Dear IMCA Member
The European Union’s Ship Recycling Regulations (EUSRR) entered into force on December 2018 for EU-flagged new builds. For existing EU-flagged vessels and non-EU-flagged vessels, the effective date is 31 December 2020. There is a requirement in EUSRR applying not only to vessels flying the flag of countries in the European Union (EU) or European Economic Area (EEA) but also to all vessels of 500 GT and above, regardless of the which flag they are flying, when calling a port or anchorage of a country that is a member of the EU or EEA.
This requirement means that from 31 December 2020, all such vessels should carry an inventory of hazardous materials (IHM) they have onboard. The IHM should be compliant with EUSRR and for vessels flying a flag of country outside the EU/EEA region, should also be accompanied by a Statement of Compliance from the flag state.
While we expect that this will affect quite a number of Members’ vessels, we foresee certain obstacles for vessel owners or operators in finalising their inventory by the deadline of 31 December 2020, especially in the current situation where inspectors and Recognised Organisations are unable to board vessels, due to COVID-19 restrictions.
IMCA is working with other organisations, including BIMCO, ICS and ECSA to lobby for an extension to the entry into force date. For IMCA, to get a better understanding of the extent of this issue and to approach the right authorities for a dialogue, we request you to share information about your fleet.
The purpose of this questionnaire is to collect and collate information on your company’s experiences with European Union’s Ship Recycling Regulations (EUSRR), in particular, the requirement to carry out an Inventory of Hazardous Materials (IHM).
All information provided will be collated by IMCA to ensure complete anonymity.
About the Questionnaire: The questionnaire contains 7 questions and should take about 5-10 minutes to complete, providing you have the required information readily accessible.
Confidentiality and data protection management of information
- We will use the information you provide for the purposes mentioned above.
- We will not pass on any personal information to third parties.
- As soon as a statistical analysis of the survey result is finalised, we will delete all personal information collected.
Thank you for participating.
Should you need assistance in completing the questionnaire, please contact Margaret Fitzgerald, Head of Marine Policy & Regulatory Affairs on Margaret.Fitzgerald@imca-int.com.