Ship Recycling FAQs

Ship recycling is the activity of complete or partial dismantling of a ship at a ship recycling facility in order to recover components and materials for reprocessing, for preparation for re-use or for re-use, whilst ensuring the management of hazardous and other materials, and includes associated operations such as storage and treatment of components and materials on site, but not their further processing or disposal in separate facilities.

There is a European Regulation (Regulation EU No. 1257/2013) setting out the requirements around ship recycling for all Member States and two Irish Regulations were issued to give effect to certain elements of the European Regulation:

European Union (Ship Recycling) Regulations 2018 S.I. No 555 of 2018
European Union (Ship Recycling) (Waste) Regulations 2019 S.I. No 13 of 2019

A ship recycling facility is a defined area that is a yard or facility located in a Member State or in a third country and used for the recycling of ships.

A ship recycling company is the owner of the ship recycling facility or any other organisation or person who has assumed the responsibility for the operation of the ship recycling activity from the owner of the ship recycling facility.

No. Ireland has no facilities listed in the most recent European List of ship recycling facilities.No. Ireland has no facilities listed in the most recent European List of ship recycling facilities.

A ship owner is the natural or legal person registered as the owner of the ship, including the natural or legal person owning the ship for a limited period pending its sale or handover to a ship recycling facility, or, in the absence of registration, the natural or legal person owning the ship or any other organisation or person, such as the manager or the bareboat charterer, who has assumed the responsibility for operation of the ship from the owner of the ship, and the legal person operating a state-owned ship.

A ship recycling plan means a plan developed by the operator of the ship recycling facility for each specific ship to be recycled under its responsibility taking into account the relevant IMO guidelines and resolutions.

The International Maritime Organisation (IMO) has guidelines available relating to ship recycling and are available on the IMO website: www.imo.org/en/OurWork/Environment/Pages/Ship-Recycling

A ship recycling facility plan is a plan prepared by the operator of the ship recycling facility and adopted by the board or the appropriate governing body of the ship recycling company that describes the operational processes and procedures involved in ship recycling at the ship recycling facility and that covers in particular workers’ safety and training, protection of human health and the environment, roles and responsibilities of personnel, emergency preparedness and response, and systems for monitoring, reporting and record-keeping, taking into account the relevant IMO guidelines and resolutions.

The EPA is the designated competent authority for facilities located in Ireland to be authorised in accordance with the EU Regulation. The Marine Survey Office is designated as the national “administration” responsible for application of the EU Regulation.The EPA is the designated competent authority for facilities located in Ireland to be authorised in accordance with the EU Regulation. The Marine Survey Office is designated as the national “administration” responsible for application of the EU Regulation.

For ship recycling which falls under the regulations, either a Waste Licence or an Industrial Emissions Licence is a suitable designated authorisation. In the case of proposed recycling of waste ships of less than 500 gross tonnage, where “Gross tonnage” means the gross tonnage (GT) calculated in accordance with the tonnage measurement regulations contained in Annex I to the International Convention on Tonnage Measurement of Ships, 1969, or any successor convention, a Class 4 and/or Class 10 Waste Facility Permit, in accordance with the Third Schedule of the Waste Management (Facility Permit and Registration) Regulations 2007, as amended, issued by a Local Authority is a suitable authorisation. The Process Flow Authorisation Chart below summarises the options.

The EU Regulation does not apply to warships, naval auxiliary, or other ships owned or operated by a state, to ships of less than 500 gross tonnage and to ships operating throughout their life only in waters subject to the sovereignty or jurisdiction of the Member State whose flag the ship is flying.

Currently, there are no facilities in Ireland licensed or granted permits for waste ship dismantling. The EPA has a general duty to investigate allegations of any unauthorised ship recycling facilities within the State. If a facility is authorised in the State, the EPA will be responsible for enforcement of the EPA licence, including the assessment of vessel-specific Ship Recycling Plans. This may require specialist marine engineer’s advice. The marine side obligations, including inspection and boarding any ship rests with the Marine Survey Office. This includes the issuing of “ready for recycling certificates” to owners of ships destined to be recycled.

If you  think the requirements of the ship recycling regulations apply to you, you are advised to contact the EPA via email at licensing@epa.ie