Industry Guidance to Ship Suppliers and Shipowners on
Materials Declarations for
Inventories of Hazardous Materials
November 2022
Materials Declarations for Inventories of Hazardous Materials
2
1 Background
The development and maintenance of the Inventory of Hazardous Materials (IHM) is the key requirement
for shipowners under the Hong Kong Convention (HKC) and EU Ship Recycling Regulation (EUSRR). Whilst
the HKC has not yet come into force, the EUSRR has, and has wide application (to shipowners within the EU,
vessels flagged within the EU and non-EU vessels calling to EU ports).
Fundamental to the development and maintenance of the IHM is the collection of available information
relevant to the ship’s construction and equipment through the Material Declaration (MD) and the Supplier’s
Declaration of Conformity (SDoC). These are required by the EUSRR (and the HKC when it comes into force)
to be provided by the suppliers of relevant parts and equipment delivered to the shipyard (IHM-development
for new ships) and shipowners (IHM-Maintenance).
The IHM requirements apply for the entire life cycle of a ship, and there are specific provisions relating to
each stage in the ship’s life to ensure that hazardous materials can be identified as far as possible, and their
disposal properly planned in the ship recycling process.
This Industry Guidance concerns only Part I of the IHM which covers the “structure and equipment of ships”
and which needs to be prepared and maintained during the operational lifetime of the ship. Part I has three
subparts and this guidance addresses Parts I-2 and I-3 only. This guidance does not address Part I-1 which is
on paints and coating systems.
More extensive guidance on the development of an IHM and compliance with the HKC and EUSRR can be
found in the Transitional Measures for Shipowners Selling Ships for Recycling.
Materials Declarations for Inventories of Hazardous Materials
3
2 Purpose
This Industry Guidance is specifically aimed at clarifying the exchange of information between shipowners
and suppliers through the supplier’s submission of MDs and SDoCs. It will assist shipowners and suppliers in
understanding and complying with their obligations with respect to MD and SDoC under the HKC and EUSRR,
reducing the administrative burden for shipowners and suppliers, and ensuring the provision of accurate
information necessary for the maintenance of IHM.
The application of the EUSRR and voluntary compliance with IHM requirements under HKC or through
companies’ environmental policies, has caused a significant increase in shipowners’ requests for MDs
to suppliers. As a consequence of this willingness to demonstrate compliance with the EUSRR and HKC,
shipowners and service providers to whom IHM management has been delegated have made MD requests
for equipment delivered to the ship, in excess of what is required under the EUSRR or HKC regimes. This has
placed a considerable administrative burden on suppliers, and can make the maintenance of the IHM by the
owner significantly more complicated. Similarly, a lack of awareness by suppliers of their responsibilities in
providing accurate MDs on request can also impact on the accuracy of IHM.
Materials Declarations for Inventories of Hazardous Materials
4
3 Statutory Framework
The EUSRR and the HKC rely upon IMO Resolution MEPC.269(68) – 2015 Guidelines for the Development
and maintenance of the Inventory of Hazardous Materials (“the IMO-Guidelines”), which include the
requirement for suppliers to provide MDs and SDoCs. For the purposes of implementing the EUSRR, the
European Maritime Safety Agency (EMSA) has also issued Best Practice Guidance on the Inventory of
Hazardous Materials (the EMSA Guidance).
The purpose of the MD is to inform the shipowner whether or not relevant items supplied by the supplier
contain hazardous materials. An MD must be supplied where the item will be part of the ships structure or
equipment, regardless of whether or not hazardous materials are present (i.e. “Zero Declaration”).
Loosely
fitted item
Identical
spare part /
component
and coating
Component
necessary
for
“continuous
operations”
Regular
consumer
product
(Table D)
Relevant
Not relevant
Blank metal
/ metal
alloy
Potentially
hazardous
items
(Table C)
NO NO NO NO NO NO
YES YES YES YES YES YES
Figure 1: Flow diagram on Material Declaration Relevance
However, an MD is not required for:
• “Loosely fitted equipment“ that is not part of the permanent ship’s structure (MEPC.269(68) 3.2.3);
• Materials listed in Table B that are inherent in solid metals or metal alloys, such as steels, aluminium,
brasses, bronzes, plating and solders (MEPC.269(68) 3.3.1);
• Components necessary for continuous ship operations (e.g. additives) (MEPC.269(68) 4.5.3);
• Printed Circuit Boards (MEPC.269(68) 3.3.2);
• Identical parts, components and coatings (MEPC.269(68) 4.3.2);
• Potentially hazardous items (Table C) in stores and as waste (MEPC.269(68) 3.2.2); or
• Regular consumer products (Table D) (MEPC.269(68) 3.2.2).
The full list of the hazardous materials to be documented is reproduced in the tables at Schedule A of this
Industry Guidance.
Appendix 1 of the IMO Guidelines provides details of the relevant hazardous materials. The EUSRR lists two
additional hazardous materials, which can be found in Appendix 1 and 2 of the EUSRR. These are:
i. Perfluorooctane sulfonic acid (PFOS) (Appendix 1); and
ii. Brominated Flame Retardant (HBCDD) (Appendix 2).
Annex B to the EMSA Guidance provides the threshold levels for these additional hazardous materials.
