Mark Johnson and Chrysa Kitsou in Inside Marine: A Timely Reminder for Non-EU Flagged Ships


Whilst the impact of the Covid-19 pandemic on the maritime sector has, understandably, dominated recent discussions, a significant legal deadline for non-EU flagged ships calling at EU ports and anchorages is rapidly approaching. Mark Johnson, London-based shipping partner and, Chrysa Kitsou, Associate, at international law firm Haynes and Boone detail what actions need to be taken between now and the end of 2020 in light of the upcoming changes to the European Ship Recycling Regulation.

Adopted in 2013, the European Ship Recycling Regulation EU No. 1257/2013 (EU SRR) aims to minimise adverse effects of ship recycling on human health and the environment. It brings forward requirements of the (not yet in force) 2009 Hong Kong Convention and introduces higher safety and environmental standards including prohibiting the beaching method of ship recycling, requirements related to downstream toxic waste management and aspects of health, safety and training.

Since 31st December 2018, EU flagged commercial ships above 500 GT should only be recycled at facilities that comply with the EU SRR. Additionally, all new European ships as well as any existing EU-flagged ships going for dismantling must have a verified inventory of hazardous materials (IHM). The EU SRR continues to apply to UK-flagged ships and UK ports and anchorages during the Brexit transition period and, pursuant to the Ship Recycling (Facilities and Requirements for Hazardous Materials on Ships) (Amendment) (EU Exit) Regulations 2019 will continue to substantially apply with logical amendments (such as reporting obligations) after the rexit transition period.

The EU SRR applies to all marine vessels, including submersibles, floating craft, floating platforms, self- elevating platforms, FSUs, PSOs, as well as vessels stripped of equipment or being towed.

Excerpted from Inside Marine. To read the full article, click here. (See Page 12.)

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