What is the EU Ship Recycling Regulation (EU SRR)?

Definition: What is the EU Ship Recycling Regulation?

The EU Ship Recycling Regulation, Regulation (EU) No 1257/2013, transposes the substantive requirements of the IMO’s Hong Kong Convention into EU law — with additional substance scope and stricter enforcement on European List facility selection. It has been fully applicable since 31 December 2018.

The regulation has three operative limbs:

The Inventory of Hazardous Materials (IHM) requirement for EU/EEA-flagged ships and EU/EEA port-calling ships of 500 GT and above.
The European List of Ship Recycling Facilities — the only authorised destinations for end-of-life EU/EEA-flagged ships.
The Ready for Recycling certification required before delivery to the yard.

Who is in scope?

EU SRR applies to:

All ships flying an EU or EEA Member State flag (Norway, Iceland, Liechtenstein included via the EEA Agreement).
All non-EU ships of 500 GT and above calling at EU/EEA ports — they must be able to demonstrate an IHM that satisfies the EU substance list.

For flag-specific guidance, see our pages for Malta, Greek, Cyprus, Italian and Norwegian flags.

What does EU SRR add beyond HKC?

EU SRR is broader than HKC in three important ways:

Substance scope: EU SRR’s hazardous-material list explicitly includes substances such as PFOS, brominated flame retardants and certain perfluorinated compounds that were not initially in the HKC core list. IHM Part I for an EU-flagged vessel must therefore be more extensive.
Approved-facility regime: EU/EEA-flagged ships may only be recycled at facilities on the European List of Ship Recycling Facilities. The 15th edition (adopted 27 February 2026) covers 41 facilities and notably added the first German shipyard.
Stronger penalties and enforcement: Each Member State sets its own penalty regime, often substantially harsher than HKC’s flag-state survey-based enforcement.

EU Implementing Decision 2026/116 — unified ICIHM format

On 19 January 2026, the European Commission adopted Implementing Decision (EU) 2026/116 introducing unified certificate formats for the Inventory of Hazardous Materials and the Ready for Recycling certificate. The single ICIHM format now satisfies both the EU SRR and the Hong Kong Convention — reducing administrative burden while maintaining EU-level environmental standards.

For EU/EEA-flagged ships this means a single certificate, dual compliance. The IHM Part I content must still cover the broader EU substance list.

EU Directive 2024/1203 — criminal liability

EU Member States must transpose Directive (EU) 2024/1203 on the protection of the environment through criminal law by 21 May 2026. The directive introduces criminal liability for serious environmental offences including ship recycling violations, illegal hazardous waste shipments and IHM non-compliance.

Combined with the recast EU Waste Shipment Regulation (digital procedures mandatory from 21 May 2026), the EU is creating an integrated, increasingly punitive regime for end-of-life vessel handling. Maritime operators face potential criminal prosecution for the most serious breaches.

How does EU SRR interact with the rest of the regulatory landscape?

EU SRR sits alongside several related EU and IMO instruments:

Hong Kong Convention — in force globally since 26 June 2025. Unified ICIHM format from January 2026.
EU Waste Shipment Regulation — recast in 2024, fully digital procedures from 21 May 2026.
Directive 2024/1203 — criminal liability for environmental offences, transposition by 21 May 2026.
FuelEU Maritime Regulation 2023/1805 — first compliance balance deadline 30 April 2026 for the 2025 reporting year. Try our FuelEU Balance Calculator.
EU ETS for shipping — phasing in 40% (2024), 70% (2025), 100% (2026) of in-scope CO₂ emissions.
CSRD/Omnibus I — sustainability reporting (cut to 1,000+ employees / EUR 450M+ turnover under Directive 2026/470).

Want to check your fleet’s readiness?

Take our free 12-question scorecard to score your fleet’s IHM compliance maturity in 3 minutes — or use the deadline calculator to find your next IHM survey deadline.

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Frequently Asked Questions

Does EU SRR apply to non-EU-flagged ships?

Indirectly — non-EU ships of 500 GT and above calling at EU/EEA ports must produce a valid IHM that satisfies the EU substance list. Port State Control inspections enforce this.

Where can I find the European List of Ship Recycling Facilities?

Published by DG ENV (European Commission Directorate-General for Environment). The 15th edition was adopted on 27 February 2026 and includes 41 authorised facilities across Europe, Türkiye and the United States — including the first German yard.

Is the EU SRR more stringent than the Hong Kong Convention?

On substance scope and approved-facility selection, yes. EU SRR adds PFOS and brominated flame retardants beyond the HKC core list, and restricts EU/EEA-flagged ships to European List yards. EU Implementing Decision 2026/116 unifies the certificate format but the substance content remains broader.

Will Brexit-era UK-flagged ships still be subject to EU SRR?

Not by flag — the UK is no longer an EU Member State. But UK ships calling at EU/EEA ports still face EU port-state checks on IHM substance content.

How does EU SRR affect ship recycling planning timing?

End-of-life events for EU/EEA-flagged ships must be planned around European List facility availability, the 90-day IRfRC validity, and IHM Parts II and III preparation. Early engagement is critical — Varuna Sentinels coordinates yard selection, IHM Part II/III development and SRP review in one workflow.