As of 31 December 2020, the EU Ship Recycling Regulation requires all existing EU flagged ships and non-EU flagged ships calling to an EU port or anchorage to carry on-board an Inventory of Hazardous Materials (IHM) with a certificate or statement of compliance as appropriate.

According to the European Commission (EC), they have received reports from industry stakeholders that COVID-19 restrictions have led to significant difficulties in surveying ships and producing certified IHMs. The lockdown measures and widespread travel restrictions which were introduced to control COVID-19 have reportedly prevented many ship owners (or their agents) from producing the IHM in the first instance, but also inhibited flag State surveyors and recognised organisations from verifying and certifying the IHMs.

As a consequence, industry stakeholders estimate that several thousand ships are likely to be unable to comply with the IHM obligations and may not have the required certification by the deadline of 31 December 2020.

Therefore, considering the disruptions caused by COVID-19, the EC has published Commission Notice suggesting EU member States to apply a harmonized approach towards enforcement during ship inspections for a limited period of 6 months from 31 December 2020 to 30 June 2021.

In accordance with this Notice, on a request basis, ClassNK issues a conditional SOC with validity for maximum 4 months, but not later than 30 June 2021 for vessels with a semi completed IHM without the on-board sampling element, if the flag state has agreed.
As of today, the authorities of Liberia, Malta and Hong Kong agreed to issue the conditional SOC, and other flag states will be notified on our website as soon as the agreement is obtained.

(To be continued)