EU Ship Recycling Regulation - EU SRR

EU rules on ship recycling aim to make it greener and safer, and to reduce the negative environmental and social impacts of recycling ships. Hundreds of large ships are dismantled in poor environmental and social conditions each year. Workers are low-paid and often have inadequate tools and little protection. This has caused many injuries, deaths and significant pollution.

EU Ship Recycling Regulation – EU SRR , largely based on the Hong Kong Convention, entered into force December 30, 2013. The regulation aims to prevent, reduce and minimise accidents, injuries and other negative effects on human health and the environment related to the recycling of ships flying the flag of European Union countries.

The inventory of hazardous waste materials

EU rules require that any EU ship going for dismantling, all new European ships, and third-country ships stopping in EU ports have on board an Inventory of Hazardous Materials (IHM). This inventory must specify the location and approximate quantities of those materials. This helps the recycling of vessels and reduces the presence of toxic materials on board ships. Port authorities of EU countries may control ships to verify whether they carry such an inventory together with a necessary certificate.

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


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 alsoupdate and maintain the IHM according to regulations on behalf of shipowners.

Last updated Mar 08, 2023