Ship Recycling

Regulation (EU) No 1257/2013 (EU SRR)

General

Introduction

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Main goals:

• enhance safety, the protection of human health and of the Union marine environment throughout a ship′s life-cycle, in particular to ensure that hazardous waste from such ship recycling is subject to environmentally sound management.

• direct ships flying the flag of a Member State to ship recycling facilities that practice safe and environmentally sound methods of dismantling

• facilitate the ratification of the Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships, 2009 (‘the Hong Kong Convention’).

See attached file “EU Regulation 1257_2013”

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EU SRR also lays down requirements for ship owners, administrations and recognised organisations regarding the development, surveying and certification of inventories of hazardous materials (IHMs) found in ships.The EU SRR’s requirements for the development of the Inventory are in fact almost entirely based on the respective requirements of the Hong Kong Convention. An IHM developed in accordance with the EU SRR must be compiled taking into account the relevant IMO guidelines.Nevertheless, EU legislation sets a few more requirements for the Inventory than the Hong Kong Convention does. Therefore, it is essential that the development and maintenance of the IHM in pursuance of the EU SRR is done:

1. in a harmonised and comprehensive manner in the light of the international knowledge and experience as reflected most notably in the relevant IMO guidelines, while

2. taking into account the specificities of the EU legislative context, in particular of the EU SRR itself.

Adoption and Entry in Force

Regulation (EU) No 1257/2013 of the European Parliament and of the Council of 20 November 2013 ‘on ship recycling and amending Regulation (EC) 1013/2006 and Directive 2009/16/EC’ was published in the Official Journal of the EU on 10 December 2013. It entered into force on 30 December 2013.Its articles will apply at various stages, as detailed in article 32 of the Regulation (EU) No 1257/2013,

Abbreviations

IC Inventory CertificateIHM Inventory of Hazardous MaterialsHM Hazardous Material

LDT Light displacement tonnes

MD Material DeclarationPCHM Potentially Containing Hazardous MaterialRfRC Ready for Recycling CertificateSRP Ship Recycling PlanSDoC Supplier’s Declaration of ConformityEU SRR Regulation (EU) No 1257/2013 on Ship Recycling VSCP Visual/Sampling Check Plan

Definition

As per Regulation (EU) No 1257/2013, article 3:‘ship’ means a vessel of any type whatsoever operating or having operated in the marine environment, and includes submersibles, floating craft, floating platforms, self- elevating platforms, Floating Storage Units (FSUs), and Floating Production Storage and Offloading Units (FPSOs), as well as a vessel stripped of equipment or being towed.‘new ship’ means a ship for which either:(a) the building contract is placed on or after the date of application of EU SRR (i.e. 31 December 2018);(b) in the absence of a building contract, the keel is laid or the ship is at a similar stage of construction six months after the date of application (i.e. 6 months after 31 December 2018) of EU SRR or thereafter; or(c) the delivery takes place thirty months after the date of application (i.e. 30 months after 31 December 2018) of EU SRR or thereafter;‘hazardous material’ means any material or substance which is liable to create hazards to human health and/or the environment;‘light displacement tonnes (LDT)’ means the weight of a ship in tonnes without cargo, fuel, lubricating oil in storage tanks, ballast water, fresh water, feedwater, consumable stores, passengers and crew and their effects and it is the sum of the weight of the hull, structure, machinery, equipment and fittings of the ship.‘new installation’ means the installation of systems, equipment, insulation or other material on a ship after the date of application of the EU SRR;

Reference documents

• Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships, 2009 as set out in final Act of the Conference SR/CONF/46 (hereafter referred to as "Hong Kong Convention"), see attached file “HongKong Convention”

• Regulation (EU) No 1257/2013 of the European Parliament and of the Council on ship recycling (hereafter referred to as "EU SRR"), See attached file “EU Regulation 1257_2013”

• EMSA’s Best Practice Guidance on the Inventory of Hazardous Materials (hereafter referred to as "EMSA IHM Guidance")., see attached file “EMSA IHM Guidance”

• 2023 Guidelines for the development of the Inventory of Hazardous Materials as set out in the annex to resolution MEPC.379(80), see attached file “MEPC.379(80)”

• 2012 Guidelines for the survey and certification of ships under the Hong Kong Convention, as set out in the annex to the resolution MEPC.222(64), see attached file “MEPC.222(64)”

• IACS Rec. 113 (Rev.1 Oct 2012) - Expert Parties Engaged in Visual and/or Sampling Checks for Preparation of Inventory of Hazardous Materials, see attached file “IACS_REC113_Rev1”

• EMSA Study of two hazardous substances (PFOS and HBCDD) included in the annexes of regulation (EU) 1257/2013 on ship recycling see attached file “EMSA Study of two hazardous substances PFOS and HBCDD”

Application

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The EU SRR applies to ships on international voyages, of 500GT and above flying the flag of a EU Member State or the flag of a third country when calling at a port or anchorage of a EU Member State (Article 2 and 12 of EU SRR).

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EU SRR does not apply to:

• any warships, naval auxiliary, or other ships owned or operated by a state and used, for the time being, only on government non-commercial service;

• ships of less than 500 gross tonnage (GT);

• ships operating throughout their life only in waters subject to the sovereignty or jurisdiction of the Member State whose flag the ship is flying.

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According to Article 3 of EU SRR, ‘ship’ means a vessel of any type whatsoever operating or having operated in the marine environment, and includes submersibles, floating craft, floating platforms, self- elevating platforms, Floating Storage Units (FSUs), and Floating Production Storage and Offloading Units (FPSOs), as well as a vessel stripped of equipment or being towed;

Enforcement Timeline

Application of EU SRR is related to three main dates (see timeline Fig.1)

• 1st publication of European List of ship recycling facilities -> 19 December 2016 – refer to 1st Publication of European List of ship recycling facilities - 19 December 2016

• General Application -> 31 December 2018 - refer to General Application (Article 32(1) of EU SRR) - 31 December 2018

• Delayed application -> 31 December 2020 - refer to Delayed application (Article 32.(2)(b))

1st Publication of European List of ship recycling facilities - 19 December 2016

The List was first established on 20 December 2016 (as set out in the Annex to the Commission Implementing Decision (EU) 2016/2323) .This list includes a total of 18 ship recycling facilities located in the European Union as compliant with the relevant requirements of EU SRR. See attached document “DECISION EU 2016_2323”

General Application (Article 32(1) of EU SRR) - 31 December 2018

1. General application of EU SRR starts the earlier date of:

   - 6 months after the combined output of the EU List SRFs is 2,5 million LDTs, or- 31/12/2018

   However, the combined output of the EU List SRF, never reached the trigger value in due time, so the EU SSR General application has been enforced on 31 December 2018 (i.e. latest date)

2. From 31 December 2018:

   - New EU ships must be subject to initial survey (Article 8(4)), The survey shall verify that Part I of the IHM identify at least the HM referred to in Annex II of EU SRR (Article 5(1)). Those ships must be issued with IC (Article 9).

   - EU ships going for recycling will be subject to final survey (Article 8(7)) and must be issued with RfRC (Article 9(9)).

Delayed application (Article 32.(2)(b))

From 31 December 2020:

- Existing EU ships must have been subject to initial survey (Article 8(4)). The survey shall verify that Part I of the IHM identify at least the HM referred to in Annex I of EU SRR (Article 5(2)). Those ships must be issued with IC (Article 9)- Non-EU ships calling EU ports/anchorages must have been subject to initial survey (Article 12(6)). The survey shall verify that Part I of the IHM identify at least the HM referred to in Annex I of EU SRR (Article 12(1)). Those ships must be issued with SoC (Article 12(6))

Establishment and updating of the European List of ship recycling facilities

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Pursuant to Article 16(1) of Regulation (EU) No 1257/2013 :The Commission shall adopt implementing acts to establish a European List of ship recycling facilities which:(a) are located in the Union and have been notified by the Member States in accordance with Article 14(3);(b) are located in a third country and whose inclusion is based on an assessment of the information and supporting evidence provided or gathered in accordance with Article 15.

Establishment of the European List

Refer to 1st Publication of European List of ship recycling facilities - 19 December 2016

Updating of the European List

Refer to the below list in amending Implementing Decision (EU) 2016/2323 establishing the European List of ship recycling facilities pursuant to Regulation (EU) No 1257/2013 of the European Parliament and of the Council.

HMs controlled / listed in annex I and annex II of EU SRR

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As per EU SRR, Article 4, the installation or use of hazardous materials referred to in Annex I on ships shall be prohibited or restricted as specified in Annex I, without prejudice to other requirements of relevant Union law which may require further measures.

