• The aim of Hong Kong Convention and EU Ship Recycling Regulation (EU SRR) is to ensure safe and environmentally sound recycling by identification of materials present in a ship’s structure, systems and equipment, that may be hazardous to health or the environment.

Ships concerned:

  • Internationally trading ships, ≥ 500 GT;
  • EU flagged ships;
  • Non-EU flagged ships when calling EU ports / anchorages.

Implementation timeline:

  • EU Ship Recycling Regulation (EU SRR), requires that ships must have an IHM Part I on the 31st of december 2020 by the latest;
  • Ships that are ready for recycling will require a complete inventory. IHM Part II and Part III could be prepared by ship’s crew.

Time until delayed application date for Inventory Certificate on board existing ships and Statement of Compliance on non-EU ships:

Preparation of Inventory of Hazardous Materials Part I has the following five steps:

Collection of HM information

The information collected from: certificates, manuals, ship's plans drawings, technical specifications and information from sister ships. The information is collected by the HazMat Expert and required ship owner assistance.

Assessment of collected information

Collected data is assessed by HazMat Expert, in order to identify every item (equipment, systems or areas) suspected to contain Hazardous Materials, based on the indicative list shown in IMO resolution MEPC.269(68). Every item on board (equipment, system, and/or area) is classified accordingly “contained”, “not contained”, “unknown”.

Preparation of Visual/Sampling Check Plan

A checking plan is prepared by HazMat Expert to determine that every item (equipment, system and/or area) of the previous step is checked visually or by sampling, depending on its classification.

Onboard Visual/Sampling Check

Onboard Visual Check and onboard Sampling Check is conducted by our duly qualified HazMat Experts and the results are recorded in “checklist”. The samples are sent to approved laboratory for analysis.

Preparation of IHM and related documentation

When the analysis of all samples is completed and all the items onboard containing Hazardous Materials are identified, approximate quantities of them are estimated by the HazMat Expert. Based on all above information an Inventory of Hazardous Materials Part I, complying with EU SRR requirements is prepared by our HazMat Expert.

• Survey & Certification

To obtain EU hazardous materials certification, after the receiving of the IHM from Orient Chartering and Logistic Ltd, the ship owner has to approach a Classification Society for survey & certification. The ship owner could choose a Classification Society from the list of approved by Flag State Classification Societies. The Class Surveyor will perform consistency documentary check and onboard survey. After successful onboard survey Class Surveyor will issue on behalf of the Flag State the following certificates:

  • EU Inventory Certificate for new & existing EU flag ships;
  • Statement of Compliance for non-EU flag ships.

Contents of an IHM

A complete IHM consists of the following parts:

  • Part I: Materials contained in the ships structure (table A + B)
  • Part II: Operationally generated waste (table C)
  • Part III: Stores (table C+D)
  • Table A Materials listed in Annex 1
  • Table B Materials listed in Annex 2
  • Table C Potentially Hazardous items
  • Table D Regular consumable goods potentially containing hazardous materials


“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”, according Article 3 of EU SRR;