Annex V HME cargo residues, E-waste, and hold-wash water

What this article covers, and what it does not

This article is about one slice of MARPOL Annex V: the residues of solid bulk cargoes, the test that decides whether those residues are Harmful to the Marine Environment, the hold-cleaning and wash-water problem that flows from that test, and the recording and disposal that follow. It also covers E-waste and the wider operational-garbage categories, because the same Garbage Record Book and the same reception-facility logic tie them together.

The general discharge regime, the eight special areas, and the per-category distance table are set out in the Annex V garbage-discharge overview and in the Annex V hub. The distance-by-distance and condition-by-condition detail for the two at-sea regimes lives in the dedicated articles on Regulation 4, discharge outside special areas and Regulation 6, discharge within special areas. This article does not restate those. It picks up where the cargo touches the chemistry: when a residue carries a hazard the GHS recognizes, Annex V stops being a distance problem and becomes a reception-facility problem.

A short word on numbering, because it trips people up. The 2011 revised Annex V text adopted by Resolution MEPC.201(62) orders the regulations so that Regulation 3 is the general discharge prohibition, Regulation 4 governs discharge outside special areas, Regulation 5 governs fixed and floating platforms, and Regulation 6 governs discharge within special areas. The 2012 Guidelines under MEPC.219(63) carry a summary Table 1 whose column headings read the other way around for the platform footnote, but the operative cross-references in section 3.1 and 3.2 of those Guidelines are explicit: cargo residues are discharged “in accordance with regulations 4.1.3 and 6.1.2,” and HME residues are “subject to regulations 4.1.3 and 6.1.2.1 of the revised MARPOL Annex V.” Reg 4 is the outside-special-areas route; Reg 6 is the within-special-areas route. Get that pairing right and the rest follows.

Cargo residues as a defined garbage stream

Annex V folds cargo residues into the definition of garbage, but it draws the boundary tightly. Regulation 1.9 of the revised Annex defines cargo residues as the remnants of cargo that cannot be recovered using commonly available methods for unloading. That phrase does the heavy lifting. Grabs, conveyors, pneumatic suction, and mechanical sweeping recover the bulk of the parcel; what remains stuck in the corners of the hold, lodged in the tank-top frames, clinging to the bulkheads as dust, or suspended in the wash water afterward, is the residue that Annex V regulates.

The boundary matters because it separates residue from recoverable cargo. A master cannot reclassify a thousand tonnes of grain still sitting in the hold as “residue” and pump it over the side because the discharge berth was tight on time. Section 3.5 of the 2012 Guidelines is direct about this: cargo residues are “created through inefficiencies in loading, unloading, onboard handling,” and operators are expected to minimize them through careful trimming, accurate stowage, and clean discharge technique, not to manufacture them for disposal convenience. Residue is what the unloading method genuinely leaves behind, no more.

There’s a second boundary, between residue and bilge water. Section 3.1 of the Guidelines carves out cargo material that ends up in the cargo-hold bilge water: that material is not treated as cargo residue, provided the material is not harmful to the marine environment and the bilge water is discharged from a loaded hold through the ship’s fixed piping bilge drainage system. The carve-out is narrow, conditioned on the non-HME status of the cargo, and does not extend to wash water generated by hold cleaning. It exists so that drainage of a loaded hold during the voyage is not caught as a garbage discharge; it does not open a back door for HME material.

Cargo residues sit alongside the operational and victual streams the broader Annex regulates, but they run on their own documentary track. They are declared before the cargo is loaded, handled at the discharge port and after it, and logged in a separate book. That separation, formalized in 2018, is the structural recognition that a bulk carrier’s residue problem is a cargo-chemistry problem, not a housekeeping one. The bulk carrier trade is where this regime bites hardest, because every parcel of dry bulk leaves something behind.

