Commercial Vessel Compliance

MSIB: EU ship recycling regulation and U.S. flagged vessels

The Inspections and Compliance Directorate issued Marine Safety Information Bulletin 04-20, “Impact of the EU Ship Recycling Regulation on U.S. flagged ships,” to encourage owners/operators of affected vessels to take early action to comply with the regulation.

Certain U.S. flagged ships entering ports or anchoring in the waters of the European Union, Iceland, or Norway may need to comply with additional requirements from December 31, 2020. Specifically, EU Regulation 1257/2013 (EU Ship Recycling Regulation) requires that ships flying the flag of third party countries, such as the United States, maintain Part I of the Inventory of Hazardous Materials (IHM) and an International Certificate on the Inventory of Hazardous Materials (ICIHM).

The requirements of the EU Ship Recycling Regulation are based on the Hong Kong Convention on the Safe and Environmentally Sound Recycling of Ships, 2009 (HK Convention), which has not yet entered force. The HK Convention is aimed at ensuring that ships, when being recycled at the end of their operational lives, do not pose any unnecessary risk to human health and safety or to the environment. The HK Convention and the EU Ship Recycling Regulation contain regulations covering the design, construction, operation and preparation of ships so as to facilitate safe and environmentally sound recycling without compromising the safety and operational efficiency of ships. Port State Control Officers of EU Member States, Iceland, or Norway may validate that each ship in their ports or anchored in their waters after December 31, 2020, has a valid IHM and ICIHM. The Coast Guard is developing a voluntary inspection program that would allow U.S. flag ships to demonstrate compliance with the EU Ship Recycling Regulation and be issued a statement of voluntary compliance.

The Coast Guard recommends that the owners / operators of impacted ships take early action to comply with the EU Ship Recycling Regulation. Developing the IHM and receiving an ICIHM may take significant time, potentially three or more months. Owners / operators of U.S. flag ships affected by the EU Ship Recycling Regulation should coordinate with their Recognized Organization to determine the RO’s process and timeline to verify compliance with the requirements of the EU Ship Recycling Regulation.

Additional information is located in the EU Ship Recycling Regulation, the HK Convention, EMSA’s Best Practice Guide on the Inventory of Hazardous Materials, and the Coast Guard’s frequently asked questions. In addition, some ROs have published guidance on the IHM and EU Ship Recycling Regulation.

Questions may be forwarded to the Office of Commercial Vessel Compliance, Flag State Control Division via

This blog is not a replacement or substitute for the formal posting of regulations and updates or existing processes for receiving formal feedback of the same. Links provided on this blog will direct the reader to official source documents, such as the Federal Register, Homeport and the Code of Federal Regulations. These documents remain the official source for regulatory information published by the Coast Guard.

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