Annex I of EU SRR provide a list of the 5 HM which are prohibited or restricted, see Annex I of Regulation (EU) No 1257/2013 (EU SSR)

• Asbestos

• Ozone-depleting substances (ODS)

• Polychlorinated biphenyls (PCB)

• Anti-fouling compounds and system

• Perfluorooctane sulfonic acid (PFOS)

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Annex II of EU SRR provide the list of HM (HM from Annex I + 10 additional HMs) which shall be identified in IHM , as applicable See Annex II of Regulation (EU) No 1257/2013 (EU SSR)

• Any hazardous materials listed in Annex I

• Cadmium and Cadmium Compounds

• Hexavalent Chromium and Hexavalent Chromium Compounds

• Lead and Lead Compounds

• Mercury and Mercury Compounds

• Polybrominated Biphenyl (PBBs)

• Polybrominated Diphenyl Ethers (PBDEs)

• Polychlorinated Naphthalenes

• Radioactive Substances

• Certain Shortchain Chlorinated Paraffins

• Brominated Flame Retardant (HBCDD)

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HM provided in Annex I and Annex II of the EU SRR are based on the ones provided in appendices 1 and 2 of the Hong Kong Convention.However EU SRR require the control / listing of two additional HM :Perfluorooctane sulfonic acid (PFOS) added in annex I of EU SRR Brominated Flame Retardant (HBCDD) added in annex II of EU SRR Annex C of EMSA guidance document provide some indicative specific test methods on the two additional HM (PFOS and HBCDD). see attached file “EMSA IHM Guidance”

Refer to EMSA Study of two hazardous substances (PFOS and HBCDD) included in the annexes of regulation (EU) 1257/2013 on ship recycling. See attached file “EMSA Study of two hazardous substances PFOS and HBCDD”

Minimum Initial Control

The following Figure summarizes the minimum¹ initial control and respective inclusion in the IHM of the two additional HM on board ships either flying the flag of a Member State or a flag of a third country:

* After the initial preparation of the IHM, it shall be properly maintained and updated reflecting new installations containing HM referred to in Annex II of the SRR (meaning that thereafter all the HM included in Annex I and Annex II of the EU SRR should be included in the IHM).** After the initial preparation of the IHM, it shall be properly maintained and updated reflecting new installations containing HM referred to in Annex II of the SRR taking into account the exemptions and transitional arrangements applicable to those materials under international law.

¹ N.B.: For existing and non-EU ships, HM included only in Annex II of the EU SRR should be identified in the IHM as far as practicable

Overview of IHM

Development of IHM

The development procedure of the IHM Part I differs depending on whether the ship is a new or an existing one. The development procedure of the IHM Part II and Part III relates only to ships flying the flag of a Member State when going for recycling. Refer to Development process of the IHM Part II for ships going for recycling (Shipowner responsability) and Development process of the IHM Part III for ships going for recycling (Shipowner responsability).

The development and maintenance of the IHM is a key requirement of the EU SRR. The EU SRR requires ‘ships’ to have it on board therefore, the obligation lies in principle with the shipowner. Furthermore, the ‘installation’ (or use) of HM referred to in Annex I of the EU SRR is prohibited or restricted and, subsequently, this entails additional responsibilities to the shipbuilders and other stakeholders (e.g. to manufacturers and suppliers).

Use of IHM Expert

The ship owner or the shipbuilder may draw upon assistance by an IHM expert company / Service Supplier (refer to IMO MEPC.379(80), IACS Rec113, EMSA’s Best practice Guidance for IHM).Surveyors shall verify that IHM including the VSCP have been prepared by personnel with the requisite knowledge and experience to conduct the assigned task.

Content of IHM

The Inventory consists of:Part I: HM contained in ship structure or equipment and referred to in Annexes I and II of the EU SRR;Part II: Operationally generated wastes; andPart III: Stores

Format of IHM

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The Inventory should be developed on the basis of the standard format set out in appendix 2 and appendix 5 of the IMO guidelines “2023 Guidelines for the development of the Inventory of Hazardous Materials” as set out in resolution MEPC.379(80) see Appendix 5 of resolution MEPC.379(80) “2023 Guidelines for the development of the Inventory of Hazardous Materials”

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However, in this format there should be a reference stating that the IHM has been developed to cover also the requirements of the EU SRR*. This would entail that the Inventory would keep the classification of Materials according to the IMO guidelines with the addition of two HM (PFOS and HBCDD) as appropriate.* E.g.: “the Inventory follows the requirements set out in the HKC and in the EU Ship Recycling Regulation (EU) 1257/2013”

Materials to be listed in the Inventory

Each item in appendix 1 of resolution MEPC.379(80) is classified under tables A, B, C or D, according to its properties, see Appendix 1 of of resolution MEPC.379(80) “2023 Guidelines for the development of the Inventory of Hazardous Materials” AS AMENDED BY RESOLUTION MEPC.405(83)

1. table A comprises the materials listed in appendix 1 of the Honk Kong Convention;

2. table B comprises the materials listed in appendix 2 of the Honk Kong Convention;

3. table C (Potentially hazardous items) comprises items which are potentially hazardous to the environment and human health at ship recycling facilities; and

4. table D (Regular consumable goods potentially containing hazardous materials) comprises goods which are not integral to a ship and are unlikely to be dismantled or treated at a ship recycling facility.

Additional HMs required by EU SRR shall be listed in part I of IHM, as appropriate, refer to HMs controlled / listed in annex I and annex II of EU SRR

An overview of the applicability of the three parts of IHM at different stages in a ship's life cycle is provided in below:

For loosely fitted equipment, there is no need to list this in part I of the Inventory. Such equipment which remains on board when the ship is recycled should be listed in part III (MEPC.379(80)).

Those batteries containing lead acid or other hazardous materials that are fixed in place should be listed in part I of the Inventory. Batteries that are loosely fitted, which includes consumer batteries and batteries in stores, should be listed in part III of the Inventory (MEPC.379(80)).Similar materials or items that contain hazardous materials that potentially exceed the threshold value can be listed together (not individually) on the IHM with their general location and approximate amount specified there ("bulk listing"). An example of how to list those materials and items is shown in row 3 of table 1 of appendix 3 of resolution MEPC.379(80).

Exemptions – Materials not required to be listed in the Inventory – MEPC.379(80)

Materials listed in Table B that are inherent in solid metals or metal alloys, such as steels, aluminium, brasses, bronzes, plating and solders, provided they are used in general construction, such as hull, superstructure, pipes or housings for equipment and machinery, are not required to be listed in the Inventory.Although electrical and electronic equipment is required to be listed in the Inventory, the amount of hazardous materials potentially contained in printed wiring boards (printed circuit boards) installed in the equipment does not need to be reported in the Inventory.

Maintenance of IHM

- According to article 5(6) of the EU SRR, Part I of the IHM of ships flying the flag of a Member State shall be properly maintained and updated throughout the operational life of the ship, reflecting new installations containing any HM referred to in Annex II of the Regulation and relevant changes in the structure and equipment of the ship.- According to article 12(4) of the EU SRR, the IHM of ships flying the flag of a third country shall be properly maintained and updated throughout the operational life of the ship, reflecting new installations containing any HMs referred to in Annex II of the Regulation and relevant changes in the structure and equipment of the ship, taking into account the exemptions and transitional arrangements applicable to those materials under international law.Therefore, shipowners should establish the necessary procedures on board the ship and within their company to manage their long-term environmental responsibilities. Refer to para Maintenance and update of the IHM Part I (Shipowner responsability)

Development process of the IHM - MEPC.379(80) + EMSA IHM Guidance (Shipowner responsability)

Development process of the IHM Part I for existing ships / ships going for recycling / non-EU ships

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Part I of the Inventory for existing ships / ships going for recycling / non-EU ships shall be developed by the shipowner. Development shall be based on IMO guidelines “2023 Guidelines for the development of the Inventory of Hazardous Materials “ as set out in resolution MEPC.379(80) and EMSA IHM Guidance.

The development process shall include five steps:.1 collection of necessary information;.2 assessment of collected information;.3 preparation of visual/sampling check plan;.4 onboard visual check and sampling check; and.5 preparation of part I of the Inventory and related documentation

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The flow diagram for developing Part I of the IHM for existing ships is described in Appendix 4 of the IMO 2015 Guidelines for the development of the Inventory of Hazardous Materials as set out in resolution MEPC.379(80) and should be consulted during process for developing the IHM according to the EU SRR – refer to flow diagram below FLOW DIAGRAM FOR DEVELOPING PART I OF THE INVENTORY FOR EXISTING SHIPS – MEPC.379(80) –Appendix 4.Appendix 5 of resolution MEPC.379(80) provides an example of development process for Part I of the inventory for existing ships. See Appendix 5 of resolution MEPC.379(80) “2023 Guidelines for the development of the Inventory of Hazardous Materials”

*1 : Documents may include any certificates, manuals, ship's plans drawings, technical specifications and information from sister and/or similar ships.*2 : The assessment should cover all materials listed in table A of appendix 1 of the Guideline; the materials listed in table B should be listed as far as practicable.It is impossible to assess all equipment and areas including those which are assumed not to contain hazardous materials described aboveUsing analysis of available documents based on knowledge and experience, it must be made clear which equipment and/or area should be included in the scope of the assessment.*3 : Equipment, system and/or areas which cannot be specified as containing materials listed in appendix 1 of these guidelines on the basis of documents can be listed in the List of equipment, system and/or area classed as "potentially containing hazardous material" without the sampling check. The prerequisite for this classification is a comprehensible justification of the conclusion, such as the impossibility to conduct samplings without compromising ship safety and operational efficiency.*4 : Sampling check. This means sampling and identification of hazardous material contained in the equipment, systems, and/or areas, by laboratory analysis. The sampling check should be applied where the presence of prohibited and restricted hazardous material is assumed but cannot be recognized by analysis of the available documentation.*5 : When equipment, systems and/or areas of a ship are not accessible for visual check or sampling check, this equipment, system and/or area is classified as "potentially containing hazardous material”.

STEP 1. Collection of necessary information

It should be conducted in accordance with the IMO guidelines (MEPC.379(80)). The shipowner should make every possible effort to obtain all reasonably available documentation regarding the ship.It is impossible to check all equipment, systems, and/or areas on board the ship to determine the presence or absence of hazardous materials. The total number of parts on board may exceed several thousand. In order to take a practical approach, an indicative list should be prepared that identifies the equipment, system, and/or area on board that is presumed to contain hazardous materials. Field interviews with the shipyard and suppliers may be necessary to prepare such lists. A typical example of an indicative list is shown in the Appendix 5 of resolution MEPC.379(80). See Appendix 5 of resolution MEPC.379(80) “2023 Guidelines for the development of the Inventory of Hazardous Materials”

STEP 2. Assessment of collected information

The information collected should be assessed to cover all HMs referred to in Annex I of the EU SRR –refer to . HM included in the Annex II of the EU SRR should be assessed as far as practicable. Preparation of a checklist is an efficient method for developing the Inventory for existing ships in order to clarify the results of each step.When a component or coating is determined to contain HMs, a "Y" should be entered in the column for "Result of document analysis" in the checklist, to denote "Contained". Likewise, when an item is determined not to contain HMs, the entry "N" should be made in the column to denote "Not contained". When a determination cannot be made as to the hazardous materials content, the column should be completed with the entry "Unknown".The results of the assessment should be reflected in the visual/sampling check plan.

