UAE Ship Recycling Regulation (SRR) to Apply to Foreign and UAE-Flagged Ships From 26 June 2025

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The UAE is setting a new course for sustainability in the maritime sector. Marking a decisive move toward the safe and environmentally sound disposal of end-of-life vessels, the UAE Ship Recycling Regulation (SRR) will apply to a broader range of ships from 26 June 2025 and  stakeholders in the maritime sector should prepare to ensure full compliance.

Adopted through Circular No. 19/2023 of 7 December 2023, the UAE SRR introduces a comprehensive domestic framework for ship recycling. The Regulation seeks to mitigate the risks traditionally associated with dismantling operations – protecting both human health and the environment – while moving the UAE closer to global best practices.

Although the UAE has not yet ratified the Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships (the Hong Kong Convention), which will enter into force on the same date, the UAE SRR appears to apply even stricter standards.

Initially, the UAE SRR applies to any ship recycling facilities operating in the UAE, although none does currently exist. This could be considered a strong indicator that Green Ship Recycling will commence in the UAE. More importantly, starting 26 June 2025, the Regulation will also apply to all ships over 500 gross tons falling into the following categories:

• UAE-flagged ships;
• Foreign ships recycled in the UAE;
• Foreign ships for which the recycling decision is made while in UAE waters;
• Foreign ships beginning their final voyage for recycling directly from UAE waters, whether or not they make technical stops along the way.

 

Inventory of Hazardous Materials (IHM)

One of the most impactful provisions is the mandatory Inventory of Hazardous Materials (IHM). This obligation applies to all new UAE-flagged ships contracted for construction, or whose keels are laid, on or after 26 June 2025, and to all foreign-flagged ships entering UAE waters or ports from that date onward (Articles 4 and 11).

 

Shipowners’ Duties and Notification Requirement

Shipowners intending to recycle vessels will face clear duties (Article 5): vessels must be recycled exclusively at approved facilities, notification must be provided to the UAE Administration no less than 15 days before recycling begins, and pre-cleaning operations must be conducted to remove or minimize hazardous materials, fuel, cargo residues, and waste. Tankers must also prepare cargo tanks and pump rooms for safe entry certification.

 

Reflagging Restrictions

In an effort to prevent circumvention of the Regulation, the UAE SRR prohibits deregistering UAE-flagged ships for the sole purpose of reflagging them in jurisdictions with weaker recycling standards. The Maritime Administration is empowered to reject a request for deregistration “if it learns that the purpose of registering them in the flag of another state is only for recycling without complying with the requirements”, and thus to avoid compliance (Article 5.4).

 

Exemptions

While the UAE SRR introduces strict obligations, it also provides for discretionary exemptions (Article 16). These may be granted by the Administration in cases of necessity – particularly when compliant recycling facilities are not available. Given the current absence of any licensed ship recycling yards in the UAE, it is likely that such exemptions will be considered on a case-by-case basis, provided that shipowners can demonstrate genuine necessity and comply with the Regulation to the extent possible.

We assume that the exemptions clause will need to be applied frequently until the UAE will establish Green Ship Recycling Facilities.

As the UAE SRR demonstrates a clear commitment towards sustainable shipping practices, it remains to be seen whether other GCC countries will follow suit in order to prevent foreign flagged vessels from coming to the UAE to change flag for the last voyage.

 

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	Jasmin Fichte Managing Partner Email: jasmin.fichte@fichtelegal.com Mobile: +971 50 210 1003
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