FPSO · Regulatory readiness
In September 2026 IOGP published Report 584-01, the first international guide dedicated to FPSO decommissioning and recycling. GSR turns that map into answers for a specific unit: what applies, what is missing and what each route costs.
What changed
Until recently, decommissioning a floating production unit was handled as a variant of fixed-platform removal. With the Hong Kong Convention in force and the IOGP addendum, an FPSO is also read as a ship to be recycled and, once the decision to dispose is taken, as waste.
In practice, flag, contamination and destination stop being execution details. They determine whether the unit can stay in country, where it may go and how long it takes to reach the tow.
26 Jun 2025
Hong Kong Convention enters into force
Sep 2026
IOGP Report 584-01 published
5
Recycling destinations reviewed by IOGP; none in Brazil
Assessment
This is what GSR checks before any cost estimate. Each point has its own rule, authority and document.
The flag determines where the unit may be recycled. Units flagged in a party state — Panama, Liberia and the Marshall Islands, among others — may only go to an authorised yard in another party state. Brazil has started accession but is not yet a party.
Once disposal is decided, the FPSO is waste under the Basel Convention. Recycling in country involves no transboundary movement. Exporting requires prior informed consent from every state of export, transit and import.
Scale and sludge in production systems may contain naturally occurring radioactive material. In Brazil NORM sits outside the National Solid Waste Policy and falls under ANSN, with CNEN Resolution 288/2021 being replaced.
Mercury binds to the corrosion layer of tanks and equipment, and torch cutting releases vapour. The Minamata Convention uses 15 mg/kg but sets no surface-contamination threshold — and steel mills tend to reject contaminated scrap.
Under NORMAM-303, sun coral removal requires an opinion from the environmental agency, and the tow is only authorised after it. NORMAM-401 added a biofouling management section in June 2025.
Chapter 6 of NORMAM-303 lists what the Port Captaincy requires from a floating unit being decommissioned, before and after approval of the executive programme.
Domestic or export
Export may make sense. But every step below carries cost and time that belong in the number before the decision.
Units flagged in a Hong Kong Convention party state depend on Brazil's accession to be recycled in the country.
What GSR delivers
The six points checked for the specific FPSO, with status, gap and owner for each.
Recycling in Brazil against export, with cost, time and the requirements that weigh on each — including NORM return and guarantees.
A documentary plan independent of CircularOS: define weighing records, inventory links and decontamination evidence required before destination, according to the agreed scope. Any digital support from CircularOS is proposed and in development, without validated production operation.
Technical material organised for the operator to build its PDI. Submission to ANP and other authorities remains with the operator.
Where Brazil stands
Status checked on 16 Sep 2026.
Based on IOGP Report 584-01 — FPSO decommissioning regulations, addendum to IOGP Report 584 (September 2026), and the Brazilian rules cited. This is GSR's technical reading, not legal advice; how it applies to a given unit requires specific analysis. Submission to regulators remains the operator's responsibility.