STEP 3 Preparation of visual/sampling check plan

A ‘visual/sampling check plan’ (VSCP) should be prepared in accordance with the IMO guidelines (MEPC.379(80)) and the provisions of this EMSA IHM guidance.The preparation of a VSCP for targeted sampling on an existing ship and on a ship flying the flag of a third country, when developing the IHM, is a legal requirement (Article 5(4) and Article 12(3) of the EU SRR).It shall be based on three lists:

.1 List of equipment, system and/or area for visual check Each item classified as "Contained" or "Not contained" in step 2 should be subjected to a visual check on board, and the entry "V" should be made in the "Check procedure" column to denote "Visual check”.2 List of equipment, system and/or area for sampling For each item categorized as "unknown", a decision should be made as to whether to apply a sampling check.A sampling check is the taking of samples to identify the presence or absence of hazardous material contained in the equipment, systems, and/or areas, by suitable and generally accepted methods such as laboratory analysis); and.3 List of equipment, system and/or area classed as "potentially containing hazardous material"(PCHM)Any item categorized as "unknown" may be classed as "potentially containing hazardous material" provided comprehensive justification is given, or if it can be assumed that there will be little or no effect on disassembly as a unit and later ship recycling and disposal operations. For example, in order to carry out a sampling check for "Packing with aux. boiler" the shipowner needs to disassemble the auxiliary boiler in a repair yard. The costs of this check are significantly higher than the later disposal costs at a ship recycling facility. In this case, therefore, the classification as "potentially containing hazardous material" is justifiable.

If random sampling is to be conducted along with targeted sampling the VSCP should reflect the items identified by the document analysis as ‘not contained’ (or PCHM) that may be checked by random sampling - see EMSA IHM Guidance chapter 4.5.1.

Following the preparation of the VSCP a risk assessment should take place to determine the existing risks and to identify the necessary precautions and safety procedures to be followed during the HM survey and sampling - see EMSA IHM Guidance chapter 4.5.1.

STEP 4. On board visual/sampling check

Targeted sampling should be carried out in accordance with the IMO guidelines (MEPC.379(80)) and with reference to a predecided sampling methodology as described in EMSA IHM Guidance chapter 4.5.1.When a sampling check is carried out, samples should be taken and the sample points should be clearly marked on the ship plan and the sample results should be referenced. Materials of the same kind may be sampled in a representative manner. Such materials are to be checked to ensure that they are of the same kind. The sampling check should be carried out drawing upon expert assistance.Any uncertainty regarding the presence of HMs should be clarified by a visual/sampling check. Checkpoints should be documented in the ship's plan and may be supported by photographs.If the equipment, system and/or area of the ship are not accessible for a visual check or sampling check, they should be classified as "potentially containing hazardous material". The prerequisite for such classification should be the same prerequisite as in STEP 3 above. Any equipment, system and/or area classed as "potentially containing Hazardous Material" may be investigated or subjected to a sampling check at the request of the shipowner during a later survey (e.g. during repair, refit or conversion).The entity carrying out the HM survey and sampling should be an IHM expert as defined in EMSA IHM Guidance document. Refer to Use of IHM Expert

The shipowner may also establish a policy for performing random sampling of materials on board existing ships after the initial preparation of the Inventory (e.g. when purchasing a ship or after a repair or conversion of the ship). In this context, the same process as for carrying out random sampling on a new ship may be applied as far as practicable.

STEP 5. Preparation of Part I of the Inventory and related documentation

The IHM should be prepared by filling out the standard format set out in Appendix 2 and Appendix 5 of the IMO guidelines in resolution MEPC.379(80). See Appendix 5 of resolution MEPC.379(80) “2023 Guidelines for the development of the Inventory of Hazardous Materials” and para Format of IHM

If any equipment, system and/or area is classed as either "containing hazardous material" or "potentially containing hazardous material", their approximate quantity and location should be listed in part I of the Inventory. These two categories should be indicated separately in the "Remarks" column of the Inventory.

In case of equipment, system and/or area is classed as "containing hazardous material", the proper justification should be included in the report associated with the inventory, on the compliance with the control measures listed in Annex I of EU SRR (i.e. installation not prohibited or restricted as specified in Annex I)

A diagram showing the location of the identified HMs should also be prepared. The collected documents should be listed in an archive which should follow the ship throughout its operational life.

Development process of the IHM Part II for ships going for recycling (Shipowner responsability)

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IHM Part II for operationally generated wastes shall be developed, once the decision to recycle a ship has been taken.

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Resolution MEPC.379(80) provide a catalogue of potentially HM in table C of appendix 1 listing the materials either in Part II or in Part III of the Inventory. See Appendix 1 of of resolution MEPC.379(80) “2023 Guidelines for the development of the Inventory of Hazardous Materials” AS AMENDED BY RESOLUTION MEPC.405(83)

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If the wastes listed in part II of the Inventory provided in Resolution MEPC.379(80) appendix 1, table C are intended for delivery with the ship to a ship recycling facility, the quantity of the operationally generated wastes should be estimated and their approximate quantities and locations should be listed in part II of the Inventory.

Development process of the IHM Part III for ships going for recycling (Shipowner responsability)

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IHM Part III for stores shall be developed, once the decision to recycle a ship has been taken.

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Resolution MEPC.379(80) provide a catalogue of potentially HM in table C of appendix 1 listing the materials either in Part II or in Part III of the Inventory. See Appendix 1 of of resolution MEPC.379(80) “2023 Guidelines for the development of the Inventory of Hazardous Materials” AS AMENDED BY RESOLUTION MEPC.405(83). Resolution MEPC.379(80) provide a catalogue of regular consumable goods in table D of appendix 1 listing the materials in Part III of the Inventory. See Appendix 1 of of resolution MEPC.379(80) “2023 Guidelines for the development of the Inventory of Hazardous Materials” AS AMENDED BY RESOLUTION MEPC.405(83)

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If the stores to be listed in part III of the Inventory provided in table C of appendix 1 are to be delivered with the ship to a ship recycling facility, the unit (e.g. capacity of cans and cylinders), quantity and location of the stores should be listed in part III of the Inventory.If any liquids and gases listed in table C of appendix 1 are integral in machinery and equipment on board a ship, their approximate quantity and location should be listed in part III of the Inventory. However, small amounts of lubricating oil, anti-seize compounds and grease which are applied to or injected into machinery and equipment to maintain normal performance do not fall within the scope of this provision. For subsequent completion of part III of the Inventory during the recycling preparation processes, the quantity of liquids and gases listed in table C of appendix 1 required for normal operation, including the related pipe system volumes, should be prepared and documented at the design and construction stage. This information belongs to the ship, and continuity of this information should be maintained if the flag, owner or operator of the ship changes.Regular consumable goods, as provided in table D of appendix 1 should not be listed in part I or part II but should be listed in part III of the Inventory if they are to be delivered with the ship to a Ship Recycling Facility. A general description including the name of item (e.g. TV set), manufacturer, quantity and location should be entered in part III of the Inventory. The check on materials provided for in paragraphs 4.1.2 and 4.1.3 of Resolution MEPC.379(80) does not apply to regular consumable goods (i.e. HM listed in Table A and B).

Maintenance and update of the IHM Part I (Shipowner responsability)

EU SRR requirements ( Article 5 & 12)

According to paragraph 6 of Article 5 of the EU SRR, for EU Ships and paragraph 4 of Article 12 of the EU SRR for Non EU Ships, the IHM Part I shall be properly maintained and updated throughout the operational life of the ship, reflecting new installations containing any hazardous materials referred to in Annex II* of the Regulation and relevant changes in the structure and equipment of the ship. *For EU Ship this means that all the HM included in Annex I and Annex II of the EU SRR shall be included in the IHM (i.e. the 15 HMs listed in Annex I and II of EU SRR)For non EU ships this means that all the HM included in Annex I - except PFOS - and Annex II of the EU SRR shall be included in the IHM (i.e. the 14 HMs listed in Annex I and II of EU SRR)

Requirements for ascertaining the conformity of the inventory during operation (MEPC.379(80) + EMSA IHM Guidance)

The shipowner is responsible for the maintenance of Part I of the IHM during the lifetime of the ship. Part I of the IHM should belong to the ship and the continuity and conformity of the information it contains should be confirmed, especially if the flag, owner or operator of the ship changes. .(MEPC.379(80) +EMSA IHM Guidance)Shipowners should implement the following measures in order to ensure the conformity of part I of the Inventory:

1. To designate a person as responsible for maintaining and updating the Inventory (the designated person may be employed ashore or on board);

2. The designated person should establish and supervise a system to ensure the necessary updating of the Inventory in the event of new installation;

   Note : A software tool may be used to support the IHM development and maintenance process and the management of all the relevant documents, information and data.

3. To maintain the Inventory including dates of changes or new deleted entries and the signature of the designated person.