The HME test: seven criteria from the GHS and the IMSBC Code

The phrase “Harmful to the Marine Environment” is not a vibe; it is a defined classification with seven discrete triggers. Section 3.2 of the 2012 Guidelines (MEPC.219(63)) states that cargo residues “are considered harmful to the marine environment and subject to regulations 4.1.3 and 6.1.2.1 of the revised MARPOL Annex V if they are residues of solid bulk substances which are classified according to the criteria of the United Nations Globally Harmonized System” of classification and labelling of chemicals as meeting one or more of the following. Any single trigger is enough. The criteria, verbatim from section 3.2, are:

• .1 Acute Aquatic Toxicity Category 1; and/or
• .2 Chronic Aquatic Toxicity Category 1 or 2; and/or
• .3 Carcinogenicity Category 1A or 1B combined with not being rapidly degradable and having high bioaccumulation; and/or
• .4 Mutagenicity Category 1A or 1B combined with not being rapidly degradable and having high bioaccumulation; and/or
• .5 Reproductive Toxicity Category 1A or 1B combined with not being rapidly degradable and having high bioaccumulation; and/or
• .6 Specific Target Organ Toxicity Repeated Exposure Category 1 combined with not being rapidly degradable and having high bioaccumulation; and/or
• .7 Solid bulk cargoes containing or consisting of synthetic polymers, rubber, plastics, or plastic feedstock pellets (this includes materials that are shredded, milled, chopped or macerated or similar materials).

Two features of this list shape every classification decision. First, the aquatic-toxicity triggers (.1 and .2) stand alone: acute Category 1 or chronic Category 1 or 2 makes the cargo HME on toxicity grounds with no further condition. Second, the human-health triggers (.3 through .6) are compound. A carcinogen is HME only when its carcinogenicity classification is paired with both “not rapidly degradable” and “high bioaccumulation.” A cargo can be a Category 1B carcinogen for human exposure and still fall outside the HME definition if it degrades quickly or does not bioaccumulate, because the criterion is about persistence in the marine environment, not about handling hazard to crew. The footnote to the Guidelines narrows the human-health triggers further: they apply to products classified for those endpoints “for oral and dermal hazards or without specification of the exposure route in the hazard statement,” which screens out inhalation-only classifications that have no bearing on what happens when the residue enters seawater.

The seventh criterion is the plastics rule, and it has no toxicity gate at all. A cargo “containing or consisting of synthetic polymers, rubber, plastics, or plastic feedstock pellets” is HME regardless of whether it shows any aquatic toxicity. This is the precautionary plastics-pollution provision, and it explicitly reaches shredded, milled, chopped, or macerated material, so recycled-plastic flake and rubber crumb are caught as cleanly as virgin pellets. The X-Press Pearl casualty off Sri Lanka in May 2021, which released on the order of 1,680 tonnes of plastic pellets, is the case study that confirmed the wisdom of treating pellet cargoes as HME without waiting for an ecotoxicity result; the X-Press Pearl disaster showed what a single pellet release does to a coastline.

A practical note on data gaps. The Guidelines permit provisional classification where reliable data for the four data-dependent criteria are not available, but provisional classification can rest only on acute aquatic toxicity, chronic aquatic toxicity, or the plastic/polymer/rubber content of the cargo. There is no provisional exception that bypasses aquatic toxicity: a shipper cannot declare a cargo non-HME on a “no data” basis if the cargo is in fact aquatically toxic. When MEPC.201(62) first entered force, IMO issued MEPC.1/Circ.791 asking competent authorities to accept provisional classifications during the first year of operation; that transitional indulgence has long since lapsed and full classification is now the expectation.

How the GHS endpoints map onto a bulk cargo

The HME criteria borrow the GHS language wholesale, so it helps to see what each endpoint measures. Acute Aquatic Toxicity Category 1 is the most stringent acute band, assigned when the lethal or effect concentration to fish, crustaceans, or algae sits at or below 1 mg/L. Chronic Aquatic Toxicity Category 1 or 2 captures longer-term harm at low concentrations, modified by whether the substance is rapidly degradable and by its measured No Observed Effect Concentration. These are the same numbers a chemical manufacturer already computes for a terrestrial safety data sheet, which is the point: Annex V reuses the existing chemistry rather than inventing a maritime test.

Bioaccumulation, in GHS terms, is judged on the bioconcentration factor or the octanol-water partition coefficient (log Kow), with a log Kow at or above 4 generally taken to indicate high bioaccumulation potential unless a measured bioconcentration factor says otherwise. Degradability is judged on whether the substance meets the GHS rapid-degradability criteria, typically through standard ready-biodegradability tests. For the human-health triggers, both conditions must hold together: a Category 1B mutagen that bioaccumulates but degrades quickly does not satisfy criterion .4, because “not rapidly degradable” is part of the same conjunctive test.