Materials Declarations for Inventories of Hazardous Materials
5
Appendix 1 of the IMO Guidelines contains Tables A, B, C and D, which provide the materials and items that must
be recorded at the various stages of a ship’s life. The following table provides an overview of the requirements:
Inventory of Hazardous Materials
Building and
operation
Prior to recycling
Part I
Structure and
equipment
Part II
Hazardous
wastes
Part III
Stores
Table A Materials
Mandatory for all ships and installations
✔
Table B Materials
Mandatory for all ships and installations, voluntary for existing ships
✔
Table C Materials
Potentially hazardous items
✔ ✔
Table D Materials
Regular consumable goods potentially containing hazardous materials
Excluded
items
✔
Tables A and B correspond to IHM Part I, which has to be certified and then maintained by the shipowner
during the operational life of the ship. The sample MD at Schedule C of this Industry Guidance reflects Tables
A and B and the EMSA Guidance for the two additional substances as required under EUSRR.
For the preparation of a ship for recycling Parts II and III of the IHM apply. The level of detail to be recorded is
lower and no additional declarations in the form of MD and SDoC are required from suppliers for such products.
It is therefore unnecessary to consider Tables C and D for IHM Maintenance and related MDs or SDoCs.
Sections 6 and 7 of the Annex to the IMO Guidelines set-out the supplier’s obligations to provide the MD and
SDoC (Appendices 6 and 7 of the IMO Guidelines provide examples of the MD and SDoC). Slightly revised
versions of these documents including the two additionally required substances by EUSRR are provided at
Schedule C and B of this Industry Guidance.
3.1 Responsibility of the shipowner
Part I of the IHM when initially developed, approved and certified, must be maintained throughout the life of
the ship. Updates to IHM Part I are required “if any machinery or equipment is added to, removed or replaced
or the hull coating is renewed according to the requirements for new ships”. As such an MD and SDoC are to
be provided by suppliers for any such items supplied.
IHM Part I must be updated during the vessel’s life cycle, if “new” items are incorporated into the vessel’s
permanent structure or other relevant changes to it occur. IHM Part I does not require updating if e.g. an
identical replacement occurs.
Updating of IHM Part I is made possible by the suppliers’ MDs, and MDs that report hazardous materials
which are not presently documented in IHM Part I will need to be recorded in it as part of IHM maintenance.
Changes to IHM are also required in case of relocations or removals of hazardous items falling under scope of
IHM Part I.
Shipowners should have a system in place to ensure that MDs are requested only when necessary, that
they are received from suppliers in completed form, that they are reviewed and that IHM Part I is updated as
necessary. Only a system that achieves all of this will enable shipowners to be compliant with their obligations
under the EUSRR, and in due course the HKC.
Materials Declarations for Inventories of Hazardous Materials
6
3.2 Material Declaration Requests
MDs are fundamental to the IHM and, with time, the provision of MDs with the relevant equipment should
become standard practice within the procurement and supply chain. Until that point, the process starts with
the shipowner making a request to the supplier for those order items where an MD is required.
To avoid unnecessary administration for suppliers and owners, it is important to ensure that MD requests are
relevant as per requirements of the HKC/EUSRR.
Those tasked with maintaining the IHM Part I should identify those order items where an MD is required. In
practical terms MDs are not necessary for stores, consumables, metals and loose equipment or otherwise
exempted items (see Section 2 and Schedule A). All requests for MDs should be carefully considered,
reviewed, and MDs should be provided as necessary. These guidelines and in particular Schedule A, should
be consulted if uncertainty arises between the supplier and shipowner on the necessity to provide a MD.
Where a supplier considers that an MD is not required, they should provide the shipowner with a written
explanation for their further consideration.
Some typical examples of MD requests that are often made, where no MD is in fact necessary, include:
1. Tools (whether hand, mechanical, electrical or diesel powered);
2. Televisions, PCs or related equipment, toaster, microwave, fridge etc – all household-like electrical equipment;
3. Identical replacement parts for existing machinery;
4. Uncoated metal parts like ball bearings, piston rings, push rods, steel plates;
5. Provisions;
6. Linen or clothing;
7. Ropes and lines;
8. Consumables (Table D); and
9. Food & beverages.
In addition to the above, a risk-based approach for MDs may be additionally and mutually agreed between
shipowners and suppliers for universal materials (e.g. gasket sheets) for ensuring that no delivery contains
Table A materials.
It should be noted that a good approach to IHM Part 1 maintenance is to aim for reduction of hazardous
materials onboard. However, some products cannot be produced without substances listed in Table B (e.g.
lead-acid batteries) and contractual requirements where suppliers are obliged to deliver only products which
are free of any and all hazardous materials are neither appropriate nor practicable.
3.3 Role of IHM Service Providers
In accordance with the IMO and EMSA Guidance, the shipowner should nominate a designated person for
IHM Maintenance. The designated person may be an internal appointment (ashore or onboard), or the role
may be assigned to an external consultant. In both situations, the duties of the designated person should be
incorporated in the shipowner’s quality management system. Shipowners may use the services of external
consultants or service providers to maintain IHM for the vessels, and in such circumstances, liability for the
accuracy of the IHM remains with the owner.
Materials Declarations for Inventories of Hazardous Materials
7
3.4 Responsibility of the supplier
On receipt of a request from a shipowner or their representative for an MD and SDoC, suppliers should
identify and declare in an MD whether or not the materials listed in Table A and Table B (and the two
additional substances introduced by EUSRR) are present above the threshold value specified in Appendix 1
and 2 of the IMO Guidelines and Annex B of the EMSA Guidance. If the required information is not available,
the supplier should obtain it from its sub-supplier. The supplier to the vessel (known as the Tier 1 supplier)
shall be responsible for the information provided to the shipowner and must issue its own MD and SDoC. The
supplier shall not pass on documents issued by its sub-suppliers, but should retain all supporting documents
provided to him by its sub-suppliers.
