Europe seeks solutions for more circularity in ships! Recycling and recovering ships material: Myth or key to a circular economy?

The Ship Recycling Regulation: solution to significantly reduce the negative effects and how Regulation contributes to the general policy objectives of the European Green Deal and the circular economy action plan

The EU Ship Recycling Regulation aims to significantly reduce the negative effects of recycling EU-flagged ships. The objectives of the Regulation are: – to encourage recycling activities in safe and sound facilities, while protecting workers’ health and safety and the environment – to contribute to sustainable ship recycling by reducing the negative impacts of ship recycling on human health and the environment – to establish a framework for responsible ship recycling at EU level and promote global action [6]. Contribution to EU policy objectives The Ship Recycling Regulation contributes to the general policy objectives of the European Green Deal and circular economy action plan, as it aims to significantly reduce the negative effects of recycling EU-flagged ships [10] . However, further action is required in order to fully integrate ship recycling into EU environmental policy objectives. Specifically, further analysis is needed as regards alignment with specific policies such as climate change adaptation or implementation of international agreements concluded under UNEP’s Basel Convention (which has since been amended) [11]. In addition greater use should be made of data provided by Member State authorities for implementing principles

What is the purpose of the Ship Recycling Regulation?

The Ship Recycling Regulation (SRR) is a comprehensive set of rules that seeks to protect human health and the environment when ships are recycled [2]. The SRR was established in 2013 by the European Commission to replace its Waste Shipment Regulation [4], which had failed to effectively regulate the export of ships from EU ports to non-OECD countries [4]. The SRR is based on the 2009 Hong Kong Convention for the Safe and Environmentally Sound Recycling of Ships [1], but sets higher standards than the Convention [1]. These standards include regulations on the design, construction, operation and preparation of ships to facilitate safe and environmentally sound recycling without compromising the safety and operational efficiency of ships [2], as well as an enforcement mechanism for ship recycling, incorporating certification and reporting requirements [5]. Additionally, the SRR prohibits the beaching method of ship recycling [1] and encourages the development of green ship recycling methods [3], which have gained widespread popularity since their introduction [3]. As an EU-listed ship recycling facility is subject to independent third party certification and auditing [1], and NGOs are allowed to submit complaints if they have concerns that a listed facility is not operating in line with the Regulation [1], the SRR is an effective tool for ensuring that ships, when being recycled after reaching the end of their operational lives, do not pose any unnecessary risks to human health, safety and to the environment [2].

What measures have been taken to implement the Regulation?

The European Union’s Ship Recycling Regulation (EU SRR) was adopted in 2013 as an early implementation of the Hong Kong Convention for the safe and environmentally sound recycling of ships [5]. The regulation requires an Inventory of Hazardous Materials (IHM) on board to identify and manage any hazardous substances [5]. Articles 4 and 5 of the EU SRR deal with the control of hazardous substances and set out the requirements for an IHM [6]. The general concept behind the IHM centers on the need to reduce harm to the environment and worker exposure to hazardous materials in shipbreaking yards [6]. The EU SRR sets higher standards than the IMO’s Hong Kong Convention, as the beaching method is not allowed and requirements related to downstream toxic waste management and labour rights are included [1]. The EU SRR also requires the operation of ship recycling facilities in a safe and environmentally sound manner [2], the design, construction, operation and preparation of ships to facilitate safe and environmentally sound recycling without compromising the safety and operational efficiency of ships [2], and an appropriate enforcement mechanism for ship recycling, incorporating certification and reporting requirements [6][2]. To ensure the safety and environmental soundness of ship recycling, the EU SRR requires the completion of Parts I, II, and III of the IHM, depending on the vessel’s stage of operation [1]. The EU SRR also includes Guidelines to assist states in the implementation of the Convention after it enters into force [6], as well as provisions for the Prohibition of Waste Shipment from an OECD country to a non-OECD country and for the operation of European Ship Recycling Facilities [7]. To monitor compliance with the Regulation, Initial, Renewal, and Additional Surveys must be undertaken throughout the vessel’s operational life [7]. Lastly, EU-listed ship recycling facilities are subject to a higher level of scrutiny, including independent third party certification and auditing, and the ability of NGOs to submit complaints should they have concerns about how the facility is operating [1].