   If any machinery or equipment is added to, removed or replaced or the hull coating is renewed, part I of the Inventory should be updated according to the requirements for new ships as stipulated in resolution MEPC.379(80) paragraphs 4.1.2 to 4.1.4 . The respective changes to the IHM shall be made accordingly and all the relevant documentation (e.g. MD and SDoC in case of machinery or equipment is added or sampling reports in case of random sampling) should be collected and maintained in the ship’s archive. (MEPC.379(80) +EMSA IHM Guidance)

   Updating is not required if identical parts or coatings are installed or applied

4. To provide related documents as required for the survey or sale of the ship.

Inclusion of cybutryne in the Inventory of Hazardous Materials IHM requirements under Regulation (EU) No 1257/2013

Refer to attached EU Guidance on the inclusion of Cybutryne in the Inventory of Hazardous Materials IHM requirements under Regulation (EU) No 1257/2013

Background: Amendments to AFS Convention and IMO Guidelines for the development of the IHM

In 2021, IMO, through resolution MEPC.331(76), adopted amendments to the AFS Convention to include controls on the biocide cybutryne. The amendments entered into force on 1 January 2023. Ships shall not apply or re-apply anti-fouling systems containing this substance from 1 January 2023. Ships shall remove or apply a coating to AFS with this substance at the next scheduled renewal of the anti-fouling system after 1 January 2023, but no later than 60 months following the last application to the ship of an anti-fouling system containing cybutryne. Refer to the related survey procedure.

• Revision of the 2015 Guidelines for the development of the Inventory of Hazardous Materials

  IMO confirmed that there was no need for an update to the list of materials for the Inventory of Hazardous Materials under the Hong Kong Convention to include cybutryne following the entry into force of the respective controls, as the existing relevant text in appendix I to the Hong Kong Convention was generic enough. But IMO recognize the need for consequential amendment of the guidelines for the development of the Inventory of Hazardous Materials, in order to cover the control of cybutryne. In that respect IMO adopted the 2023 Guidelines for the development of the Inventory of Hazardous Materials (resolution MEPC.379(80) as amended by resolution MEPC.405(83).

2 EU Guidance on the inclusion of Cybutryne in the Inventory of Hazardous Materials IHM requirements under Regulation (EU) No 1257/2013

EU published guidance which provides the following information for the implementation:

1. All existing IHM documents should not be immediately revised to record Cybutryne if it is present on a ship. But:

   AFS Convention requires ships that have Cybutryne in their anti-fouling system to put a coating that forms a barrier to this substance leaching from the underlying non-compliant anti-fouling system or remove it at the next scheduled renewal of the anti-fouling system after 1 January 2023, but no later than 60 months following the last application to the ship of an anti-fouling system containing Cybutryne. At this stage, the IHM document for the ship in question should be updated/maintained to record the presence/absence of Cybutryne.However, the inclusion of Cybutryne in the IHM should happen immediately when maintenance results in the update of the IHM to include new materials or a survey under Article 8(3) SRR takes place.

   Refer to the diagram in DIAGRAM for the inclusion of Cybutryne in the EXISTING IHM under Regulation (EU) No 1257/2013

2. New ships after 1 January 2023 should have aboard an IHM, which shall record that there is no Cybutryne in their anti-fouling system

Ship recycling plan (Shipowner responsibility)

Untitled

As per EU SRR, Article 7(3)(a):The ship recycling plan shall be developed by the operator of the ship recycling facility in accordance with the relevant provisions of the Hong Kong Convention and taking into account the relevant IMO guidelines and the ship-relevant information provided by the shipowner in accordance with Article 6(1)(a) of EU SRR so that its contents are consistent with the information contained in the inventory of hazardous materials;

The ship recycling plan shall be tacitly or explicitly approved by the competent authority in accordance with the requirements of the state where the ship recycling facility is located, where applicable.

Explicit approval shall be given when the competent authority sends a written notification of its decision on the ship recycling plan to the operator of the ship recycling facility, the ship owner and the administration.Tacit approval shall be deemed given, if no written objection to the ship recycling plan is communicated by the competent authority to the operator of the ship recycling facility, the ship owner and the administration within a review period laid down in accordance with the requirements of the state where the ship recycling facility is located, where applicable, and notified in accordance with Article 15(2)(b).NB: Detailed information of the explicit or tacit procedure for the approval of the ship recycling plan are indicated in the European List of ship recycling facilities. Refer to Updating of the European List for the European List of ship recycling facilities.

‘competent authority’ means a governmental authority or authorities designated by a Member State or a third country as responsible for ship recycling facilities, within a specified geographical area or an area of expertise, relating to all operations within the jurisdiction of that state;

Survey

General

Untitled

As per EU SRR, Article 8, EU Ships shall be subject to the following surveys:(a) an initial survey;(b) a renewal survey;(c) an additional survey;(d) a final survey.

Untitled

When duly delegated by the Ship’s Administration, Recognised Organisation (RO) will performed the appropriate surveys taking into account the provisions of “2012 Guidelines for the survey and certification of ships under the Hong Kong Convention “ – Resolution MEPC.222(64)

Untitled

Non-EU Ships are subject to surveys (intial / renewal / additional) taking into account the provisions of “2012 Guidelines for the survey and certification of ships under the Hong Kong Convention “ – Resolution MEPC.222(64)

Initial survey for EU existing ships and for non EU ships

Untitled

The survey shall verify that Part I of the IHM complies with the requirements of the EU SRR

Untitled

The visual/sampling check plan and Part I of the Inventory of Hazardous Materials should be prepared by personnel with the requisite knowledge and experience to conduct the assigned task, in accordance with the 2015 Guidelines for the development of the inventory of hazardous materials, as may be amended.

Untitled

As per resolution MEPC.222(64) – “2012 Guidelines for the survey and certification of ships under the Hong Kong Convention”, paragraph 3.1.2 :

- Prior to the initial survey for an existing ship, a request for the initial survey should be submitted by the shipowner to Recognised Organisation (RO) along with the ship data required for the Inventory Certificate - The request for an initial survey for an existing ship should be supplemented by Part I of the IHM, and/or the VSCP developed in accordance with the 2015 Guidelines for the development of the Inventory of Hazardous Materials as set out in resolution MEPC.379(80).- Part I of the IHM should be submitted by the shipowner to the Administration or a recognized organization along with supporting information such as the report of the visual/sampling check and/or any MD and SDoC.- The survey should verify that Part I of the IHM identifies the HMs contained and/or potentially contained in the ship structure and equipment, their location and approximate quantities, by checking supporting information such as the report of the visual check and/or sampling check and/or any MD and SDoC.The survey should also clarify that the ship complies with regulations 4 and 5 of the annex to the Hong Kong Convention. (i.e. Controls of ships’ HMs and IHM)Classification as "potentially containing hazardous materials" should be noted in the remarks column of the IHM. The survey should further verify that the IHM, especially the location of HMs, is consistent with the arrangements, structure and equipment of the ship, through onboard visual inspection.

Surveyors duties

Initial survey is divided in two main parts:- Sampling verification of the accuracy, consistency and clarity of the information recorded in the IHM, part I by the Shipyard and which is supported by a SDoC and related MD or VSCP results.- Onboard survey aiming at verifying by sampling the location of the listed equipment, systems and/or areas.Additionally evidence of implementation of a procedure on board the ship for maintaining part I ofthe IHM.

Documentary consistency check

NB : Prior to perform the documentary consistency check, surveyors shall have due regard to the development process of IHM as described in Development process of the IHM - MEPC.379(80) + EMSA IHM Guidance (Shipowner responsability).Particular attention shall be paid to:

• Personnel which have performed visual/sampling checks are properly qualified – refer to Use of IHM Expert

• Ship complies with minimum control measures for the HM listed in Annex I of EU SRR. refer to STEP 5. Preparation of Part I of the Inventory and related documentation

  N.B.: PFOS is not applicable for non –EU ships– refer to HMs controlled / listed in annex I and annex II of EU SRR

• IHM Part I identify, as appropriate, the Hazardous Materials listed in Annex I of EU SRR

  N.B.: PFOS is not applicable for non –EU ships

• Adequate documentation and reports are available / annexed to the IHM in order to assess the correctness of the development process. IHM shall be the result of a rigorous development process and it is therefore essential that the development process has been done in accordance with IMO guidelines “2023 Guidelines for the development of the Inventory of Hazardous Materials” as set out in resolution MEPC.379(80) as amended, including the “5 steps process” - refer to Development process of the IHM - MEPC.379(80) + EMSA IHM Guidance (Shipowner responsability)

• Results of VSCP shall have been reported correctly in the IHM and that any equipment, system and/or area classed as either "containing hazardous material" or "PCHM" are listed with their approximate quantity and location in the IHM.

• The amounts of HM have been estimated properly and located in a plan annexed to the IHM.

Upon satisfactory review, IHM shall be stamped with the following wording:

Reviewed for consistency See (report reference)Recognised Organisation (RO) Marine & Offshore (Survey Centre)Date (date of review completion).

Where documents are approved electronically, Recognised Organisation (RO) Approbat shall be used to endorse the IHM with the dedicated review stamp as per the below:

On board verification

On board verification

On board survey is carried out by the Surveyor to check at random:

• the location of the listed equipment, systems and/or areas

• that no access can be arranged for sampling of equipment, system and/or area listed into the list of equipment, system and/or area classed as “Potentially containing hazardous material”, for those items where no such access is provided.

Lifecycle management

Lifecycle management

Surveyor shall verify that shipowners have implemented a series of measures to ensure the conformity of Part I of the Inventory throughout the operational life of the ship. In this context, designating a person as responsible for maintaining and updating the Inventory is a crucial responsibility for the shipowner.

