New EU Ship Recycling Certificate Formats

Why Proper IHM Maintenance Matters More Than Ever

The European Commission has recently introduced new standard formats for ship recycling certificates under the EU Ship Recycling Regulation (EU SRR). These updates are aimed at streamlining documentation, improving consistency, and reducing administrative burden for shipowners and authorities.

While the format of certificates has changed, the underlying compliance requirements remain the same. One thing is clearer than ever: accurate and up-to-date Inventory of Hazardous Materials (IHM) documentation is critical

At Varuna Sentinels BV, our role is focused on IHM maintenance and operational compliance support, helping shipowners stay prepared for inspections, certification, and future recycling requirements.

Why the Change Matters

Previously, shipowners and recycling facilities were required to manage parallel certification systems to comply with both EU SRR and the Hong Kong Convention. The new formats now allow:

  • Single-certificate usability under both EU and IMO frameworks
  • Reduced duplication for EU-flag and EU-trading vessels
  • Faster approvals and clearer audit trails for Port State Control (PSC)

This represents one of the most significant administrative simplifications in EU ship recycling since the SRR entered into force.

What Has Changed?

The Commission has released three revised certificate templates, replacing earlier paper-heavy formats:

  • Inventory of Hazardous Materials (IHM) Certificate
  • Ready for Recycling Certificate
  • Ship Recycling Facility Certificate

The objective of these new formats is to:

  • Improve clarity and standardisation across EU Member States
  • Reduce duplication and administrative effort
  • Support smoother verification by authorities and stakeholders

Impact: Each format reduces required fields from 47 to 28 while preserving mandatory data elements. Digital signatures replace wet-ink verification, cutting approval times from 15 days to 72 hours.

What Has Not Changed: The IHM Imperative

Despite the introduction of new certificate formats

  • The requirement to maintain a correct, complete, and up-to-date IHM remains unchanged
  • Shipowners must continue to ensure that hazardous materials onboard are properly identified and documented
  • Authorities and Class will still rely on IHM accuracy when verifying compliance

In short, new certificate layouts do not reduce compliance responsibility. In fact, clearer formats make any IHM gaps more visible.

Why IHM Maintenance Is More Important Than Ever

IHM is not a one-time exercise. It is a living document that must be maintained throughout a vessel's operational life.

Proper IHM maintenance ensures that:

  • Changes due to repairs, retrofits, or equipment replacement are captured
  • Hazardous material declarations remain valid and traceable
  • The vessel is always ready for inspection or certification when required

Under the updated EU certificate formats, poor-quality or outdated IHM data can directly delay or complicate certification processes.

Critical Point: Accurate IHM inputs are the foundation of all certificate updates. Missing or outdated IHM data can lead to questions or delays at later stages.

What Shipowners Should Be Aware Of

Shipowners and managers should keep in mind that:

  • Certificate updates rely heavily on accurate IHM inputs
  • Missing or outdated IHM data can lead to questions or delays at later stages
  • Maintaining IHM during operation reduces cost and pressure at the recycling stage
  • Early and continuous compliance avoids last-minute corrective actions

Industry coverage on this topic is also available here: - Brussels Morning – European Commission introduces new ship recycling certificate formats

Implementation Timeline

New formats take effect from 19 January 2026 across all 27 EU member states plus EFTA countries. A six-month transition allows dual-format acceptance until 19 July 2026.

  • January 19, 2026: New certificate formats enter into force
  • March 1, 2026: Launch of the central digital repository by EMSA
  • Q2 2026 Deadline: Over 4,200 active EU-listed recycling facilities to update systems
  • July 19, 2026: End of transition period; old formats no longer accepted
  • Penalties: Non-compliance penalties remain at €1.5 million maximum per violation

Targeted Administrative Burden Reductions

Annual savings are projected at €42 million across the sector through digitisation. Key improvements include:

  • 65% reduction in form completion time
  • Auto-population of data from existing EU vessel registries
  • 87% reduction in transcription errors via standardised dropdowns
  • Bulk upload functionality for up to 50 vessels simultaneously
  • 22 hours average paperwork reduction per vessel processed

Economic Impact: Shipyards report immediate paperwork reductions averaging 22 hours per vessel processed, translating to significant operational savings.

Compliance with Hong Kong Convention

Updated formats maintain full alignment with the IMO Hong Kong International Convention for Safe and Environmentally Sound Ship Recycling. All 16 hazardous material categories remain tracked without exception. Waste management plans integrate seamlessly with existing digital logs.

Digital signatures and QR codes embed verification links directly into documents for instant authenticity checks, ensuring compliance with both EU and international standards.

Digital Infrastructure and Security

EMSA's central platform employs blockchain verification for certificate integrity. End-to-end encryption protects sensitive hazardous materials data, and role-based access limits information to authorised personnel only.

API connections enable real-time syncing with classification society databases, ensuring a robust and secure digital ecosystem for ship recycling documentation.

How Varuna Sentinels Supports Shipowners

Varuna Sentinels specialises in IHM maintenance and ongoing compliance support during vessel operations.

Our services include:

  • IHM Part I maintenance and updates in line with new formats
  • Review of hazardous material declarations
  • Support during repairs, retrofits, and equipment changes
  • Alignment of IHM with EU SRR and Hong Kong Convention (HKC) expectations
  • Ensuring vessels remain inspection-ready at all times

We do not issue ship recycling certificates. Instead, we ensure that the core technical document behind those certificates -- the IHM -- is accurate, current, and compliant.

Key Takeaway

The introduction of new EU ship recycling certificate formats is a reminder that good compliance starts long before recycling.

A well-maintained IHM:

  • Simplifies future certification
  • Reduces compliance risk
  • Saves time and cost for shipowners

With Varuna Sentinels, shipowners can rely on a structured, practical, and transparent IHM maintenance approach, ensuring long-term compliance without last-minute challenges.

Reach out to Varuna Sentinels BV for expert support:

Varuna Sentinels BV

Email: contact@varuna-sentinels.com

Website: www.varuna-sentinels.com

References & Further Reading