Question: A customer asked me for EU Ship Recycling Regulation (SRR) compliance information. I'm not familiar with this requirement. Why does my customer need this information?
Answer: The EU SRR aims to make ship recycling safer and reduce its negative social and environmental impacts. To do so, it establishes rules and requirements for ships flying an EU flag, ships manufactured in the EU, and ships stopping in EU ports. One of these requirements involves maintaining an inventory of hazardous materials (IHM), a document identifying whether the ship contains or is carrying any substances that appear on a specific declarable substance list.
If your customer is asking you for information about the EU SRR, it means that they are either in the business of building EU ships, or they are part of the supply chain indirectly providing materials used to build EU ships. As your customer's supplier, you are also part of this supply chain. Your customer needs this information from you so they can either document the material components of ships they are building, or pass the information along to their supply chain partners.
Your customer should have provided you with a list of parts or products in scope and a declarable substance list. You will need to confirm for your customer whether any of these substances are present in the identified parts/products. You may also need to provide information about substance quantities. Your customer may ask for you to document this information in a standardized format, such as a Supplier Declaration of Compliance (SDOC).
There are also requirements for non-EU ships to carry/provide an IHM that satisfies reporting requirements from the International Maritime Organization (IMO). Ships that meet EU SRR IHM requirements will automatically meet IMO IHM requirements, since the list of EU SRR IHM reportable substances includes all substances on the IMO IHM list.
For more information, see https://ec.europa.eu/environment/topics/waste-and-recycling/ships_en.
This article is current as of 2021-08-03.