Renewal survey for existing EU ships and non EU ships

Untitled

The survey shall verify that Part I of the IHM complies with the requirements of the EU SRR

Untitled

As per resolution MEPC.222(64) – “2012 Guidelines for the survey and certification of ships under the Hong Kong Convention”:

- A renewal survey should be carried out at intervals specified by the Administration not exceeding five years.- The request for a renewal survey should be supplemented by the latest version of part I of the IHM, and MD and SDoC regarding any change, replacement or significant repair of structure, equipment, systems, fittings, arrangements and material since the last survey.

- The survey should verify that part I of the IHM is properly maintained and updated to reflect changes in ship structure and equipment, by checking MD and SDoC, and should clarify that the ship complies with regulations 4 and 5 of the annex to the Convention. The survey should also verify that the IHM, especially the location of HMs, is consistent with the arrangements, structure and equipment of the ship, through on-board visual inspection.The survey should further verify that any decision by the shipowner to delete equipment, system and/or area previously classed as "PCHM" from Part I of the IHM is based on clear grounds for believing that the equipment, system and/or area in question contain no HMs.

Additional survey for existing EU ships and for non EU ships

Untitled

As per resolution MEPC.222(64) – “2012 Guidelines for the survey and certification of ships under the Hong Kong Convention”:An additional survey, either general or partial according to the circumstances, may be conducted at the request of the shipowner after change, replacement or significant repair of the structure, equipment, systems, fittings, arrangements and material, which has an impact on the IHM.

Final survey for ships going to recycling - for EU ships

Untitled

1. The final survey shall be conducted prior to the ship being taken out of service and before the recycling of the ship has started.

2. Final survey is applicable to ships flying the flag of a EU Member State.

3. Final survey shall be carried be carried out taking into account the 2012 Guidelines for the survey and certification of ships under the Hong Kong Convention - resolution MEPC.222(64) – see attached file MEPC.222(64).

4. The following graph show the ship recycling process to be followed.

   refer to Ship recycling process from preparation to completion - Appendix 3 of MEPC.210(63) - 2012 Guidelines for safe and environmentally sound ship recycling

Untitled

For existing ships intended for ship recycling, the initial survey and the final survey may be conducted at the same time

Untitled

The final survey shall verify that:

1. the IHM complies with the requirements of Article 5 of EU SRR; (.i.e. inventory of hazardous materials shall, in addition to the properly maintained and updated Part I, incorporate Part II for operationally generated waste and Part III for stores, and be verified by the administration or a recognised organisation authorised by it)

   Upon satisfactory review, IHM shall be stamped with the wording 'reviewed for consistency on XXXX at XXXX'.

2. The ship recycling plan properly reflects the information contained in the IHM and complies with the requirements of Article 7 of EU SRR;

   As referred to in Article 7(3) of EU SRR, the Ship Recycling Plan shall be either explicitly or tacitly approved by the Competent Authority. NB: Detailed information of the explicit or tacit procedure for the approval of the ship recycling plan are indicated in the European List of ship recycling facilities. Refer to Updating of the European List for the European List of ship recycling facilities.

3. The ship recycling facility where the ship is to be recycled is included in the European List. Refer to Updating of the European List

ASMS Items

Surveys related to the EU Inventory Certificate only

ASMS survey check list are available when selecting the survey code:EUIV: EU IHM Documentation ReviewEUII: EU IHM Initial SurveyNB: ASMS survey code EUIV - Documentary consistency check - and EUII -On board verification - , constitute the initial survey. Having carried out a survey in connection with the survey code EUIV is a prerequisite for selecting the survey code EUII. It will not be possible to declare issuance of "EU IHM Certificate/SoC" in case survey EUII is not selected in the Survey selection list. EUIR: EU IHM Renewal SurveyEUIA: EU IHM Additional Survey

EUIO: EU IHM Occasional Survey

Surveys related to the “combined” EU and Hong Kong Convention Inventory Certificate

ASMS survey check list are available and the following survey codes shall be selected in relation to the “combined” EU and Hong Kong Convention Inventory certificate, where applicable (see EU IC): EHIV – EU SRR and Hong Kong Documentation ReviewEHII – EU SRR and Hong Kong Initial surveyNB: ASMS survey code EHIV - Documentary consistency check - and EHII -On board verification - , constitute the initial survey. Having carried out a survey in connection with the survey code EUIV is a prerequisite for selecting the survey code EHII. It will not be possible to declare issuance of " EU and Hong Kong Convention Certificate on IHM" in case survey EHII is not selected in the Survey selection list.EHIR – EU SRR and Hong Kong Renewal surveyEHIA – EU SRR and Hong Kong Additional surveyEHIO – EU SRR and Hong Kong Occasional survey

Surveys related to the EU Ready for recycling Certificate only

ASMS survey check list are available when selecting the survey code:EURV: EU Ready for Recycling ReviewEURF: EU Ready for Recycling Final Survey

Surveys related to the “combined” EU & HK Ready for Recycling Certificate

ASMS survey check list are available when selecting the survey code:

EHRV – EU SRR and Hong Kong Ready for Recycling ReviewEHRF – EU SRR and Hong Kong Final survey

Qualification of Surveyors

Surveyors involved in initial/additional/renewal/final surveys shall be qualified for 'IHM' surveys.

Certification

EU IC

Untitled

All ships flying the flag of a EU Member State shall carry on board a ship a specific ‘Inventory Certificate’ issued by the administration or a RO authorised by it.

Untitled

As per EU SRR article 9, after successful completion of an initial or renewal survey, an inventory certificate shall be issued. That certificate shall be supplemented by Part I of the IHM, referred to in EU SRR Article 5(5)(a).NB: EU Inventory Certificate can be issued to EU ship from General application date i.e. 31 December 2018, when Recognised Organisation (RO) is so delegated by the Flag (refer to flag procedures).

Untitled

An inventory certificate shall be issued for a period specified by the administration, which shall not exceed five years.

Untitled

An inventory certificate shall be endorsed at the request of the ship owner after successful completion of an additional survey conducted in accordance with Article 8(6). Therefore the page of the endorsement at survey shall be reproduced and added to the certificate as considered necessary by the Administration.

Untitled

Inventory certificates issued and endorsed in accordance with Article 9 of EU SRR shall comply with the format set out in the Annex to the COMMISSION IMPLEMENTING DECISION (EU) 2016/2325.Form of EU Certificate on IHM is available in ASMS Certificate.

New “combined” format under both the Hong Kong Convention and Regulation (EU) No 1257/2013

The European Commission adopted new format for Inventory certificate. The update enables ship owners to fulfil their obligations under both the EU's Ship Recycling Regulation and the Hong Kong Convention with a single Inventory certificate, thereby reducing administrative burden without lowering the EU requirements.Unless otherwise instructed by the Flag, from 9 February 2026, the format set out in the Annex to the COMMISSION IMPLEMENTING DECISION (EU) 026/121 (i.e. combined EU & HK IC) shall be issued by Recognised Organisation (RO) for ships of an EU flag that is a party to the Hong Kong Convention, when Recognised Organisation (RO) is duly delegated for both EU SRR and HK Convention survey and certification. Refer to flag procedures.

Enforcement Timeline for the replacement of current certificates & issuance of the new format to be used under both the Hong Kong Convention and Regulation (EU) No 1257/2013

From 9 February 2026 and unless otherwise instructed by the flag, for ships flying a EU flag which has ratified the HK Convention and when Recognised Organisation (RO) is duly delegated for both EU SRR and HK Convention survey and certification, surveyors are instructed to replace EU Inventory Certificate and Hong Kong Inventory certificate by the new “combined” format as per COMMISSION IMPLEMENTING DECISION (EU) 026/121, at the first occasion but not later than next renewal survey under EU SRR. Refer to flag procedures for any specific flag instructions. The certificate format is available in ASMS Certificates under section Recycling of Ships – EU SRR under the document name “For EU Ships International Certificate on Inventory of Hazardous Materials with Hong Kong Convention”. Therefore an International Certificate on Inventory of Hazardous Materials (i.e. “combined” EU & HKC ) may be issued on the basis of:- A renewal survey, ASMS survey code: EHIR, or- An administrative job, in cases where the Flag has specifically instructed us to do so.

Statement of Compliance

SoC for non-EU Ships

All ships flying the flag of a third country, when calling at a port or anchorage of a EU Member State, shall carry on board a ship-specific ‘statement of compliance’ issued by the relevant authorities of the third country whose flag the ship is flying or an organisation authorised by them and supplemented by Part I of the IHM.

Refer to flag procedures for possible specific Flag requirements.

SoC upon owner’s request

In all cases, upon Owner’s request a SoC is to be issued.

Untitled

The SoC is issued after verification of the IHM and the form is available in Certificate Editor and ASMS2.

EU RfRC

Untitled

After successful completion of a final survey in accordance with Article 8(7) of EU SRR, the administration or a recognised organisation authorised by it shall issue a ready for recycling certificate (RfRC). That certificate shall be supplemented by the IHM and the ship recycling plan.NB: EU RfRC can be issued to EU ship from General application date i.e. 31 December 2018, when Recognised Organisation (RO) is so delegated by the Flag (refer to flag procedures).

Untitled

Where the initial survey and the final survey are conducted at the same time as provided for in Article 8(8) of EU SRR, only the EU RfRC shall be issued.

Untitled

EU Ready for recycling certificates issued in accordance with Article 9(9) and endorsed in accordance with Article 10(5) of EU SRR shall comply with the format set out in the Annex to the COMMISSION IMPLEMENTING DECISION (EU) 2016/2321.

Form of EU RfRC is available in ASMS Certificate.