This mapping is why the determination belongs to the shipper rather than the ship. The data feeding the GHS endpoints come from the producer’s own toxicology and ecotoxicology files. A master has neither the laboratory nor the substance-specific dossier to classify a copper concentrate’s chronic aquatic toxicity from the deck. What the master can do, and must, is read the declaration, check it against the bulk cargo shipping name and the cargo’s known character, and challenge anything that looks wrong on its face: a copper concentrate declared non-HME, for instance, should draw a hard second look, because metal concentrates routinely trip the chronic aquatic toxicity criterion.

The shipper’s declaration under the IMSBC Code

The classification is worthless if it does not reach the ship, so Annex V hangs the duty on the document the bulk trade already uses. Section 3.4 of the 2012 Guidelines states that solid bulk cargoes “should be classified and declared by the shipper as to whether or not they are harmful to the marine environment,” and that “such declaration should be included in the information required in section 4.2 of the IMSBC Code.” For ships on international voyages the cross-reference runs to section 4.2.3 of the IMSBC Code; for ships not on international voyages the Administration may accept another declared means.

This is the same shipper’s cargo declaration that already carries the bulk cargo shipping name, the cargo group (Group A liquefiable, Group B chemical hazard, or Group C neither), the stowage and segregation requirements, and the moisture and transportable moisture limit data where they apply. The HME line is one more field on a form the master is already required to receive and check before loading. Resolution MEPC.277(70) made the declaration mandatory by amending the IMSBC Code so that the harmful-or-not-harmful statement is part of the required cargo information, not an optional add-on.

The burden split is deliberate. The shipper, who holds the cargo data, classifies and declares. The master, who holds the discharge decision, verifies the declaration is present, signed, and not obviously inconsistent with the cargo. A master is entitled to rely on a properly completed declaration absent evident error or fraud, and the chief mate’s Garbage Record Book Part II entry references that declaration as the source of the HME determination. Where the declaration is missing, the safe default is to treat the residue as HME and retain it; a ship cannot manufacture a non-HME route out of an absent declaration.

The commercial weight of the declaration is why charterparty practice has moved to lock it down. P&I clubs and BIMCO circulated recommended clauses after 2018 requiring charterers to provide, before loading, a shipper’s declaration stating whether the cargo is HME, included in the section 4.2 IMSBC information, with the cost of any consequent retention and reception falling where the clause allocates it. The point of the clause is that a late or wrong HME declaration can strand residue on board for an entire ballast leg, and the parties want the cost consequence settled in advance rather than litigated after a detention.

Why HME residues stay on board

The discharge consequence of an HME finding is stark and worth stating plainly: there is no at-sea route. Cargo residues that are HME, and the hold-wash water that contains them, may not be discharged into the sea inside or outside a special area, at any distance from land, at any speed. The only lawful disposal is delivery to a port reception facility. Section 3.3 of the 2012 Guidelines anticipates that such residues “may require special handling not normally provided by reception facilities” and tells ports receiving HME cargoes to provide adequate facilities, including for the wash water.

Contrast the non-HME case. A non-HME cargo residue not contained in wash water may be discharged outside special areas, more than 12 nautical miles from the nearest land, with the ship en route, under Regulation 4.1.3. Non-HME residues and cleaning agents contained in hold-wash water may be discharged subject to the conditions in Regulation 6.1.2, which the Guidelines’ Table 1 ties to the same more-than-12-nautical-mile, en-route, as-far-as-practicable standard. Within special areas the routes narrow sharply: discharge of cargo residues not in wash water is prohibited, and residues in wash water are permitted only under the conditioned Regulation 6.1.2.1 route. The full conditions sit in the dedicated Reg 4 and Reg 6 articles.

The operational gap between HME and non-HME is therefore the gap between a wash-and-discharge voyage and a wash-and-retain voyage. A Panamax that loads a non-HME grain cargo can wash holds at sea after the discharge port and run the wash water over the side at 12 nm. The same ship loaded with an HME metal concentrate must hold every litre of wash water for shore reception, which can mean carrying contaminated water through an entire ballast passage to a port equipped to take it. That single classification flips the whole hold-cleaning plan.