How has the Regulation been enforced?

The enforcement of obligations stemming from the EU Ship Recycling Regulation (SRR) is of critical importance [8]. The SRR is based on the 2009 Hong Kong Convention for the Safe and Environmentally Sound Recycling of Ships [1], and it has been enforced [5]. The purpose of the EU Regulation is to guide how States should implement the Convention [5], and it is reinforced through additional requirements, including the establishment of an appropriate enforcement mechanism for ship recycling, incorporating certification and reporting requirements [5]. Articles 4 and 5 of the EU Regulation deal with the control of hazardous substances and set out the requirement for an Inventory of Hazardous Materials (IHM) [6]. The IHM centers on the need to reduce harm to the environment and worker exposure to hazardous materials in ship-breaking yards [6]. The Regulation also brings forward the requirements of the 2009 Hong Kong Convention and sets higher standards [1]. This includes the prohibition of the beaching method, requirements related to downstream toxic waste management, and labour rights. The shipowners have the responsibility and obligation to ensure that their vessels comply with the EU Regulation [5], and the Restriction of the Use of Certain Hazardous Substances in Electrical and Electronic Equipment Regulations 2012, as amended, implementing the EU Regulation [5]. Furthermore, EU listed ship recycling facilities are subject to a higher level of scrutiny. Independent third-party certification and auditing, as well as the ability of NGOs to submit complaints if concerns arise, are included [1].

The objectives of the Regulation are:

The objective is to reduce the negative impacts of ship recycling on human health and the environment. The Regulation seeks to ensure that ships are recycled in safe and sound facilities while protecting workers’ health and safety and the environment.

The Regulation encourages recycling activities in safe and sound facilities by:

  • Requiring Member States to take measures to ensure that the operation of ship breaking yards complies with environmental safety requirements at all times (article 4)
  • Ensuring that appropriate control measures are taken against possible threats to human health caused by emissions into the air (article 5) To encourage recycling activities in safe and sound facilities, while protecting workers’ health and safety and the environment

The Ship Recycling Regulation aims to significantly reduce the negative effects of recycling EU-flagged ships. This is a step towards meeting and exceeding the EU’s circular economy objectives, climate change objectives and environmental objectives.

The regulation sets out requirements for shipowners and operators who want to carry out ship recycling activities in an approved facility. Requirements include:

  • ensuring that workers are provided with adequate protection from exposure to hazards;
  • ensuring that workers receive health surveillance;
  • ensuring that waste is managed properly;
  • preventing pollution of air or water during disassembly operations.

To contribute to sustainable ship recycling by reducing the negative impacts of ship recycling on human health and the environment

The regulation aims to contribute to sustainable ship recycling by reducing the negative impacts of ship recycling on human health and the environment.

The regulation will help minimise the environmental impact of ships as well as their potential for harm in a number of ways:

  • it will reduce pollution from hazardous substances that are released during ship breaking activities;
  • it will require high quality waste management at EU-flagged ship breaking facilities;
  • it will make sure that EU-flagged vessels are recycled in an environmentally sound way wherever they are broken up;

To establish a framework for responsible ship recycling at EU level and to promote global action.

The Regulation is a framework for responsible ship recycling at EU level and to promote global action. The Regulation establishes the first-ever framework for the international shipment of ships for recycling. It also sets out requirements for EU Member States on how to regulate such shipments by their nationals, including by establishing national systems of control and registration.