Under both the EUSRR and the HKC the supplier is only obliged to provide an MD where the item supplied
is one that requires an MD. Where an MD request is received for an item that does not require one then the
supplier should advise the shipowner accordingly and reference these guidelines, in particular section 3.4.6.
3.4.1 SDoC
The SDoC is a supplier specific document, confirming that all associated MDs comply with the statutory
requirements (HKC, EUSRR and Res.MEPC.269 (68)). Suppliers can use the same form of SDoC for all
their customers, which describes the legal instruments and, if applicable, the supplier’s own management
approach. A specimen SDoC is found at Appendix 7 of the IHM Guidelines, and is attached as Schedule B -
Form of SDoC to this guidance.
ISO 30005 standard offers a unique numbering system for MDs and SDoCs.
3.4.2 Scope of SDoC
The supplier must state the extent of the coverage provided by a SDoC, as follows:
1. Limit its coverage to a specific order;
2. Cover repeated orders of similar products; or
3. General applicability for all orders by any customer.
Where a supplier selects to issue a SDoC to cover all MDs issued by the supplier to the customer, this can
usefully limit the administrative burden for otherwise issuing multiple SDoCs.
3.4.3 SDoC – ID Number
Each SDoC must contain a SDoC – ID Number. This is very important as it forms the essential link between the
SDoC and all associated MDs. Every MD has to have a clear reference to an SDoC, and this is achieved by each
MD stating a valid SDoC - ID number. The supplier should choose a unique numbering system for SDoCs.
Materials Declarations for Inventories of Hazardous Materials
8
3.4.4 How to complete a SDoC
The following diagram demonstrates how suppliers should complete a SDOC.
SUPPLIER’S DECLARATION OF CONFORMITY
for Material Declaration Management
(according to IMO Resolution MEPC.269(68) and EU Ship Recycling Regulation)
1)
SDoC ID No
.
SD-MMYYYY
-AbrSuppl.-onoingNo.
2) Issuer’s name:
Issuer’s address:
3) Scope of SDoC Object(s) of the declaration:
Valid for this order and
listed product(s) only
Valid for repeated order of
listed product(s) only
×
Valid for all orders and
customers (typical choice)
4) The object of declaration described above is in conformity with the requirement of the
following documents:
5) Document No. Title Edition Date
MEPC. Res 269(68) Guidelines for the Development of
Inventory of Hazardous Materials
2015 15.05.2015
SRCONF 45 International Hong Kong Convention
for the Safe and Environmentally
Sound Recycling of Ships
2009 19.05.2009
ISO 30005 Ships and marine technology — Ship
recycling management systems —
Information control for hazardous
materials in the manufacturing chain
of shipbuilding and ship operations
2012 01.05.2012
REGULATION (EU)
No 1257/2013
Regulation of the European Parliament
and of the Council of 20 November
2013 on ship recycling and amending
Regulation (EC) No 1013/2006 and
Directive 2009/16/EC
2013 20.11.2013
related to:
REGULATION (EU)
No 1257/2013
EMSA’s Best Practice Guidance on
the Inventory of Hazardous Materials 2016 28.10.2016
6)
Additional Inf
ormation:
Signe
d for and on behalf of:
(Place of issue) (Date of issue)
7)
(Name, function) (Signature)
1)
2)
3)
4)
5)
6)
7)
8)
9)
10)
Choose a unique
numbering system
for SDoCs
Make entries only if
scope of this SDoC
is limited to specific
products. If SDoC
is not limited to
specific products,
leave this section
blank or insert under
1) “all products
supplied”
Here, references
to the legal
requirements (SR/
CONF/45 and Res.
MEPC.269(68), etc.)
and certificates or
quality manuals
(e.g. ISO 9001, ISO
30005) applicable
for the provision
of IHM related
information and
documents are
contained. The most
common
requirements have
been included, and
can be amended if
necessary
Company name
Company address
Company name
or stamp
Signature and date
of issue are essential
to include
Name and function
are essential
to include
Materials Declarations for Inventories of Hazardous Materials
9
3.4.5 Material Declarations
The Material Declaration is a product-specific document and a “check list” on whether or not any of the
homogenous materials (see 3.4.7) contained in a supplied product contain any of the listed hazardous
materials above the related threshold levels (if applicable). It is important to understand that the MD is
required whether or not hazardous materials are present. All MDs must refer to a valid SDoC, by reference to
the SDoC - ID Number.
3.4.6 Completing a Material Declaration
When a product does not contain a hazardous material, or where it is present in a concentration below any
specific threshold value, a “No” entry should be made and no further details are required in the respective
column(s). In such cases a group of similar products can be covered by a single MD (e.g. O-Rings of
different dimensions).
Where a listed hazardous material is contained (above the given threshold level – if any) a “Yes” entry is
required and further details are to be provided in the columns “quantity” and “unit“ and further specified in
the far right column. In such cases, a single MD must be issued for each product, because it is necessary to
identify the quantity of hazardous materials and that most likely varies in different products.
The following is important to note:
• “SDoC ID-No.” in the MD form and its associated SDoC form must be the same;
• “Company name” in MD & “Issuer’s name” in SDoC must be the same; and
• “Address” in MD and the “Issuer’s name” in SDoC form must be the same.
3.4.7 Homogeneous materials
A homogeneous material is a material of uniform composition throughout that cannot be mechanically
disjointed into different materials, meaning that the materials cannot, in principle, be separated by
mechanical actions such as unscrewing, cutting, crushing, grinding and abrasive processes. The following
provides examples of homogeneous materials: figure 1 shows the layers of paint and figure 2 a cable with six
different homogenous materials.
