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Transition to MEPC.379(80): What ships should do with older IHMs.

With the Hong Kong Convention coming into force on June 26, 2025, the need for an accurate and up-to-date inventory of hazardous materials (IHM) has never been more urgent. For ship owners and managers, especially those whose IHMs were prepared under older IMO directives, the publication of MEPC.379(80) in 2023 and Amendment Resolution MEPC.405(83) marks a crucial moment. This newsletter highlights key regulatory changes, specific technical updates and immediate actions required for ships whose IHMs were developed under MEPC.197(62) or MEPC.269(68).

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Transition to MEPC.379(80): What ships with older IHMs should do.

ResolutionYearReplacesCurrent status
MEPC.197(62)2011MEPC.179(59)Obsolete
MEPC.269(68)2015MEPC.197(62)Replaced
MEPC.379(80)2023MEPC.269(68)Active

What has changed in MEPC.379(80)?

1. Threshold reduced for polybrominated biphenyls (PBBs).

Old threshold (MEPC.197(62), Appendix 1, Table B): 1,000 mg/kg
New threshold (MEPC.269(68) and MEPC.379(80), Appendix 1, Table B): 50 mg/kg
This significant reduction brings the IMO in line with Basel Convention standards. For ships with IHMs prepared in accordance with MEPC.197(62), new laboratory testing may be required to confirm compliance.

2. Cybutryne now listed as hazardous

New material added (MEPC.379(80), Appendix 1, Table A-4): Antifouling systems containing Cybutryne.
Threshold: 1,000 mg/kg in dry paint or 200 mg/kg in wet paint.
This affects ships whose IHMs are prepared according to MEPC.269(68), which does not include Cybutryne. Updating is mandatory if the material is present.

If your IHM was prepared under MEPC.197(62)

Key gap: outdated PBB threshold value.
Required actions:

  • Perform a gap analysis on all items containing PBBs.
  • If based on material declarations only, provide specific testing according to MEPC.379(80), Appendix 9.
  • Update thresholds where necessary (Ref: MEPC.379(80), §3.5)
  • Review the IHM Part-I and statements (Ref: §4.3.1, §6.2)

If your IHM was prepared under MEPC.269(68)

Major gap: lack of Cybutryne
Required actions:

  • Review all antifouling systems (Ref: MEPC.379(80), Appendix 1, Table A-4)
  • If not certain, sample and test coatings for Cybutryne content
  • Amend IHM Part I accordingly
  • Ensure new entries comply with the format in Appendix 2 and the procedures in §4.2 and §6

Snapshot compliance

Prepared UnderKey issueImmediate Action
MEPC.197(62)PBB threshold outdatedPerform laboratory tests, update IHM.
MEPC.269(68)Cybutryne not listedAntifouling reviewed, entries revised
MEPC.379(80)-Regular maintenance and monitoring

Next steps

  1. 1.

    Initiate technical gap assessment for existing IHMs

  2. 2.

    Arrange laboratory testing as necessary

  3. 3.

    Ensure that IHM maintenance is based on MEPC.379(80)

  4. 4.

    Coordinate with flag and RO for approvals during investigations

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