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All EU/EEA-flagged ships to be recycled after 31 December 2018 are required to have an RfRC and shall only be sent to recycling facilities included in the European List of Ship Recycling Facilities (European List).


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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 RO 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 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

The Hong Kong Convention has not yet entered into force. As a result, 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.


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IHM compliance only three months away – how to meet the deadline by going digital

Read more in the Technical and Regulatory news No. 19/2020 – Statutory

On-demand webinar: EU Ship Recycling Regulation and IHM – how to prepare for compliance (January, 2020)

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