Topcoat
Primer
Chromate
Zinc
Steel
Sheath
(PVC)
Intervention
(paper)
Conductor
(copper)
3 insulators
(rubber)
Figure 2: Five homogenous materials Figure 3: Six homogenous materials
Where a listed hazardous material is contained above its specific threshold level in a homogeneous material, in
the “Quantity-section the weight of the homogenous material containing hazardous materials is to be specified
(not the weight of pure hazardous material itself). In the right column of MD the exact location and material
containing the hazardous material is to be specified. For further clarity, a diagram or drawing can be attached.
Materials Declarations for Inventories of Hazardous Materials
10
3.4.8 Further Points to Note
In addition to the information provided above, the following additional information should be noted:
There are widely varying national definitions for “asbestos free”. For the purposes of HKC and EUSRR any
concentration > 0.1% of the six different types of asbestos is relevant for IHMs. Please check carefully.
For RoHS-compliant electronics and electrical appliances required information is mostly already available
(Table A and Table B line 1-6).
Suppliers may find it convenient to retain a library of previously submitted MDs for future use. However,
very great care must be taken and suppliers must be aware that the specifications between different
sub-suppliers may vary, or specifications may be changed during production without further notice.
3.4.9 MD – ID Number
All MDs should carry a unique MD – ID Number.
Materials Declarations for Inventories of Hazardous Materials
11
Table Material Name Threshold
Value
Present above
threshold value
IF YES
Material Mass
IF YES Information
on where it is used
Yes / No Mass Unit
TABLE B
Materials listed
in appendix 2 of
the Convention
Cadmium & Cadmium Compounds 100 mg/kg
Hexavalent Chromium and Hexavalent Chromium
Compounds
1,000 mg/kg
Lead and Lead Compounds 1,000 mg/kg
Mercury and Mercury Compounds 1,000 mg/kg
Polybromated Biphenyl (PBBs) 50 mg/kg
Polybrominated Dephenyl Ethers (PBDEs) 1,000 mg/kg
Polychloronaphtalenes (Cl>=3) 50 mg/kg
Radioactive substances No threshold
value
Certain Shortchain Chlorinated Paraffins 1%
* 0.1% in principle, if 1% is applied, it should be recorded in Remarks section
** 50 mg/kg is to be used as threshold for reporting existing PCB only. NOTE: All new materials are to be free of any PCBs!
*** Additional material to be listed acc. to Annex 1 and Annex 2 of the EU Ship Recycling Regulation No. 1257/2013
The object of declaration described above is in conformity with the IMO Guidelines for the development of Inventory of Hazardous Materials
Resolutions MEPC.269(68) (and, for EU-Ships: EMSA’s Best Practice Guidance on the Inventory of Hazardous Materials)
Important Notice: The content and specifications of this form may not be changed or amended. Any changes or amendments by others than the
author of this form constitute a breach of copyright law.
(Date DD/MM/YYYY) (Signature and Company Stamp)
IMPORTANT NOTICE: Any significant change in material content may render this declaration invalid
Table Material Name Threshold
Value
Present above
threshold level
IF YES
Material
Mass
IF YES Information on
where it is used
Yes/No
Mass Unit
TABLE A
Materials
listed in
appendix
1 of the
Convention
Asbestos Asbestos 0.1%*
Polychlorinated
biphenyls (PCBs)
Polychlorinated Biphenyls
(PCBs)
50mg/kg**
Ozone depleting
substances
Chlorofluorocarbons (CFCs)
No threshold
level
Halons
Other fully Halogenated CFCs
Carbon Tetrachloride
1,1,1-Trichloroethane
Hydrochlorofluorocarbons
Hydrobromofluorocarbons
Methyl Bromide
Bromochloromethane
Anti-fouling systems
containing organotin
compounds as a biocide
2,500 mg
total tin/kg
MATERIAL DECLARATION
Type 1: Self Declaration
3.5 How to complete a MD
The following diagram demonstrates how suppliers should complete a MD.
<Product information>
Product Name Product Number
Delivered Unit Product Information
Amount Unit
Date:
<Date of declaration>
<Material information>
MD-ID-No.
<MD ID Number>
Remarks
<Other information (e.g. client, shipbuilder, hull no. if applicable)>
Company name
Telephone No.
Address
E-mail address
<Supplier (respondent) information>
SD-MMYYYY-AbrSuppl.-ongoingNo.
Division name
Fax No.
Contact person
SDoC ID No.
Choose
a unique
numbering
system for
MDs
A group of
products
can be
covered by
one MD (e.g.
O-Rings of
different
dimensions
and not
containing
HazMats)
Signature and date
are essential
to include
Associated
SDoC-ID no.
is essential to
include
Choose a
logical unit for
the delivered
product (for
example: piece,
kg, m, m
2
, m
3
,
etc.), both must
agree
In case the hazardous material is not
contained in a supplied product, or
below the specific threshold level,
a “No” entry is made and no further
details are required in the respective
line(s). In case a listed hazardous
material is contained (above the
given threshold level – if any –
otherwise any concentration is to be
declared) a “Yes” entry is required
and further details are to be provided
under the columns “quantity”, “unit”,
and where it is included
This material information shows the amount of hazardous materials contained in 1 Unit:
1
Unit
Materials Declarations for Inventories of Hazardous Materials
12
4 Dialogue and Reporting
MDs and SDoCs should be reviewed by the shipowner or its representative in the context of the ship specific
IHM once they have been received. Where the forms are not fully compliant, the shipowner should provide
the supplier with the reasons for their rejection in the spirit of a collaboration to achieve effective compliance
with the IHM requirements. Collaboration between shipowners and suppliers in the development and
maintenance of IHM Part I is fundamental to facilitating safe and environmentally sound ship recycling, and
the wider effort to reduce the environmental impact of shipping.