Why the absolute retention for HME, when non-HME residue can go to sea at 12 nm? Because the HME criteria pick out exactly the substances whose dispersion at sea causes the harm Annex V exists to prevent: acute and chronic aquatic toxicants that kill or impair marine life at low concentration, persistent bioaccumulative human-health hazards that climb the food chain, and plastics that never break down. The 12-nm dispersion logic that works for grain dust does not work for material engineered, by the criteria, to persist or to poison. Retention is the only control that holds.

The hold-cleaning and wash-water problem

Hold cleaning is where the HME regime stops being paperwork and becomes a deck operation. After a bulk parcel discharges, the holds carry residue as dust on the frames, sweepings in the corners, and stain on the coatings. Preparing the hold for the next cargo, especially a clean cargo grade after a dirty one, means sweeping, then washing, often with sea water and sometimes with cleaning agents, and the wash water that runs off carries the residue with it. The standards for that preparation sit in the cargo hold preparation standards and interact with hold ventilation and the cleaning technique each cargo grade demands.

For a non-HME cargo the sequence is manageable: sweep, collect the dry residue for the Regulation 4.1.3 route or for reception, wash at sea more than 12 nm out while en route, and log it. For an HME cargo the same sequence runs into a wall at the wash step. The wash water now contains HME residue, so it cannot go over the side. The ship must collect and retain it, which means a holding arrangement, a transfer plan, and a reception facility at a port that can take contaminated wash water. Few ships have dedicated wash-water tankage; the common improvisation is to retain wash water in a designated hold or in a ballast tank set aside for the purpose, with all the cross-contamination and subsequent cleaning that decision creates.

The cleaning agents add their own layer. Section 1.7.4 of the 2012 Guidelines treats cleaning agents and additives in hold-wash water as operational waste and therefore garbage, but allows their discharge if they are not harmful to the marine environment. Section 1.7.5 sets the test: the agent must not be a harmful substance under the relevant criteria, and must not contain any components known to be carcinogenic, mutagenic, or reprotoxic. Section 1.7.6 requires the ship’s record to hold producer evidence that the product meets the not-harmful criteria, with a dated and signed supplier statement adequate for the purpose. So even a non-HME cargo can produce a wash water that fails the discharge test if the crew used a harmful cleaning chemical; the agent’s own classification rides along with the residue’s.

Volume is the practical pressure. Hold-wash water from a single Panamax hold can run to tens of cubic meters per wash, and a full hold-cleaning campaign across five or seven holds generates a substantial parcel that, if HME-contaminated, has nowhere to go but a tank and then a facility. This is the operational reason the HME rule reshaped reception-facility demand at dry-bulk ports after 2018: cargoes once washed out at sea now arrive at the berth as a retained-water problem the terminal must be equipped to receive.

Worked classification: which common bulk cargoes are HME

The HME test resolves differently across the bulk trade, and a few worked cases show the pattern without inventing numbers. The determinations below are the cargo-by-cargo character recognized in the trade and the IMSBC schedules, applied to the section 3.2 criteria; the actual call on any specific parcel is the shipper’s declaration, not a generic label.

Grain cargoes such as wheat, maize, and soya beans are typically declared non-HME. The residue is broken grain, husk, and dust with no aquatic-toxicity or persistence trigger, so it runs on the Regulation 4.1.3 route and the hold-wash water can discharge at sea outside special areas. The exception is fumigant or pesticide treatment: a grain parcel carrying a biocide that itself classifies as a chronic aquatic toxicant can flip to HME on the chemistry of the treatment, not the grain.

Metal concentrates are the cargoes most likely to be HME. Copper concentrate, lead concentrate, zinc concentrate, and many mineral concentrates carry trace-metal loadings that meet the chronic aquatic toxicity criterion at Category 1 or 2, which makes them HME on criterion .2 with no further condition. The residue and its wash water must be retained for shore reception. By contrast, high-grade iron ore and bauxite are commonly non-HME because they lack the toxic trace-metal loading, though specific grades with elevated contaminants can be declared HME.

