Ensuring Compliance with EU Ship Recycling Regulation: Key Updates from Malta's Merchant Shipping Directorate

Malta’s Merchant Shipping Directorate has released an important update regarding the enforcement of the EU Ship Recycling Regulation No. 1257/2013, specifically focusing on the Inventory of Hazardous Materials (IHM). This notice, Merchant Shipping Notice 163. Rev.1, calls for stringent compliance from shipowners, operators, and managers concerning hazardous materials on board ships. This article delves into the specifics of the notice and its implications for maritime operations registered under the Maltese flag.

Context and Importance

The EU Ship Recycling Regulation aims to promote environmentally sound recycling of ships and reduce the adverse effects of hazardous materials. The regulation mandates that all ships must carry an IHM along with a valid certificate or statement of compliance, a requirement that became effective from December 31, 2020.

Updates on Cybutryne Usage

A significant focus of the recent notice is the control on the use of Cybutryne, an antifouling substance that was recently restricted. The International Maritime Organization (IMO) and the European Maritime Safety Agency (EMSA) have updated their guidelines to include provisions regarding Cybutryne:

• New Ships: Any ship built on or after January 1, 2023, must demonstrate through its IHM that its antifouling systems are free from Cybutryne.
• Existing Ships: Must assess and record the presence of Cybutryne in their antifouling systems before their next IHM renewal survey.

Detailed Requirements and Compliance Steps

Inventory of Hazardous Materials (IHM)

• Documentation and Compliance: All ships are required to maintain an up-to-date IHM that is verified and compliant with current regulations. This inventory must include detailed information on all hazardous materials present on board.
• Supplier Declarations: Material declarations supplied to the shipowner must confirm the absence of Cybutryne, following the format outlined in Appendix 6 of Resolution MEPC.379(80).

Role of EMSA and Port State Control

• The EMSA provides guidance on inspections carried out by EU port states, ensuring that the enforcement of the Ship Recycling Regulation is harmonized and effective. This involves procedural guidance to assist with the consistent implementation of the regulation across member states.

Implications for Shipowners and Operators

Compliance Urgency

• The Merchant Shipping Directorate emphasizes the urgency of compliance, urging all stakeholders to cooperate fully to ensure that Maltese ships operate without interruptions and in full regulatory compliance.
• Monitoring and Updates: Shipowners and operators are advised to stay updated with any additional notices and guidelines from the Merchant Shipping Directorate to adapt promptly to any new requirements.

Merchant Shipping Notice 163. Rev.1 is a critical directive for all stakeholders in the maritime industry operating under the Maltese flag, reinforcing the importance of environmental stewardship and safety in maritime operations. By adhering to these updated guidelines, the maritime community can significantly contribute to sustainable and safe shipping practices.

For more information, please see the document below (available only to subscribers):

Enforcement of EU Ship Recycling Regulation No. 1257/2013 Relating to the Inventory of Hazardous Materials