Additional guidance on common mistakes in MD and SDOC are provided in Schedule D of this document.
Materials Declarations for Inventories of Hazardous Materials
13
Schedule A – Appendix 1 from the 2015 Guidelines for the Development of
Inventories of Hazardous Materials
(Table A)
18
MEPC 68/21/Add.1
Annex 17, page 12
https://edocs.imo.org/Final Documents/English/MEPC 68-21-ADD.1 (E).doc
APPENDIX 1
ITEMS TO BE LISTED IN THE INVENTORY OF HAZARDOUS MATERIALS
Table A – Materials listed in appendix 1 of the Annex to the Convention
No. Materials
Inventory
Threshold
value
Part I
Part II Part III
A-1 Asbestos x
0.1%
4
A-2 Polychlorinated biphenyls (PCBs) x
50 mg/kg
5
A-3
Ozone depleting
substances
CFCs x
no threshold
value
6
Halons x
Other fully halogenated CFCs x
Carbon tetrachloride x
1,1,1-Trichloroethane (Methyl chloroform) x
Hydrochlorofluorocarbons x
Hydrobromofluorocarbons x
Methyl bromide x
Bromochloromethane x
A-4 Anti-fouling systems containing organotin compounds as a biocide
x
2,500 mg total
tin/kg
7
4
In accordance with regulation 4 of the Convention, for all ships, new installation of materials which contain
asbestos shall be prohibited. According to the UN recommendation "Globally Harmonized System of
Classification and Labelling of Chemicals (GHS)" adopted by the United Nations Economic and Social
Council's Sub-Committee of Experts on the Globally Harmonized System of Classification and Labelling of
Chemicals (UNSCEGHS), the UN's Sub-Committee of
Experts, in 2002 (published in 2003), carcinogenic
mixtures classified as Category 1A (including asbestos mixtures) under the GHS are required to be
labelled as carcinogenic if the ratio is more than 0.1%. However, if 1% is applied, this threshold value
should be recorded in the Inventory and, if available, the Material Declaration and can be applied not later
than five years after the entry into force of the Convention. The threshold value o
f 0.1% need not be
retroactively applied to those Inventories and Material Declarations.
5
In accordance with regulation 4 of the Convention, for all ships, new installation of materials which contain
PCBs shall be prohibited. The Organization set 50 mg/kg as the threshold value referring to the
concentration level at which wastes, substances and articles containing, consisting of or contaminated with
PCB are characterized as hazardo
us under the Basel Convention.
6
"No threshold value" is in accordance with the Montreal Protocol for reporting ODS. Unintentional trace
contaminants should not be listed in the Material Declarations and in the Inventory.
7
This threshold value is based on the Guidelines for brief sampling of anti-fouling systems on ships
(resolution MEPC.104(49)).
Materials Declarations for Inventories of Hazardous Materials
14
(Table B)
19
MEPC 68/21/Add.1
Annex 17, page 13
https://edocs.imo.org/Final Documents/English/MEPC 68-21-ADD.1 (E).doc
Table B – Materials listed in appendix 2 of the Annex to the Convention
No. Materials
Inventory
Threshold value
Part I Part II Part III
B-1 Cadmium and cadmium compounds x
100 mg/kg
8
B-2 Hexavalent chromium and hexavalent chromium compounds x
1,000 mg/kg
8
B-3 Lead and lead compounds x
1,000 mg/kg
8
B-4 Mercury and mercury compounds x
1,000 mg/kg
8
B-5 Polybrominated biphenyl (PBBs) x
50 mg/kg
9
B-6 Polybrominated diphenyl ethers (PBDEs) x
1,000 mg/kg
8
B-7 Polychlorinated naphthalenes (more than 3 chlorine atoms) x
50mg/kg
10
B-8 Radioactive substances x
no threshold value
11
B-9
Certain shortchain chlorinated paraffins (Alkanes, C10-C13,
chloro)
x
1%
12
8
9
10
11
12
The Organization set this as the threshold value referring to the Restriction of Hazardous Substances
(RoHS Directive 2011/65/EU, Annex II).
The Organization set 50 mg/kg as the threshold value referring to the concentration level at which wastes,
substances and articles containing, consisting of or contaminated with PBB are characterized as
hazardous under the Basel Convention.
The Organization set 50 mg/kg as the threshold value referring to
the concentration level at which wastes,
substances and articles containing, consisting of or contaminated with PCN are characterized as
hazardous under the Basel Convention.
All radioactive sources should be included in the Material Declaration and in the Inventory. Radioactive
source means radioactive material permanently sealed in a capsule or closely bonded and in a solid form
that is used as a source of radiation. This includes consumer products and industrial gauges with
radioactive materials. Examples are listed in appendix 10 of Res.MEPC.269(68).
The Organization set 1
% as the threshold value referring to the EU legislation that restricts Chlorinated
Paraffins from being placed on the market for use as substances or as constituents of other substances or
preparations in concentrations higher than 1% (EU Regulation 1907/2006, Annex XVII Entry 42 and
Regulation 519/2012).