New “combined” format to be used under both the Hong Kong Convention and Regulation (EU) No 1257/2013

The European Commission adopted a new format for Ready for recycling certificate. The update enables ship owners to fulfil their obligations under both the EU's Ship Recycling Regulation and the Hong Kong Convention with a single RfRC certificate, thereby reducing administrative burden without lowering the EU requirements.Unless otherwise instructed by the Flag, from 9 February 2026, format set out in the Annex to the COMMISSION IMPLEMENTING DECISION (EU) 026/116 (i.e. combined EU & HK RfRC) shall be issued for ships of an EU flag, when Recognised Organisation (RO) is duly delegated both EU SRR and HK Convention survey and certification. Refer to flag procedures.

HM found onboard in contravention of statutory requirements - Issuance of EU IC or Statement of Compliance

2 cases may arise:

1. HMs installed in compliance with the “control measures” as specified in Annex I of EU SRR (refer to Untitled) BUT in contravention with other statutory requirements (e.g. asbestos detected on board, in contravention of SOLAS regulation II-1/3-5).

   Unless otherwise instructed by the flag, the presence on board of hazardous materials duly reported in the IHM, Part I must not preclude the issuance of the EU IC or SoC, provided that the proper justifications are included in the report associated with the inventory (refer to STEP 5. Preparation of Part I of the Inventory and related documentation) on the compliance with the control measures listed in Annex I of EU SRR (i.e. installation not prohibited or restricted as specified in Annex I)

   Action shall be undertaken, as appropriate, within the framework of concerned statutory instruments (e.g. SOLAS Safety Construction for materials containing asbestos) and the flag Administration is be contacted for the concerned ship through the MOC. Refer also to flag procedures

   For the application of the provisions of SOLAS regulation II-1/3-5 in relation to the installation of materials which contain asbestos refer to Safety Construction [Under Progress]

2. HMs installed in non-conformity with the “control measures” as specified in Annex I (refer to Untitled)

   The issuance of the EU IC te or SoC is subject to the rectification of the non-conformity identified. The flag Administration is be contacted on a case by case basis through the MOC

Change of Flag, RO or Owner / Manager

1 Change of Flag

Change from Non-EU flag to EU flag

(EU SRR article 12(8))

As per EU SRR article 12(8), non-EU ships applying to be registered under the flag of a EU Member State shall ensure that an inventory of HMs, as provided for in Article 5(2) (i.e. provisions applicable to existing EU ship), is kept on board or is established within six months of the registration under the flag of that EU Member State or during any of the next surveys under Article 8(3) (i.e. renewal or additional survey) whichever comes first.

1. Recognised Organisation (RO) remains the RO issuing the Inventory Certificate

   - With flag agreement (and possible flag instruction, refer to the related survey procedure), an Inventory Certificate may be issued for 6 months or less (when the next survey is within 6 months of the registration) through survey code EUIO with following note “Certificate issued for XX months in accordance with REGULATION (EU) No 1257/2013 article 12(8) and pending review of IHM report /amended report and performance of corresponding initial survey”.

   - Existing IHM shall be endorsed “Accepted on behalf of the Flag of……….at the time of change of Flag based on the approval from (or on behalf of) former Flag …….” and copy attached to survey report.

   - In order to complete the review of Part I of IHM (which shall include PFOS) and corresponding initial survey, survey code EUIO is to be selected. Copy of Part I of IHM first page stamped with the wording “reviewed for consistency on XXXX at XXXX” is to be attached to survey report.

2. Change of RO (issuing the Inventory certificate) to Recognised Organisation (RO)

   In case it is Recognised Organisation (RO) which is contracted by the manager to issue the inventory certificate on behalf of the gaining flag:

   - The attending surveyor is to confirm the consistency of IHM Part I as per Change of RO (issuing the Inventory Certificate/ Statement of Compliance) to Recognised Organisation (RO), without change of Flag; and- With flag agreement (and possible flag instruction refer to the related survey procedure), an Inventory Certificate may be issued for 6 months or less (when the next survey is within 6 months of the registration) through survey code EUIO with following note “Certificate issued for XX months in accordance with REGULATION (EU) No 1257/2013 article 12(8) and pending review of IHM report /amended report and performance of corresponding initial survey”; and- Existing IHM Part I is to be endorsed “Accepted on behalf of the Flag of……….at the time of change of Flag based on the approval from (or on behalf of) former Flag …….” and copy attached to survey report.

   In order to complete the review of Part I of IHM (which shall include PFOS) and corresponding initial survey, survey code EUIO is to be selected. Copy of Part I of IHM first page stamped with the wording “reviewed for consistency on XXXX at XXXX” is to be attached to survey report.

Change from EU flag to EU flag

1. Recognised Organisation (RO) remains the RO issuing the Inventory Certificate

   - Unless otherwise instructed by the Flag, the Inventory Certificate for previous EU flag is to be re-issued for new EU flag through EUIO survey code, keeping the same validity and same reference to Part I of IHM; and- Existing IHM Part I, is to be endorsed “Accepted on behalf of the Flag of……….at the time of change of Flag based on the approval from (or on behalf of) former Flag …….” and copy attached to survey report.

2. Change of RO (issuing the Inventory certificate) to Recognised Organisation (RO)

   In case it is Recognised Organisation (RO) which is contracted by the manager to issue the inventory certificate on behalf of the gaining flag:

   - The attending surveyor is to confirm the consistency of IHM Part I as per Change of RO (issuing the Inventory Certificate/ Statement of Compliance) to Recognised Organisation (RO), without change of Flag; and- Unless otherwise instructed by the Flag, the Inventory Certificate issued by previous RO for previous EU flag is to be re-issued by Recognised Organisation (RO) for new EU flag through EUIO survey code, keeping the same validity and same reference to Part I of IHM; and- Existing IHM Part I, is to be endorsed “Accepted on behalf of the Flag of……….at the time of change of Flag based on the approval from (or on behalf of) former Flag …….” and copy attached to survey report.

Change from EU flag to non EU flag

1. Recognised Organisation (RO) remains the RO issuing the Inventory SoC

   - The Inventory Certificate for previous flag is to be replaced by a SoC* for new flag through EUIO survey code, keeping the same validity and same reference to Part I of IHM; and- Existing IHM Part I, is to be endorsed “Accepted on behalf of the Flag of……….at the time of change of Flag based on the approval from (or on behalf of) former Flag …….” and copy attached to survey report. In case the gaining flag does not accept issuance of SoC* on its behalf, the existing IHM Part I, is to be endorsed “Accepted at the time of change of Flag based on the approval from (or on behalf of) former Flag …….” and copy attached to survey report.

2. Change of RO (issuing the Inventory SoC) to Recognised Organisation (RO)

   In case it is Recognised Organisation (RO) which is contracted by the manager to issue the SoC:

   - The attending surveyor is to confirm the consistency of IHM Part I as per Change of RO (issuing the Inventory Certificate/ Statement of Compliance) to Recognised Organisation (RO), without change of Flag; and- The Inventory Certificate issued by previous RO for previous EU flag is to be replaced by a SoC* for new flag through EUIO survey code, keeping the same validity and same reference to Part I of IHM; and- Existing IHM Part I, is to be endorsed “Accepted on behalf of the Flag of……….at the time of change of Flag based on the approval from (or on behalf of) former Flag …….” and copy attached to survey report. In case the gaining flag does not accept issuance of SoC* on its behalf, the existing IHM Part I, is to be endorsed “Accepted at the time of change of Flag based on the approval from (or on behalf of) former Flag …….” and copy attached to survey report

* Note: refer to the related survey procedure for instructions related to the format of the Inventory SoC accepted by the gaining non-EU flag

Change of RO (issuing the Inventory Certificate/ Statement of Compliance) to Recognised Organisation (RO), without change of Flag

The attending surveyor is to confirm that an Inventory Certificate / SoC in accordance with EU SRR requirements has been issued after an initial survey by the previous RO. In addition the below points are to be verified by the surveyor:- The IHM Part I and report are maintained up-to-date since the last survey- A person from the crew has been appointed responsible for the maintenance of the IHM Part I- Confirmation that lifetime quality management system has been established by the shipowner / manager

Unless otherwise instructed by the Flag (refer to the related survey procedure), Inventory Certificate / SoC* issued by previous RO is to be re-issued by Recognised Organisation (RO) through EUIO survey code, keeping the same validity and same reference to Part I of IHM. When duly delegated by the flag, existing IHM shall be endorsed “Accepted on behalf of the Flag of……….at the time of change of RO based on the approval from former RO …….” and copy attached to survey report. In case the gaining flag does not accept issuance of SoC* on its behalf, the existing IHM Part I, is to be endorsed “Accepted at the time of change of Flag based on the approval from (or on behalf of) former Flag …….” and copy attached to survey report

* Note: refer to the related survey procedure for instructions related to the format of the Inventory SoC accepted by the gaining non-EU flag

Change of Owner / Manager with Recognised Organisation (RO) remaining the RO in charge of the EU IHM

The attending surveyor is to confirm the below points:- The IHM Part I and report are updated to reflect the detail of the new owner / manager.- The IHM Part I and report are maintained up-to-date since the last survey- A person from the crew has been appointed responsible for the maintenance of the IHM Part I- Confirmation that lifetime quality management system has been established by the shipowner / manager

Unless otherwise instructed by the Flag (refer to the related survey procedure), Inventory Certificate / SoC issued to the previous owner / manager is to be re-issued by Recognised Organisation (RO) through EUIO survey code, keeping the same validity and same reference to Part I of IHM. Existing IHM shall be re-endorsed and copy attached to survey report.

EU SRR VERIFICATION CONTRACTING

General

Contracting of EU SRR activity is performed as per requirements of the related management procedure.

