EU Ship Recycling Regulation - EU SRR

A new EU regulation on ship recycling ( EU Ship Recycling Regulation – EU SRR ), largely based on the Hong Kong Convention, entered into force December 30, 2013. The new regulation aims to prevent, reduce and minimize accidents, injuries and other adverse effects on human health and the environment caused by ship recycling. In addition, it seeks to ensure the proper management of hazardous materials on board ships. It also aims to facilitate the ratification of the Hong Kong Convention.

All new ships that are built today and are affected by the EU regulation, requires an Inventory of Hazardous Materials (IHM). By December 31, 2020, all existing ships flying the flag of a member state of the EU, or ships flying the flag of a third country that are calling at EU ports, are required to have an IHM.

EU Ship Recycling Regulation Deadlines

6 months after reaching 2.5 million LDT, all newbuilds in the EU will be required to have an IHM. The final deadline for this requirement is December 31, 2018. However, industry experts say that the goal will be reached by the end of 2016.


In order for an existing ship to get an IHM, a HazMat Expert is first required to do an IHM inspection on board the ship. An IHM inspection includes taking HazMat samples for testing in a HazMat certified laboratory. Based on the number of ships that will require an IHM, there needs to be performed 24 IHM inspections per day from 2015 to the end of 2020. For every month that passes by, the pressure in the HazMat Expert market will increase.

Some representatives of the HazMat industry believe that the price for an IHM inspection may eventually cost as much as €65,000 EUR, a fourfold increase compared to the current market price. The expert panel during the Norwegian Shipowners’ Association’s 2015 Environmental Conference firmly recommended shipowners to act early in that regard.

We strongly recommend shipowners to get in touch with us to plan for an IHM inspection and the preparation of an IHM sooner rather than later. We also update and maintain the IHM according to regulations on behalf of shipowners.