Materials Declarations for Inventories of Hazardous Materials
15
(Table C)
20
MEPC 62/24
Annex 3, page 13
I:\MEPC\62\24.doc
TABLE C Potentially hazardous items
No. Properties Goods
Inventory
Part I Part II Part III
C-1
Liquid
Oiliness
Kerosene x
C-2 White spirit x
C-3 Lubricating oil x
C-4 Hydraulic oil x
C-5 Anti-seize compounds x
C-6 Fuel additive x
C-7 Engine coolant additives x
C-8 Antifreeze fluids x
C-9
Boiler and feed water treatment and test
re-agents
x
C-10 De-ioniser regenerating chemicals x
C-11 Evaporator dosing and descaling acids x
C-12 Paint stabilizers/rust stabilizers x
C-13 Solvents/thinners x
C-14 Paints x
C-15 Chemical refrigerants x
C-16 Battery electrolyte x
C-17 Alcohol, methylated spirits x
C-18
Gas
Explosives/
inflammables
Acetylene x
C-19 Propane x
C-20 Butane x
C-21 Oxygen x
C-22
Green House
Gases
CO
2
x
C-23 Perfluorocarbons (PFCs) x
C-24 Methane x
C-25 Hydrofluorocarbon (HFCs) x
C-27 Nitrous oxide (N
2
O) x
C-28 Sulfur hexafluoride (SF
6
) x
C-29
Liquid
Oiliness
Bunkers: fuel oil x
C-30 Grease x
C-31 Waste oil (sludge) x
C-32
Bilge and/or waste water generated by the
after-treatment systems fitted on machineries
x
C-33 Oily liquid cargo tank residues x
C-34 Ballast water x
C-35 Raw sewage x
C-36 Treated sewage x
C-37 Non-oily liquid cargo residues x
C-38 Gas
Explosibility/
inflammability
Fuel gas x
Materials Declarations for Inventories of Hazardous Materials
16
(Table C continued)
21
MEPC 62/24
Annex 3, page 14
I:\MEPC\62\24.doc
TABLE C Potentially hazardous items
No. Properties Goods
Inventory
Part I Part II Part III
C-39
Solid
Dry cargo residues x
C-40 Medical waste/infectious waste x
C-41 Incinerator ash
2)
x
C-42 Garbage
2)
x
C-43 Fuel tank residues x
C-45 Oily solid cargo tank residues x
C-45 Oily or chemical contaminated rags x
C-46 Batteries (incl. lead acid batteries) x
C-47 Pesticides/insecticide sprays x
C-48 Extinguishers x
C-49
Chemical cleaner (incl. electrical equipment
cleaner, carbon remover)
x
C-50 Detergent/bleacher (could be a liquid) x
C-51 Miscellaneous medicines x
C-52
Fire fighting clothing and Personal protective
equipment
x
C-53 Dry tank residues x
C-54 Cargo residues x
C-55
Spare parts which contain materials listed in
Table A or Table B
x
2) Definition of garbage is identical to that in MARPOL Annex V. However, incinerator ash is classified
separately because it may include hazardous substances or heavy metals.
TABLE D
Regular consumable goods potentially containing Hazardous Materials
No. Properties Example
Inventory
Part I Part II Part III
D-1
Domestic and
accommodation
appliances
Computers, refrigerators, printers, scanners, television
sets, radio sets, video cameras, video recorders,
telephones, consumer batteries, fluorescent lamps,
filament bulbs, lamps
x
This Table does not include ship-specific equipment integral to ship operations, which has to be listed in
Part I of the Inventory.
Materials Declarations for Inventories of Hazardous Materials
17
(Table D)
MEPC 68/21/Add.1
Annex 17, page 15
https://edocs.imo.org/Final Documents/English/MEPC 68-21-ADD.1 (E).doc
No.
Properties
Goods
Inventory
Part I
Part II
Part III
C-39
Solid
Dry cargo residues
x
C-40
Medical waste/infectious waste
x
C-41
Incinerator ash
13
x
C-42
Garbage
x
C-43
Fuel tank residues
x
C-44
Oily solid cargo tank residues
x
C-45
Oily or chemical contaminated rags
x
C-46
Batteries (incl. lead acid batteries)㻌
x
C-47
Pesticides/insecticide sprays
x
C-48
Extinguishers
x
C-49
Chemical cleaner (incl. electrical equipment
cleaner, carbon remover)
x
C-50
Detergent/bleacher (could be a liquid)
x
C-51
Miscellaneous medicines
x
C-52
Fire fighting clothing and Personal protective
equipment
x
C-53
Dry tank residues
x
C-54
Cargo residues㻌
x
C-55
Spare parts which contain materials listed in
Table A or Table B
x
Table D – Regular consumable goods potentially containing hazardous materials
14
No.
Properties
Example
Inventory
Part I
Part II
Part III
D-1
Electrical and electronic
equipment
Computers, refrigerators, printers, scanners, television
sets, radio sets, video cameras, video recorders,
telephones, consumer batteries, fluorescent lamps,
filament bulbs, lamps
x
D-2
Lighting equipment
Fluorescent lamps, filament bulbs, lamps
x
D-3
Non ship-specific
furniture, interior and
similar equipment
Chairs, sofas, tables, beds, curtains, carpets, garbage
bins, bed-linen, pillows, towels, mattresses, storage
racks, decoration, bathroom installations, toys, not
structurally relevant or integrated artwork
x
13
Definition of garbage is identical to that in MARPOL Annex V. However, incinerator ash is classified
separately because it may include hazardous substances or heavy metals.
14
This table does not include ship-specific equipment integral to ship operations, which has to be listed in
part I of the inventory.