Certification of vessels for which Recognised Organisation (RO) is not acting as Classification Society

EU SRR certification for vessels for which Recognised Organisation (RO) is not acting as Classification Society is subject to Flag authorization for such arrangement and MO decision.In case of request of EU SRR certification for vessels for which Recognised Organisation (RO) is not acting as Classification Society the CD of the vessel shall request the authorization for contracting to MO in charge for the vessel.Following the MO acceptance the CD of the vessel shall prepare EU SRR Form I (available in Certificate Editor) and IMO DCS / EU SRR Conditions of Certification (available in Certificate Editor) and send to the Company for signature and original to be sent to HO to the attention of FM_REG for filing and advanced by email with CM in copy.

Hong Kong Convention

General

The Hong Kong Convention aims at ensuring that ships, when being recycled after reaching the end of their operational lives, do not pose any unnecessary risk to human health and safety or to the environment.

The Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships, 2009 (the Hong Kong Convention), was adopted at a diplomatic conference held in Hong Kong, China, from 11 to 15 May 2009, which was attended by delegates from 63 countries.

Entry into force on 26 June 2025

The Bangladesh and Liberia accession brings the combined merchant fleet tonnage of contracting States to the treaty to approximately 45.81% with 22 of contracting States and the combined annual ship recycling volume of the Contracting States during the preceding 10 years amounts to 23,848,453 gross tonnage, equivalent to 3.31% of the required recycling volume. (Source: IMO Public info available on 27/06/2023)

As the thresholds for number of state criterion (15 states), for the tonnage criterion (40%) and ship recycling capacity (not less than 3% of the gross tonnage of the combined merchant shipping of those States mentioned above) are met, the Hong Kong Convention enters into force on 26 June 2025.

Guidelines for the implementation of the convention

Key requirements

The convention has requirements for both ships and ship recycling facilities where the ships will be recycled

1. Ships are required to:• Comply with ban/restriction for 4 Hazardous Materials.• Carry onboard an Inventory of Hazardous Materials (IHM) during the lifetime of the ship• Be recycled at an authorized Ship Recycling Facilities

2. Ship recycling facilities are required to • be authorized by the Competent Authority(ies) of a Party in which they operate• prepare/adopt a Ship Recycling Facility Plan (SRFP)• Develop a ship-specific Ship Recycling Plan (SRP) before any recycling of a ship can take place

Application and implantation for ships at the EIF

Application (Article 3 of HKC)

Article 3 read as follows:

1 Unless expressly provided otherwise in this Convention, this Convention shall apply to:.1 ships entitled to fly the flag of a Party or operating under its authority;[…..]2 This Convention shall not apply to any warships, naval auxiliary, or other ships owned or operated by a Party and used, for the time being, only on government non-commercial service. However, each Party shall ensure, by the adoption of appropriate measures not impairing operations or operational capabilities of such ships owned or operated by it, that such ships act in a manner consistent with this Convention, so far as is reasonable and practicable.3 This Convention shall not apply to ships of less than 500 GT or to ships operating throughout their life only in waters subject to the sovereignty or jurisdiction of the State whose flag the ship is entitled to fly. However, each Party shall ensure, by the adoption of appropriate measures, that such ships act in a manner consistent with this Convention, so far as is reasonable and practicable.4 With respect to ships entitled to fly the flag of non-Parties to this Convention, Parties shall apply the requirements of this Convention as may be necessary to ensure that no more favourable treatment is given to such ships.

Carriage requirements for the Inventory of Hazardous Materials (IHM) at the EIF

- Each new ship shall have on board an Inventory of Hazardous Materials (regulation 5.1)- Existing ships shall have on board an Inventory of Hazardous Materials not later than 5 years after the entry into force of this Convention or before going for recycling if this is earlier, taking into account the guidelines developed by the Organization and the Organization’s Harmonized System of Survey and Certification (regulation 5.2). refer to Harmonisation of surveys

New ship versus existing ship

1. “New ship” means a ship (regulation 1.4):.1 for which the building contract is placed on or after the entry into force of this Convention; or.2 in the absence of a building contract, the keel of which is laid or which is at a similar stage of construction on or after six months after the entry into force of this Convention; or.3 the delivery of which is on or after 30 months after the entry into force of this Convention.

2. “Existing ship” means a ship which is not a new ship (regulation 1.3).

3. In ascertaining whether a ship is a "new ship" or an "existing ship" according to the Convention, the term "a similar stage of construction" in regulation 1.4.2 of the annex to the Convention means the stage at which:.1 construction identifiable with a specific ship begins; and.2 assembly of that ship has commenced comprising at least 50 tonnes or 1% of the estimated mass of all structural material, whichever is less.

Initial Survey & Issuance of International Certificate at EIF

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Hong Kong Convention does not require the control /listing of the following two additional HM requested by EU SSR:- Perfluorooctane sulfonic acid (PFOS) added in annex I of EU SRR - Brominated Flame Retardant (HBCDD) added in annex II of EU SRRProcedure described in Regulation (EU) No 1257/2013 (EU SRR) shall be followed, as applicable, for survey and issuance International Certificate under Hong Kong Convention for existing ships

For new ships, the initial survey shall be conducted taking into the provisions of para.3.1.1 of resolution MEPC.222(64), which includes in particular the verification of the part I of the Inventory of Hazardous Materials based on the Material Declaration and Supplier's Declaration of Conformity, as well as the consistency on board of the location of Hazardous Materials, identified and declared in the Inventory. Refer also to the newbuilding surveys procedure.

Harmonisation of surveys

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The initial and renewal surveys should be harmonized with the surveys required by other applicable statutory instruments of the Organization. (regulation 10.5).

Initial survey for existing ships

As per resolution MEPC.222(64) – “2012 Guidelines for the survey and certification of ships under the Hong Kong Convention”:

3.1.2.1 In the case of an existing ship, an initial survey should be conducted before the International Certificate on Inventory of Hazardous Materials is issued and not later than five years after the entry into force of the Convention. The initial survey should be harmonized with the renewal surveys required by other applicable statutory instruments of the Organization, in line with regulations 5.2 and 10.5 of the annex to the Convention and with the principles established in resolution A.1053(27), as amended (Survey Guidelines under the Harmonized System of Survey and Certification (HSSC), 2011).

Recognised Organisation (RO) Policy: Unless otherwise instructed by the flag, the initial survey for the existing ships shall be carried out at or before the renewal survey of other statutory certificates on or after 26 June 2025. The term of the certificate shall be harmonized with other statutory certificates in line with regulations 5.2 and and 10.5 of the Convention.

Scope of the survey for existing ships conforming with recycling requirements (EU SRR, SoC HKC, Green Passport notation, CAC)

Recognised Organisation (RO) policy, unless otherwise instructed by the flag, will be that a survey will be required to verify that the IHM has been properly maintained and updated and it is representative of the arrangement, structure and equipment onboard.

Therefore, for these ships, and within the framework of the entry into force of the HK Convention, an International Certificate on Inventory of Hazardous Materials may be issued on the basis of:- A renewal survey, ASMS survey code: HKIR (or EHIR for the issuance of the “combined” EU & HKC Certificate), or- An administrative job, in cases where the Flag has specifically instructed us to do so.

Refer to flag procedures for possible specific flag instructions for the issuance of HKC Certificate

Certificates

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SoC under Hong Kong Convention is available in ASMS2 Certificate, and International Certificate under Hong Kong Convention and International Ready for Recycling Certificate are available from the EIF.

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Refer to Certificates

Survey

General

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As per regulation 10 of the Convention, Ships to which the convention applies, shall be subject to the following surveys:(a) an initial survey;(b) a renewal survey;(c) an additional survey;(d) a final survey

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When duly delegated by the Ship’s Administration, Recognised Organisation (RO) will perform the appropriate surveys taking into account the provisions of “2012 Guidelines for the survey and certification of ships under the Hong Kong Convention “– Resolution MEPC.222(64).

Initial survey for existing ships

Refer to Initial Survey & Issuance of International Certificate at EIF and procedure described Initial survey for EU existing ships and for non EU ships

Renewal survey

Refer to procedure described Renewal survey for existing EU ships and non EU ships

Additional survey

Refer to procedure described Additional survey for existing EU ships and for non EU ships

Final survey for ships going to recycling

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1. The final survey shall be conducted before the ship being taken out of service and before the recycling of the ship has started

2. Final survey shall be carried be carried out taking into account the 2012 Guidelines for the survey and certification of ships under the Hong Kong Convention - resolution MEPC.222(64) – see attached file MEPC.222(64).

3. The following graph shows the ship recycling process to be followed.

   

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For existing ships intended for ship recycling, the initial survey and the final survey may be conducted at the same time

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1. the IHM complies with the requirements of regulation 5.4 of the Convention; (i.e. inventory of hazardous materials shall, in addition to the properly maintained and updated Part I, incorporate Part II for operationally generated waste and Part III for stores, and be verified by the administration or a recognized organisation authorised by it)

   Upon satisfactory review, IHM shall be stamped with the wording 'reviewed for consistency on XXXX at XXXX'.

2. The Ship Recycling Plan properly reflects the information contained in the IHM and complies with the requirements of regulation 9 of the Convention.

   Approval of Ship Recycling Plans :As referred to in regulation 9.4 of the Convention, the Ship Recycling Plan shall be either explicitly or tacitly approved by the Competent Authority.

   Approval process :The Competent Authority must send a written acknowledgement of receipt of the SRP to the ship recycling facility, the shipowner, and the Administration (flag) within three (3) working days of its receipt.Thereafter:.1 where a Party requires explicit approval of the Ship Recycling Plan, the Competent Authority must send written notification of a decision to approve or deny the SRP to the Facility, shipowner and Administration.2 where a Party requires tacit approval of the Ship Recycling Plan, the acknowledgment of receipt will specify the end date of a 14-day review periodThe Competent Authority will notify any written objection to the SRP to the Ship Recycling Facility, shipowner and Administration within this 14-day review period. Where no such written objection has been notified, the Ship Recycling Plan will be deemed to be approved.Competent Autority(ies) (article 2.3 of the Convention) : means a governmental authority or authorities designated by a Party as responsible, within specified geographical area(s) or area(s) of expertise, for duties related to Ship Recycling Facilities operating within the jurisdiction of that Party as specified in this Convention.

