New interim rules for ship recycling

Summary#

The government issued the Interim Order Respecting the Recycling of Vessels under the Canada Shipping Act, 2001 to set short-term rules for how large ships are prepared for recycling. It requires owners of vessels of 500 gross tonnage or more heading to a recycling facility to keep an up-to-date Inventory of Hazardous Materials, make it available to crews and recyclers, and to minimize and record leftover cargo, fuel and waste. The order is dated March 26, 2026 and comes into force on April 1, 2026.

What it does#

• Defines key terms:
  • hazardous materials are the substances listed in Appendix 2 to the Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships, 2009.
  • Inventory of Hazardous Materials is a record of what hazardous materials are on board and where they are located.
  • recycling and recycling facility are also defined (recycling does not include routine repair or maintenance).
• Sets the rule scope:
  • Applies to vessels of 500 gross tonnage or more (not government vessels) that are en route to be recycled.
  • Covers Canadian vessels everywhere and foreign vessels in Canadian waters.
• Requires ship owners to:
  • Keep an up-to-date Inventory of Hazardous Materials on board.
  • Make that inventory available to the ship’s master, crew and the person in charge at the recycling facility.
  • Take measures to reduce cargo residues, fuel oil residues and waste before recycling, and keep a record of those measures.
• States the order comes into force on April 1, 2026 (or on the day it is made if issued after that date).

Who's affected#

• Owners and operators of commercial ships of 500 gross tonnage or more.
• Ship masters and crew who will need access to the inventory and to follow preparation steps.
• Ship recycling facilities in Canada that will receive vessels subject to the order.
• Transport officials who oversee marine safety and environmental protection (the order was made by the Minister of Transport, Steven MacKinnon).
• It is unclear from the notice whether any other groups (for example small vessels, government vessels, or specific international operators) have related obligations beyond what is stated.

Why it matters#

• Gives recyclers and crews a clear record of hazardous materials on board, which can reduce health risks during dismantling.
• Aims to reduce leftover fuels, cargo residues and waste that could pollute the marine environment when ships are recycled.
• Introduces routine recordkeeping and preparation steps for owners, which may be a modest administrative or operational cost.
• The notice is an interim measure; the document does not say how it will be enforced or what penalties (if any) will apply.