Fertilizers split on formulation. Urea and many potash grades are commonly non-HME; diammonium phosphate, phosphate rock, and ammonium-nitrate-based fertilizers can meet the chronic aquatic toxicity criterion depending on the blend and any biocide treatment. Fishmeal can carry feed-additive and antioxidant content that drives an HME call. Coal and petroleum coke are commonly non-HME but can trip the criteria where heavy-metal or polycyclic-aromatic content is elevated in a particular source. Clean inert cargoes such as salt, sand, and cement are non-HME.

The plastics criterion catches a small but growing trade. Plastic feedstock pellets, recycled-plastic flake, and rubber crumb are HME under criterion .7 regardless of any toxicity result, so their residues and wash water are retain-only. This is the criterion that the pellet trade has had to absorb since 2018, and it is the one with the least ambiguity: if the cargo is or contains polymer, the residue is HME.

E-waste and Category I

E-waste earned its own letter in 2018. Before Resolution MEPC.277(70), discarded electronics fell under the general operational-waste prohibition without a dedicated definition. The resolution defined e-waste and assigned it Category I in Garbage Record Book Part I. The definition reaches electrical and electronic equipment from normal ship operation, including all components and consumables at the time of discard, where the equipment contains material potentially hazardous to human health or the environment.

The discharge rule for Category I is the simplest in the Annex: prohibited everywhere, no exception, no distance, no special-area distinction. E-waste goes ashore, full stop. The reason is the same heavy-metal and persistent-contaminant logic that drives the HME plastics and toxicity criteria: discarded computers, monitors, mobile telephones, navigational electronics, batteries, and circuit boards carry lead, cadmium, mercury, brominated flame retardants, and other persistent toxicants that have no business in the sea. Shore disposal must run through a certified electronic-waste stream rather than mixed municipal landfill, to keep those metals out of the environment at the receiving end too.

The practical handling problem is volume creep. A modern ship cycles through a steady stream of electronics over its service life: bridge equipment upgrades, replaced personal devices, spent uninterruptible-power-supply batteries, failed monitors, obsolete handhelds. The Garbage Management Plan should designate a segregated, labelled store for e-waste, separate from the general operational-waste stream, because mixing e-waste into Category F operational waste both breaks the segregation the plan requires and risks the heavy-metal contamination of any ash if the mixed stream reaches an incinerator. E-waste is not incinerated; it is stored dry and landed.

Category I sits between Category H, fishing gear, and the Part II cargo-residue categories in the current Garbage Record Book numbering. That placement is worth noting because it is the source of a common error, addressed next: the category letters changed in 2018, and the old letters still circulate.

The category scheme: Part I A to I, Part II J and K

Resolution MEPC.277(70) gave the Garbage Record Book the two-part structure in use today, and pinned the category letters. Part I applies to all ships and runs Categories A through I. Part II applies to ships carrying solid bulk cargoes and runs Categories J and K. The full set:

Two clarifications keep this table honest. First, the distance figures and conditions are the at-sea defaults; the operative text is the Annex itself, not the table, and the per-regulation detail belongs in the Reg 4 and Reg 6 articles. Second, the letters are exactly as MEPC.277(70) fixed them: H is fishing gear, I is e-waste, J is non-HME cargo residue, K is HME cargo residue. There is no Category K in Part I and no fishing-gear category in Part II.

This is the spot to flag a numbering discrepancy in the existing corpus. The sibling Annex V garbage-discharge overview presents a category table in which H is HME cargo residue and J is non-HME cargo residue, with e-waste at I and no Category K. That mapping predates the MEPC.277(70) lettering or conflates an interim scheme; it does not match the Part I/Part II structure that has been in force since 1 March 2018. The Annex V hub and this article use the MEPC.277(70) lettering, which is the one printed in the current Garbage Record Book forms. Anyone working from the older table should re-map H to fishing gear, treat I as e-waste, and read J and K as the Part II cargo-residue pair.

Garbage Record Book Part II

Part II is the cargo-residue ledger, and it exists because Resolution MEPC.277(70) recognized that cargo-residue operations run on a different chain from general garbage. General garbage is logged by the officer of the watch as it is generated and disposed. Cargo residue is logged by the chief mate against the cargo plan and the shipper’s HME declaration, at the discharge port and during hold cleaning afterward. The two streams diverged enough to warrant separate books, and 1 March 2018 is the date the split took effect.