3. The Ship Recycling Facility(ies) where the ship is to be recycled holds a valid authorization in the form of a Document of Authorisation to Conduct Ship Recycling (DASR) in accordance with this Convention

   Please refer to the pdf files provided by the IMO on :

   - LIST OF SHIP RECYCLING FACILITIES (SRF) AUTHORIZED

   - CONTACT DETAILS FOR THE COMPETENT AUTHORITY(IES)

   accessible on the following web page

   https://www.imo.org/en/ourwork/environment/pages/ship-recycling.aspx

ASMS Items

Surveys related to the Inventory SoC under Hong Kong Convention

ASMS survey check lists are available when selecting the survey code:HKIV: HK Convention IHM Documentation ReviewHKII: HK Convention IHM Initial SurveyNB : ASMS survey code HKIV - Documentary consistency check - and HKII -On board verification - , constitute the initial survey. Having carried out a survey in connection with the survey code HKIV is a prerequisite for selecting the survey code HKII. It will not be possible to declare issuance of " HK Convention IHM SoC" in case survey HKII is not selected in the Survey selection list.HKIR: HK Convention IHM Renewal Survey HKIA: HK Convention IHM Additional Survey

HKIO: HK Convention IHM Occasional Survey

Surveys related to the International Ready for recycling Certificate

ASMS survey check lists are available when selecting the survey code:HKRV: HK Ready for Recycling ReviewHKRF: HK Ready for Recycling Final Survey

Certificates

Duration of the certificates

a) An International Certificate on Inventory of Hazardous Materials shall be issued for a period specified by the Administration, which shall not exceed five years (regulation 14.2).b) An International Ready for Recycling Certificate shall be issued for a period specified by the Administration that shall not exceed three months (regulation 14.3).

International Certificate on Inventory of Hazardous Materials

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As per regulation 11.1, after successful completion of an initial or renewal survey, an inventory certificate shall be issued to any new ships to which regulation 10 of the Convention applies. That certificate shall be supplemented by Part I of the IHM

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An International Certificate on Inventory of Hazardous Materials shall be issued for a period specified by the Administration, which shall not exceed five years. (regulation 14.2)

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The International Certificate on Inventory of Hazardous Materials, at the request of the shipowner, shall be endorsed either by the Administration or by any person or organization authorized by it after successful completion of an additional survey conducted in accordance with regulation 10 of the Convention (regulation 11.2). Therefore, the page of the endorsement shall be reproduced and added to the certificate as considered necessary by the Administration.

International Ready for Recycling Certificate

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After successful completion of a final survey in accordance with regulation 10.4 of the Convention, the administration or a recognised organisation authorised by it shall issue a international ready for recycling certificate (RfRC). That certificate shall be supplemented by the IHM and the ship recycling plan.

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Where the initial survey and the final survey are conducted at the same time as provided for in regulation 11.1 of the Convention, only the international RfRC shall be issued (res. MEPC.222(64)).

FAQ

Refer to the attached file - IMO Frequently Asked Questions “01 FAQ for HKC (WBS No. TC-2048-11-2000) final”

Appendix — Annex I of Regulation (EU) No 1257/2013 (EU SSR)

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Appendix — Annex II of Regulation (EU) No 1257/2013 (EU SSR)

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ANNEX IILIST OF ITEMS FOR THE INVENTORY OF HAZARDOUS MATERIALS1. Any hazardous materials listed in Annex I2. Cadmium and Cadmium Compounds3. Hexavalent Chromium and Hexavalent Chromium Compounds4. Lead and Lead Compounds5. Mercury and Mercury Compounds6. Polybrominated Biphenyl (PBBs)7. Polybrominated Diphenyl Ethers (PBDEs)8. Polychlorinated Naphthalenes (more than 3 chlorine atoms)9. Radioactive Substances10. Certain Shortchain Chlorinated Paraffins (Alkanes, C10-C13, chloro)11. Brominated Flame Retardant (HBCDD)

Appendix — Annex B of EMSA IHM Guidance

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Materials to be listed in the IHM Part I The following threshold values of reporting HM in the IHM should apply taking into account the IMO guidelines and the referenced EU legislation:

* N.B.: The referenced legislation is an indicative list of EU legal instruments not necessarily applicable on ships. 64 N.B.: The IMO guidelines (Resolution MEPC.379(80)) provide the following in a footnote : “In accordance with regulation 4 of the Convention, for all ships, new installation of materials which contain asbestos shall be prohibited. According to the UN recommendation "Globally Harmonized System of Classification and Labelling of Chemicals (GHS)" adopted by the United Nations Economic and Social Council's Sub- Committee of Experts on the Globally Harmonized System of Classification and Labelling of Chemicals (UNSCEGHS), the UN's Sub-Committee of Experts, in 2002 (published in 2003), carcinogenic mixtures classified as Category 1A (including asbestos mixtures) under the GHS are required to be labelled as carcinogenic if the ratio is more than 0.1%. However, if 1% is applied, this threshold value should be recorded in the Inventory and, if available, the Material Declaration and can be applied not later than five years after the entry into force of the Convention. The threshold value of 0.1% need not be retroactively applied to those Inventories and Material Declarations” 65 OJ L 262, 27-9-1976, p. 201. 66 OJ L 330, 16-12-2009, p.28. 67 According to the HKC new installations containing hydrochlorofluorocarbons (HCFCs) are permitted until 1 January 2020. However, this provision has not been incorporated in the SRR. 68 OJ L 286, 31-10-2009, p.1. 69 OJ L 158, 30-4-2004, p. 7. 70 Not applicable for ships flying the flag of a third country. 71 OJ L 372, 27-12-2006, p.32.

72 OJ L 115, 9-5-2003, p.1. 73 OJ L 262, 27-9-1976, p. 201. 74 OJ L 174, 1-7-2011, p.88.

75 OJ L 159, 29-6-1996, p.1.** See EMSA IHM Guidance Annex C.b.3.76 OJ L 55, 02-03-2016, p.7.

Appendix 1 of of resolution MEPC.379(80) “2023 Guidelines for the development of the Inventory of Hazardous Materials” AS AMENDED BY RESOLUTION MEPC.405(83)

ITEMS TO BE LISTED IN THE INVENTORY OF HAZARDOUS MATERIALS

4 In accordance with regulation 4 of the Convention, for all ships, new installation of materials which contain asbestos shall be prohibited. According to the UN recommendation "Globally Harmonized System of Classification and Labelling of Chemicals (GHS)" adopted by the United Nations Economic and Social Council's Sub-Committee of Experts on the Globally Harmonized System of Classification and Labelling of Chemicals (UNSCEGHS), the UN's Sub-Committee of Experts, in 2002 (published in 2003), carcinogenic mixtures classified as Category 1A (including asbestos mixtures) under the GHS are required to be labelled as carcinogenic if the ratio is more than 0.1%. However, if 1% is applied, this threshold value should be recorded in the Inventory and, if available, the Material Declaration and can be applied not later than five years after the entry into force of the Convention. The threshold value of 0.1% need not be retroactively applied to those Inventories and Material Declarations.

5 In accordance with regulation 4 of the Convention, for all ships, new installation of materials which contain PCBs shall be prohibited. The Organization set 50 mg/kg as the threshold value referring to the concentration level at which wastes, substances and articles containing, consisting of or contaminated with PCB are characterized as hazardous under the Basel Convention.

6 "No threshold value" is in accordance with the Montreal Protocol for reporting ODS. Unintentional trace contaminants should not be listed in the Material Declarations and in the Inventory.

7 This threshold value is based on the 2022 Guidelines for brief sampling of anti-fouling systems on ships (resolution MEPC.356(78)).

8 These threshold values are based on appendix I of the 2022 Guidelines for survey and certification of anti-fouling systems on ships (resolution MEPC.358(78)).

8 The Organization set this as the threshold value referring to the Restriction of Hazardous Substances (RoHS Directive 2011/65/EU, Annex II).9 The Organization set 50 mg/kg as the threshold value referring to the concentration level at which wastes, substances and articles containing, consisting of or contaminated with PBB are characterized as hazardous under the Basel Convention.10 The Organization set 50 mg/kg as the threshold value referring to the concentration level at which wastes, substances and articles containing, consisting of or contaminated with PCN are characterized as hazardous under the Basel Convention.11 All radioactive sources should be included in the Material Declaration and in the Inventory. Radioactive source means radioactive material permanently sealed in a capsule or closely bonded and in a solid form that is used as a source of radiation. This includes consumer products and industrial gauges with radioactive materials. Examples are listed in appendix 10.12 The Organization set 1% as the threshold value referring to the EU legislation that restricts Chlorinated Paraffins from being placed on the market for use as substances or as constituents of other substances or preparations in concentrations higher than 1% (EU Regulation 1907/2006, Annex XVII Entry 42 and Regulation 519/2012).

13 Definition of garbage is identical to that in MARPOL Annex V. However, incinerator ash is classified separately because it may include hazardous substances or heavy metals

14 This table does not include ship-specific equipment integral to ship operations, which has to be listed in part I of the inventory.

Appendix 5 of resolution MEPC.379(80) “2023 Guidelines for the development of the Inventory of Hazardous Materials”

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see attached file “MEPC.379(80)”

Appendix — DIAGRAM for the inclusion of Cybutryne in the EXISTING IHM under Regulation (EU) No 1257/2013

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