This is a discussion document about elements of the new EU SRR, particularly from an in-service shipowner point of view (not recycling), since this will effect most shipowners earliest.

It highlights a worrying difficulty in providing inventories and then in enforcement on non EU ships via Port State Control.

It also questions where the wide range and number of competencies are going to come from since, for example, it takes very specialist companies to assume asbestos liabilities.

It is intended to be a living document, updated for more information and per any debate, so comments welcome. The document is available on the projects / ship recycling page of the website; https://www.marprof.net/ship-recycling.