EU SRR: Who is in scope of IHM requirements?

Ship recycling requirements apply to ships that are 500 metric tons in gross weight or heavier. Here are the inventory of hazardous materials (IHM) requirements for those ships:

  • Ships that fly an EU flag or are built in the EU must carry and maintain a valid IHM that is prepared according to EU SRR standards, using the EU SRR IHM hazardous materials list.
  • Ships that aren't EU-built or flying an EU flag, and which intend to dock in EU ports, must have a valid International Maritime Organization (IMO) IHM Part 1. An IMO IHM is similar to an EU SRR IHM, but the IMO IHM reportable substances list is slightly shorter. (The EU SRR IHM substances list contains all the substances on the IMO IHM substances list, and some others as well.)
  • Ships that aren't EU-built or flying an EU flag, and which are not traveling to the EU, are not subject to requirements under the EU SRR. However, they should still maintain a valid IMO IHM Part 1 as a matter of best practice; this may also be required by some other countries' port authorities.

Special cases: In some situations, the general requirements described above do not apply.

  • Ships that only travel within their own country throughout their life cycles, including ships operating only in waters subject to the sovereignty/jurisdiction of the EU member state under which they are flagged, are not subject to EU SRR IHM requirements. However, they should still maintain a valid IMO IHM Part 1 as a matter of best practice.
  • Ships owned and controlled by a national government, which are not used for commercial purposes, are not subject to EU SRR IHM requirements. However, they should still maintain a valid IMO IHM Part 1 as a matter of best practice.

When a ship enters an EU port, the port authority of that EU member state can board a ship prior to docking and inspect the IHM and other relevant documentation. The port authority may deny the ship entry to port if the IHM is not present or has not been maintained/audited according to the applicable requirements.

Ships under 500 metric tons in gross weight are outside the scope of EU SRR and IMO requirements, and do not need to prepare or maintain an IHM.

This article is current as of 2021-08-03.

 

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