Inventory of Hazardous Materials Full Certification

The regulatory landscape for ship recycling

In view of increased concern about various environmental issues, the focus on the use of non-hazardous materials in ship design, building and operation is also increasing. Two regulations, presently governing the requirements of the Inventory of Hazardous Materials (IHM) and authorization of ship recycling facilities, are:

The EU Regulation on Ship Recycling (EU) No. 1257/2013 (EU SRR), in force for European flagged vessels and 3rd party flagged vessels, visiting European ports or anchorages, equal to and above 500 GT.

Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships, 2009 SR/CONF/45 (HKC), which will enter into force in June 2025.

Impact on new builds and ship in service

All ships of or above 500 GT shall have a certified IHM on board. With the EU SRR, regardless of their flag or trading area, most shipyards already offer IHM preparation for new builds, so the additional impact of the HKC is not expected to be large.

Ships in service shall comply with this requirement by 26 June 2030 or before going to recycling if this is earlier. The world fleet consists of about 53,000 vessels within the scope of HKC. AMG1 estimates that with the full application of the EU SRR, about 30,000 vessels are already carrying an IHM Certificate or Statement of Compliance. Still, a large volume of about 23,000 vessels would need to be equipped with a certified IHM over the coming years.

The maintenance of the IHM in case of any changes in the ship’s structure or equipment will become more important with the entry into force of the HKC, as Port State Control is expected to focus on IHM inspections globally.

Recommendations

Ship owners and managers, shipyards and ship recycling facilities are advised to familiarize themselves with the compliance requirements of the HKC. AMG1 will provide further guidance in the coming period to prepare for the implementation of the HKC.