Materials Declarations for Inventories of Hazardous Materials
18
Schedule B – Model Form of SDoC
SUPPLIER’S DECLARATION OF CONFORMITY
for Material Declaration Management
(according to IMO Resolution MEPC.269(68) and EU Ship Recycling Regulation)
1) SDoC ID No.:
2) Issuer’s name:
Issuer’s address:
3) Scope of SDoC Object(s) of the declaration:
Valid for this order and
listed product(s) only
Valid for repeated order of
listed product(s) only
×
Valid for all orders and
customers (typical choice)
4) The object of declaration described above is in conformity with the requirement of the following documents:
5) Document No. Title Edition Date of
MEPC. Res 269(68) Guidelines for the Development of Inventory
of Hazardous Materials
2015 15.05.2015
SRCONF 45 International Hong Kong Convention for the Safe and
Environmentally Sound Recycling of Ships
2009 19.05.2009
ISO 30005 Ships and marine technology — Ship recycling
management systems — Information control for
hazardous materials in the manufacturing chain of
shipbuilding and ship operations
2012 01.05.2012
REGULATION (EU)
No 1257/2013
Regulation of the European Parliament and of the
Council of 20 November 2013 on ship recycling
and amending Regulation (EC) No 1013/2006 and
Directive 2009/16/EC
2013 20.11.2013
related to: REGULATION (EU)
No 1257/2013
EMSA’s Best Practice Guidance on the Inventory
of Hazardous Materials
2016 28.10.2016
6) Additional Information:
Signed for and on behalf of:
(Place of issue) (Date of issue)
7)
(Name, function) (Signature)
1)
2)
3)
4)
5)
6)
7)
8)
9)
10)
Materials Declarations for Inventories of Hazardous Materials
19
MATERIAL DECLARATION
Type 1: Self Declaration
Schedule C – Model Form of MD
Table Material Name Threshold Value Present above
threshold value
IF YES
Material Mass
IF YES Information
on where it is used
Yes / No Mass Unit
TABLE B
Materials listed in
appendix 2 of the
Convention
Cadmium & Cadmium Compounds 100 mg/kg
Hexavalent Chromium and Hexavalent Chromium
Compounds
1,000 mg/kg
Lead and Lead Compounds 1,000 mg/kg
Mercury and Mercury Compounds 1,000 mg/kg
Polybromated Biphenyl (PBBs) 50 mg/kg
Polybrominated Dephenyl Ethers (PBDEs) 1,000 mg/kg
Polychloronaphtalenes (Cl>=3) 50 mg/kg
Radioactive substances No threshold
value
Certain Shortchain Chlorinated Paraffins 1%
* 0.1% in principle, if 1% is applied, it should be recorded in Remarks section
** 50 mg/kg is to be used as threshold for reporting existing PCB only. NOTE: All new materials are to be free of any PCBs!
*** Additional material to be listed acc. to Annex 1 and Annex 2 of the EU Ship Recycling Regulation No. 1257/2013
The object of declaration described above is in conformity with the IMO Guidelines for the development of Inventory of Hazardous Materials Resolutions MEPC.269(68)
(and, for EU-Ships: EMSA’s Best Practice Guidance on the Inventory of Hazardous Materials)
Important Notice: The content and specifications of this form may not be changed or amended. Any changes or amendments by others than the author of this form
constitute a breach of copyright law.
(Date DD/MM/YYYY) (Signature and Company Stamp)
IMPORTANT NOTICE: Any significant change in material content may render this declaration invalid
Table Material Name Threshold
Value
Present above
threshold level
IF YES
Material Mass
IF YES Information on where it is used
Yes/No
Mass Unit
TABLE A
Materials listed
in appendix
1 of the
Convention
Asbestos Asbestos 0.1%*
Polychlorinated
biphenyls (PCBs)
Polychlorinated Biphenyls
(PCBs)
50mg/kg**
Ozone depleting
substances
Chlorofluorocarbons (CFCs)
No threshold
level
Halons
Other fully Halogenated
CFCs
Carbon Tetrachloride
1,1,1-Trichloroethane
Hydrochlorofluorocarbons
Hydrobromofluorocarbons
Methyl Bromide
Bromochloromethane
Anti-fouling systems
containing organotin
compounds as a biocide
2,500 mg
total tin/kg
<Product information>
Product Name Product Number
Delivered Unit Product Information
Amount Unit
Date:
<Date of declaration>
<Material information>
MD-ID-No.
<MD ID Number>
Remarks
<Other information (e.g. client, shipbuilder, hull no. if applicable)>
Company name
Telephone No.
Address
E-mail address
<Supplier (respondent) information>
SD-MMYYYY-AbrSuppl.-ongoingNo.
Division name
Fax No.
Contact person
SDoC ID No.
This material information shows the amount of hazardous materials contained in 1 Unit:
1
Unit
Materials Declarations for Inventories of Hazardous Materials
20
Schedule D – Common mistakes
Introduction
This section provides examples of common mistakes in MDs and SDoCs and guidance how to resolve them.
An understanding of these issues will ease the preparation of the documents by suppliers and help reduce
the workload for all involved.
