2019, requires that end-of-life ships from EU/OECD countries can only be recycled in EU/OECD countries.

Similarly, the EU Waste Shipment Regulation requires that even though flying a flag of a third party, a ship shall only be sent to EU/EEA/OECD countries for recycling if leaving from one of the EU/EEA ports.