Accordingly, the bulletin states that certain US flagged vessels that enter or anchor to ports in the waters of the European Union, Iceland, or Norway may need to follow additional requirements from December 31, 2020.

The 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 in line with the Hong Kong Convention on the Safe and Environmentally Sound Recycling of Ships, 2009 (HK Convention), which has not yet entered force.


Overall, the Hong Kong Convention ensures that ships, when being recycled at the end of their operational lives, do not pose any unnecessary risk to human health, safety and to environment.

Therefore, based on the EU Regulation and the Hong Kong Convention, port state control officers from EU Member States, Iceland and Norway may validate that each ship in their ports or anchored in their waters after December 31, 2020, has a valid IHM and ICIHM.

As a result, to assist US flag ships demonstrate compliance, the USCG is developing a voluntary inspection program.

In addition, the coast guard advises that the owners/operators of impacted vessels take action as earlier as possible with the EU Ship Recycling Regulation.

Given that developing the IHM and receiving an ICIHM may take significant time, potentially three or more months, the interested parties are advised to 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.