MD Requests for equipment and stores delivered to the ship, far in excess of what is required under the
EUSRR or HKC regimes can overwhelm suppliers, with varying consequences, all of which are detrimental to,
and/or inconsistent with, the shipowners’ obligations in relation to the maintenance of IHM:
i. suppliers refuse to supply certain ships/shipowners altogether;
ii. suppliers refuse or fail to provide any MDs at all, whether for items that require them or those
that do not;
iii. suppliers comply with unnecessary requests or spend time rejecting them, at significant cost of
manpower, and such costs are passed on to shipowners in increased prices or surcharges;
iv. some unscrupulous suppliers simply issue MDs without any care or regard for their accuracy,
rendering their content inaccurate and worthless;
Similarly, the inaccuracy of the MD and SDoC forms completion from the suppliers may include:
i. sending MD and the SDoC without being correctly completed, indicating insufficient knowledge of the
forms completion instructions;
ii. sending the MDs instead of the SDoC and vice versa;
iii. sending MSDS or other technical specification forms instead of MD and SDoC;
iv. filling in the MD form without having concrete data of the supplied items composition.
None of these outcomes benefit IHM-compliance for the supplier, shipowner, crew or, at the end of the
ship’s life, the ship recycler who has to incorporate the IHM-information into the recycling planning. As such
excessive requests create significant disadvantages for the entire industry and do nothing to further the
objective of safer recycling.
Materials Declarations for Inventories of Hazardous Materials
21
Common Mistakes and How to Solve Them
1 SDoC
1 SDoC ID no. is missing.
è Insert a SDoC ID no. (guidance provided above). One SDoC for a supplier company is
advisable and all product specific MDs can then reference this SDoC-ID number.
2 Missing information concerning relevant legislations, standards and norms
è Insert legal and organisational references as applicable. This clarifies the legal
background and avoids mis-understandings. As such, it safeguards suppliers and
shipowners alike from conflicts as the background is clearly defined.
At least the following is to be listed:
• Hong Kong Convention
• EU SRR
The following are optional:
MEPC. Res 269(68)
EMSA’s Best Practice Guidance on the Inventory of Hazardous Materials
ISO 30005
RoHS
REACH
3 Missing / wrong contact details and signature
è The SDoC must contain suppliers’ contact details and be signed by a representative
of the company.
4 Provision of TIER – two documents
As the SDoC is a legal document and is to be requested from / provided by Tier 1 supplier, it is
necessary that the Tier 1 supplier provides the documents in its own company name.
Materials Declarations for Inventories of Hazardous Materials
22
2 MD
1 MD ID no. is missing
è Insert a unique ID for your MD, as described above. It is advisable to use a structured
numbering system, for easy archiving and reuse for future requests.
2 Reference to SDoC ID No. is missing
è Insert the correct SDoC ID No. (from SDoC). MDs have to show the SDoC-ID number
they are related to, otherwise, the combination of the two documents is not legally
valid and will not be accepted by customers.
By issuing one “Master SDoC”, the same SDoC ID No. can be used for as many MDs
as supplier wants.
3 Amount and / or unit is missing
è Insert quantity / unit of the declared item, both selections should be identical for
ensuring consistency in the details provided. For avoiding order-specific MDs clarify
with your customer if he accepts a standard value for quantities delivered.
4 Product name not identical with PO
è Ensure that the right item name is referenced, so the documents can be related easily
to the respective order item and documentation request. Alternatively, the product
number should be identical at least.
5 Unnecessary Yes-entries
è Before making a Yes-entry, check if the item / material falls under any exception as
provided (e.g. metal and metal alloys are excluded and not relevant for suppliers
documentation). Otherwise, unnecessary entries and follow-up activities onboard are
generated during IHM Maintenance for the shipowner / customer.
6 Wrong Quantities
è If a hazardous material is contained above its specific threshold level, a Yes-entry is
required. The threshold relates to the entire homogenous material containing it and
therefore the mass and unit of the entire homogeneous material is to be specified.
DO NOT insert the mass of the pure HazMat contained in an unspecified mass of a
homogenous material which contains it.
7 Missing / wrong contact details and signature
è The MD must contain suppliers’ contact details (and depending on the form be signed).
8 Provision of TIER – two documents
è As the MD is a legal document and was requested from the supplier, it is incumbent
on the supplier to provide the documents in their company’s name. It is not
acceptable that suppliers provide Tier 2 (their supplier) documents. The contract
exists between supplier and customer and this needs to be considered in the
documents as well. As such a supplier (Tier 1) has to create own documents based on
data from its supply chain.
Materials Declarations for Inventories of Hazardous Materials
23
International Chamber of Shipping
Walsingham House 35 Seething Lane London EC3N 4AH
Tel: + 44 20 7090 1460
Email: [email protected]
Web: www.ics-shipping.org
Materials Declarations for Inventories of Hazardous Materials
Published by
Marisec Publications
Walsingham House
35 Seething Lane
London EC3N 4AH
November 2022
T
el: +44 20 7090 1460
Email: [email protected]
Web: www.ics-shipping.org
© International Chamber of Shipping 2022
While the advice given in this Guidance has been developed using the best information
available, it is intended purely as guidance to be used at the user’s own risk. No responsibility
is accepted by Marisec Publications or by the International Chamber of Shipping or by any
person, firm, corporation or organisation who or which has been in any way concerned with
the furnishing of information or data, the compilation, publication or any translation, supply
or sale of this Guidance for the accuracy of any information or advice given herein or for any
omission herefrom or from any consequences whatsoever resulting directly or indirectly
from compliance with or adoption of guidance contained therein even if caused by a failure to
exercise reasonable care.
The International Chamber of Shipping (ICS) is the global trade association representing
national shipowners’ associations from Asia, Africa, the Americas and Europe and more
than 80% of the world merchant fleet. Established in 1921, ICS is concerned with all aspects
of maritime affairs particularly maritime safety, environmental protection, maritime law
and employment affairs. ICS enjoys consultative status with the UN International Maritime
Organization (IMO) and International Labour Organization (ILO).