The aim is to significantly reduce the negative effects of recycling EU-flagged ships, in particular through better management of their toxic substances and hazardous waste when being recycled overseas (by setting standards), as well as through improved record keeping requirements (such as providing information on all previous owners).

Contribution to EU policy objectives

The EU Ship Recycling Regulation contributes to the EU’s objective of reducing the negative effects of recycling on workers and local communities, as well as addressing social issues, including child labour. The Regulation also contributes to the achievement of a more circular economy, lessening dependence on finite resources and reducing waste generation by introducing more stringent requirements for ships’ dismantling [6].

As such, further action is required at both Member State level through national implementation measures and at EU level through implementing acts regarding [6] :

  • Further analysis is needed with respect to costs and benefits associated with different waste management routes for ship dismantling; collecting data on these costs would assist in implementing this measure effectively.
  • Greater use should be made of data collected under this Directive to support conclusions drawn from it (such as on environmental impact).
  • Addressing the circularity principle in waste legislation (such as by setting targets)

The Ship Recycling Regulation contributes to the general policy objectives of the European Green Deal and the circular economy action plan, as it aims to significantly reduce the negative effects of recycling EU-flagged ships. However, further action is required in order to fully integrate ship recycling into EU environmental policy objectives. Specifically, further analysis is needed as regards alignment with specific policies and priorities such as climate change adaptation or implementation of international agreements, notably those concluded under UNEP’s Basel Convention (which has since been amended). In addition, greater use should be made of data provided by Member State authorities for implementing EPR principles.

The EU Ship Recycling Regulation strengthens the overall Union policy objective of introducing the circularity principle into waste legislation.

The regulation is an important step towards a more circular economy. The EU Ship Recycling Regulation strengthens the overall Union policy objective of introducing the circularity principle into waste legislation.

By reducing unnecessary environmental impacts, it supports the implementation of the European Green Deal, which aims to create a resource-efficient economy in Europe by 2035 [10].

The new rules on ship recycling also strengthen a number of key elements in the Circular Economy Package adopted by Parliament and Council in 2015: they include a ban on deliberate disposal at sea through pre-incineration or mechanical destruction; measures to reduce releases into water; requirements for financial guarantees for financing projects that are likely to have significant environmental effects; full transparency about all aspects of ship recycling operations; and mandatory registration with national authorities for those involved with these activities [12]. 

Conclusion

The EU Ship Recycling Regulation strengthens the overall Union policy objective of introducing the circularity principle into waste legislation. It contributes to environmental sustainability and resource efficiency by requiring ship recycling facilities to recover materials from ships and reuse them sustainably.


Sources

1.https://shipbreakingplatform.org/issues-of-interest/the-law/eu-srr/

2.https://www.imo.org/en/OurWork/Environment/Pages/Ship-Recycling.aspx

3.https://www.wirana.com/Green-Ship-Recycling-Understanding-the-Concept-in-Deep-27.html

4.https://www.hellenicshippingnews.com/the-ship-recycling-regulations-where-we-stand-today-and-which-standard-to-follow/

5.https://www.wfw.com/articles/the-eu-ship-recycling-regulation-completing-your-ihm-during-covid-19/

6.https://environment.ec.europa.eu/topics/waste-and-recycling/ships_en

7.https://www.walleniuswilhelmsen.com/insights/what-is-green-ship-recycling-1

8.https://www.verifavia-shipping.com/shipping-carbon-emissions-verification/maritime-industry-guidelines-on-the-enforcement-of-obligations-under-the-eu-ship-recycling-regulation-relating-to-the-inventory-of-hazardous-materials-of-vessels-operating-in-european-waters-257.php

9. https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=CELEX:32013R1257

10. https://commission.europa.eu/strategy-and-policy/priorities-2019-2024/european-green-deal_en

11. https://www.unep.org/resources/report/basel-convention-control-transboundary-movements-hazardous-wastes 

12. https://environment.ec.europa.eu/strategy/circular-economy-action-plan_en

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