A Part II entry records the date and time of the operation; the ship’s position at the start; the cargo type and the HME or non-HME determination, cross-referenced to the IMSBC section 4.2 declaration; the estimated quantity of residue or wash water; the disposal route taken (discharge to sea outside special areas under Regulation 4.1.3, discharge to a reception facility, or retention on board for a later port); the hold or holds the residue came from; and the signature of the officer in charge, with the master countersigning the completed page. The entry’s job is to build an audit trail that ties the loaded cargo to its declaration, the discharge port, and the residue’s fate.

The recording discipline carries an evidentiary edge. A cargo-residue discharge that is not entered in Part II is presumed unauthorized, and the master’s defense that it was a lawful non-HME discharge fails on the absence of the contemporaneous record. The HME-or-not field is the load-bearing entry: it is the line a port state control officer reads to test whether a discharge logged at, say, 13 nm outside a special area was lawful (non-HME) or a violation (HME discharged at sea). Falsified Part II entries are criminal offenses under most flag-state legislation implementing MARPOL.

The Garbage Record Book, both parts, is retained on board for at least two years after the date of the last entry, and it travels with the ship on a change of flag. The general entry-keeping rules, the Garbage Management Plan that frames them, and the placard requirements all sit under Regulation 10 and are detailed in the Reg 10 placards, GMP, and record-keeping article; this article treats only the Part II cargo-residue dimension.

The Garbage Management Plan and the cargo-residue routine

Regulation 10 requires every ship of 100 GT and above, every ship certified to carry 15 or more persons, and every fixed and floating platform to carry a written Garbage Management Plan. The plan’s content follows the 2012 Guidelines for the Development of Garbage Management Plans (Resolution MEPC.220(63)) and the implementation Guidelines (MEPC.295(71)). For a bulk carrier the plan must carry a cargo-residue routine that turns the HME regime into a step-by-step deck procedure, because the regulation is only as good as the routine that executes it.

A working cargo-residue routine names, for each loaded cargo: the source of the HME determination (the section 4.2 IMSBC declaration), the planned disposal route for dry residue, the planned route for hold-wash water, the holding arrangement if retention is required, the reception facility at the intended port, and the Part II entry the chief mate will make. It also names the responsible officer (typically the chief mate, with the master retaining overall responsibility) and the exception procedure for when the plan breaks: a reception facility that refuses contaminated wash water, a declaration that arrives late, or a cargo whose HME status is challenged at loading.

The plan and the practice must match. A Garbage Management Plan that describes a wash-water retention tank the ship no longer has, or that references the pre-2018 single-part record book, is a finding at flag-state survey and at PSC inspection. Material discrepancies between the plan and the on-board reality are detained-grade under most regimes, because a plan that does not reflect the ship cannot be the document the crew actually works from.

The plan must be in the working language of the crew, and additionally in English, French, or Spanish where the working language is none of those, so that a chief mate can brief the deck crew in a language they understand while a port-state officer can read the same procedures. The cargo-residue routine is the part of the plan most likely to be tested by a bulk-trade PSC officer, because it is where the HME declaration, the discharge log, and the reception receipts have to line up.

Reception facilities and the cost of retention

The HME regime only works if there is somewhere to land the residue, which is why Regulation 8 obliges parties to MARPOL to provide adequate reception facilities at their ports and terminals for garbage, including cargo residues. Section 3.3 of the 2012 Guidelines presses the point for HME residues specifically: ports and terminals receiving HME cargoes “should have adequate reception facilities for all relevant residues, including when contained in washwater.” The facility obligation is the precondition that lets the at-sea prohibition stand without trapping ships with nowhere to discharge.

The cost falls on the retain-and-land voyages. A bulk carrier that loads an HME concentrate must budget reception of both the dry residue and the wash water at a port equipped to take contaminated water, which is a narrower set of ports than those that take general garbage. Reception charges for cargo residues and contaminated wash water run above the per-cubic-meter rates for ordinary garbage, and the scheduling of the offloading interacts with the next loading. The Baltic Sea HELCOM no-special-fee regime is the benchmark for removing the financial incentive to discharge at sea, but it does not extend to every region, and at many dry-bulk ports the reception of HME wash water is a negotiated, scheduled, and priced service rather than an included one.

