Materials Declarations for Inventories of Hazardous Materials Guidance

Brussels, Belgium, 11.05.2023, 11:47 Uhr

THe OCEAN Secretariat

Materials Declarations for Inventories of Hazardous Materials

Industry Guidance for Ship Suppliers and Ship Owners

The EU Ship Recycling Regulation specifies that shipowners must establish and maintain an inventory of hazardous materials (IHM). What is the role of ship suppliers in it?

Greener & safer ship recycling

The EU has recently implemented regulations from the so-called Hong Kong Convention (HKC) into its laws, demonstrating its commitment to safe and eco-friendly ship recycling. Today, as a result, the EU says that these new EU rules on ship recycling aim to make it greener and safer and to reduce the negative environmental and social impacts of recycling ships. In addition to the existing Convention standards, the EU has introduced additional safety and environmental measures, resulting in the EU Ship Recycling Regulation or short EUSRR.

Ship Recycling – a global problem

According to the EU, numerous sizable vessels are dismantled annually under substandard environmental and social circumstances. The labourers involved are paid meagre wages and are typically provided with insufficient equipment and inadequate safety measures. This has led to a high number of casualties, pollution, and environmental damage.

Meet the EUSRR

The European Union Ship Recycling Regulation (EUSRR) is the only legally binding framework that governs ship recycling. It is mandatory for EU shipowners, vessels carrying EU flags, and non-EU vessels visiting EU ports to comply with it.

The law is put forth to ensure that ship recycling is done in a manner that is environmentally safe and sound. It also prohibits or limits the usage of hazardous materials such as asbestos or substances that contribute to ozone depletion. Moreover, a directory of ship recycling facilities in Europe is set to be created.

The inventory of hazardous waste materials

According to the EUSRR, all EU ships destined for dismantling, as well as new European ships and third-country ships making stops at EU ports, must possess an inventory of hazardous materials on board. This inventory must indicate the location and estimated quantities of such materials. This requirement helps in the recycling process of vessels and minimizes the presence of harmful substances on ships. EU port authorities have the right to inspect ships to ensure that they carry the necessary certification and inventory.

To create and maintain the Inventory of Hazardous Materials (IHM), it is crucial to collect details about the ship's construction and equipment from the Material Declaration (MD) and Supplier's Declaration of Conformity (SDoC). As per the EUSRR regulations and the upcoming HKC regulations, both shipowners (for IHM-Maintenance) and suppliers of relevant components and equipment (for IHM-Development in new ships) are obligated to provide this information.

New Industry Guidance

The purpose of this industry guidance is to clarify the process of information sharing between shipowners and suppliers during the submission of MDs and SDoCs. This will reduce the administrative workload for both ship suppliers and shipowners and guarantee the provision of accurate information necessary for the upkeep of IHM. Additionally, it will aid shipowners and suppliers in comprehending and fulfilling their responsibilities regarding MD and SDoC in accordance with the HKC and EUSRR.

This industry guidance is co-sponsored by BIMCO, the International Ship Suppliers & Services Association (ISSA), and the International HazMat Association (IHMA).

Download the Guide Here

For additional information, visit:

And the EU Commission: