MEMBER ALERT Shipowners Claims Bureau, Inc., Manager One Battery Park Plaza 31 st Fl., New York, NY 10004 USA Tel: +1 212 847 4500 Fax: +1 212 847 4599 https://www.american-club.com American Club Member Alert – August 26 , 20 20 1 AUGUST 26, 2020 EUROPEAN UNION (EU) REQUIREMENTS FOR EU- AND NON-EU-FLAGGED SHIPS REGARDING INVENTORIES OF HAZARDOUS MATERIALS (IHM) IN THE CONTEXT OF THE EU SHIP RECYCLING REGULATION (EUSRR) The EU Ship Recycling Regulation (EUSRR), adopted in 2013, contains requirements for EU-flagged ships, of 500 GT and above, to carry an inventory of hazardous materials (IHM). In addition, ships calling at EU ports from non-EU countries will also be required to carry an IHM identifying all the hazardous materials on board. EU-flagged ships must also be scrapped in an EU approved ship recycling facility. The EUSRR is aimed at facilitating early ratification of the Hong Kong Convention 2009 both within the EU and in other countries outside the EU - by applying controls to ships and ship recycling facilities in accordance with the Convention. It aims to ensure that vessels are recycled in EU-approved facilities worldwide. As of the December 31, 2020, the EUSRR will apply to: • existing EU-flagged ships, which will be required to have onboard a verified IHM with a Statement of Compliance. If the ship is scheduled to be recycled, the IHM should be on board; and • non-EU-flagged ships calling at EU ports, which will also be required to have onboard a verified IHM with a Statement of Compliance. Members are recommended to familiarize themselves with the European Maritime Safety Agency’s (EMSA’s) Guidance on the Inventory of Hazardous Materials: IHM Development and Maintenance in the Context of the EU Ship Recycling Regulation which provides both technical information and procedural guidance. The EU maintains a website providing updates on ship recycling at: https://ec.europa.eu/environment/waste/ships/ and maintains its list of approved ship recycling facilities in both EU and non-EU states at: https://ec.europa.eu/environment/waste/ships/list.htm. Your Managers recommend that Members take note of this information and be guided accordingly.