The post-2018 shift in demand is the documented operational consequence. Cargoes once washed out at sea, certain metal concentrates and treated fertilizers above all, now arrive at the berth as a retained-water reception problem. Terminals handling those cargoes have had to build or contract for wash-water reception they did not previously need, and the bulk carrier trade has absorbed the retention cost into voyage planning. The regime did not reduce the residue; it redirected it from the sea to the shore, which was the intent.

Differentiation, special cases, and where the regimes meet

This article and its siblings divide the Annex V cargo-residue topic cleanly, and it is worth saying where the seams are. The garbage-discharge overview carries the whole-Annex regime at survey level: the general prohibition, the eight special areas, the per-category distance table, the Garbage Management Plan, and the record book at overview depth. The Reg 4 and Reg 6 articles carry the distance-by-distance conditions for the outside and within-special-area regimes. This article carries the cargo chemistry: the HME test, the declaration, the hold-wash water problem, Part II, and E-waste. The Annex V hub is the parent.

A few cross-regime cases sit at the edges. Liquid cargo residues are not Annex V at all: chemical-tank washings are Annex II noxious liquid substances and the residue of a packaged harmful substance is Annex III, governed by the packaged-dangerous-goods regime. Tank-cleaning slop from oil and chemical cargoes runs under Annex I or Annex II and the tank-cleaning and crude-oil-washing practice, not the Garbage Record Book. Annex V Part II is for solid bulk cargo residue; the more specific annex prevails where a residue could be argued into more than one.

The polar dimension tightens everything. In Antarctic waters and under the Polar Code and the Antarctic Special Area regime, garbage discharge is restricted well beyond the general Annex V baseline, and cargo residues face retention obligations stricter than the 12-nm route. A ship working a polar bulk trade should read the cargo-residue routine against the Polar Code Part II-A requirements, not the open-water defaults.

Enforcement closes the loop. PSC officers in the Paris MoU and Tokyo MoU regions check the Garbage Record Book Part II against the IMSBC declarations and the reception receipts, looking for the inconsistency that betrays an unlawful HME discharge: a residue logged as discharged at sea that the loading declaration shows was HME, a wash-water entry with no matching reception receipt, or a position that places the discharge inside a special area. The audit trail Part II builds is exactly what the inspection tests, and a clean trail is the difference between a closed inspection and a detention.

Limitations

This article is a reference to the cargo-residue and E-waste provisions of MARPOL Annex V, not a substitute for the instruments. The operative texts are the revised Annex V adopted by Resolution MEPC.201(62), the amendments in Resolution MEPC.277(70) in force from 1 March 2018, and the 2012 Guidelines in Resolution MEPC.219(63) as updated by the 2017 Guidelines in Resolution MEPC.295(71). Where this summary and those instruments differ, the instruments govern, and a compliance decision should work from the ship’s own Garbage Management Plan and the current consolidated Annex V text.

The HME determination is the shipper’s, made before loading from the cargo’s GHS classification and declared under section 4.2 of the IMSBC Code. This article describes how common cargoes tend to classify, but a generic label is not a determination: the parcel-specific declaration governs, and a master cannot reclassify a residue as non-HME at hold-cleaning time because it looks clean. Where the declaration is absent or doubtful, the safe default is retention.

The category lettering used here, Part I A through I and Part II J and K, is the MEPC.277(70) scheme in force since 1 March 2018 and printed in the current Garbage Record Book forms. Older references, including one sibling article in this corpus, carry a different mapping for the cargo-residue letters; the resolution lettering controls. Special-area reception-facility status, the regional reception charges, and the polar overlays change over time and should be confirmed against the current MEPC circulars and the port’s own provisions before a voyage relies on them.

See also

• MARPOL Annex V: Garbage from Ships parent hub
• MARPOL Annex V: garbage discharge rules overview regime
• Annex V Regulation 4: discharge outside special areas
• Annex V Regulation 6: discharge within special areas
• Annex V Regulation 10: placards, GMP, and record-keeping
• Annex V Regulation 7: exceptions
• IMSBC Code
• IMSBC Group A cargoes
• IMSBC Group B cargoes
• IMSBC Group C cargoes
• Cargo hold preparation standards
• Bulk carrier
• Polar Code
• MARPOL Convention
• Port State Control
• X-Press Pearl 2021 Sri Lanka disaster