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Göteborg: 4 December 2020

EU Guidelines on the enforcement of obligations under the EU Ship Recycling Regulation

European Union IHM compliance “extension”

Click here to download the  EU Guidelines»

The European Commission (EC) has agreed to a qualified extension of the 31st December 2020 deadline, under the Union’s Ship Recycling Regulations (EUSRR), for compliance with the inventory of hazardous materials (IHM) requirement.

As this has been agreed because of the disruption experienced as a result of the Covid-19 pandemic, the extension is not a simple postponement.

If Owners are found to be not compliant during the first six months of 2021, they will have to be able to show that their non-compliance results specifically from disruption caused by the pandemic if they are to avoid being penalised. 

From 31st December 2020, all ships of 500 GT and above, flying the flag of countries in the European Union (EU), and all other ships, regardless of flag, visiting an EU port or anchorage, are required to carry a completed IHM. 

However, in October 2020 the EC published guidelines on the enforcement of this obligation. The guidelines recognise the disruption caused by the pandemic and the likelihood that the Owners of many ships have not been able to comply with the original deadline of 31 December 2020.

The EC has suggested that member states apply the following uniform approach for the first half of 2021:

  1. In all cases of non-compliance, including an incomplete IHM, the Owner/Master, will have to provide evidence of all the measures taken to undertake and complete the IHM work and obtain the required certification and documentation on time. Simply referring to the pandemic as an excuse will not be considered sufficient.
  2. The Port State control (PSC) inspectors are then to assess the evidence provided on a case-by-case basis to determine whether they are satisfied with the efforts made to comply within the original deadline. If satisfied, the Owner will have a further 4 months (from the date of the PSC inspection) in which to compete, the IHM.  
  3. Evidence should be kept of any further disruption caused by the ongoing pandemic in case of a further PSC inspection.  


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