As informed by ClassNK Technical Information No. TEC-0978, 1170 and 1185, EU flagged existing ships and Non-EU flagged ships calling at a port or anchorage of an EU member state shall have on board an approved inventory of hazardous materials (IHM) by 31 December 2020.

For Non-EU flagged ships, a statement of compliance (SOC) shall be issued in accordance with Article 12.6 of the EU Regulation after verification of the IHM by the relevant authorities of a Non-EU country whose flag the ship is flying or an organisation authorised by them, in accordance with the national requirements. According to the EU authority, the SOC shall be issued by or on behalf of the Flag state.

Until now, ClassNK has issued a SOC to the Hong Kong Convention not on behalf of the flag Administration but on our own behalf. As ClassNK has now received authorization and/or instructions from major non-EU flag Administrations, SOCs will be issued in the following manner:

1 Ships to which ClassNK is authorised to issue the SOC on behalf of the Administration:
ClassNK issues SOCs to Ship Recycle Convention (HKC-SOC) and Article 12 of the EU regulation (EU12-SOC) on behalf of the Administration.
2 Ships to which the SOC may not be issued on behalf of the Administration:
ClassNK continues to issue the SOC to Ship Recycle Convention as before (not on behalf of the Administration) and newly issues the SOC to Article 12 of the EU regulation (EU12-SOC) but not on behalf of the Administration.
3 Ships that comply with Article 5 of the EU Regulation voluntarily:
In addition to the above, on a request basis including an on-going verification, ClassNK issues a Statement of Fact (EU5-SOF) to Article 5 of the EU Regulations, for which two substances, PFOS and HBCDD, are required to be included in the IHM in addition to those required under the Hong Kong Convention. (Related to TEC No. 1170)

For ships whose IHM is developed from now on, please refer to TEC No. 1170 and submit an application, so that an SOC will be issued as per the above 1 or 2. For ships with the IHM notation affixed to their classification character (ships to which an SOC is issued not on behalf of the flag Administration), the above 1 or 2 will be applied at the IHM renewal survey conducted in conjunction with the next class special survey.

(To be continued)