What Does Non-HME Mean Under MARPOL Annex V?

For a complete explanation, read our MARPOL compliant boat cleaner guide.

The term “Non-HME” is increasingly used within the marine sector, particularly in relation to cleaning products, discharge criteria and regulatory compliance. However, there remains significant misunderstanding about what it actually means and how it applies in practice.

Understanding Non-HME is essential for vessel operators, marinas, boatyards and procurement managers seeking to align operations with MARPOL Annex V requirements.

What Is HME?

HME stands for Harmful to the Marine Environment.

Under MARPOL Annex V, certain substances are classified as harmful based on their toxicity, persistence and potential to cause long-term damage to marine ecosystems. Products that meet defined hazard thresholds - particularly acute or chronic aquatic toxicity classifications - may fall within this category.

These classifications are typically derived from Globally Harmonised System (GHS) criteria and CLP hazard statements such as:

• H400 – Very toxic to aquatic life

• H410 – Very toxic to aquatic life with long lasting effects

• H411 – Toxic to aquatic life with long lasting effects

Where a substance meets defined criteria, it may be considered HME for the purposes of discharge restrictions.

What Does Non-HME Mean?

A product classified as Non-HME does not meet the threshold criteria for being harmful to the marine environment under MARPOL Annex V discharge standards.

In practical terms, this means:

• The formulation does not carry defined aquatic hazard classifications at regulatory thresholds

• The product does not meet criteria that would trigger classification as harmful under Annex V

• Discharge risk assessment does not identify the product as environmentally hazardous under MARPOL definitions

It is important to note that Non-HME does not mean “zero impact” or “harmless in all circumstances”. Rather, it means the product does not meet internationally defined hazard thresholds that would restrict discharge under MARPOL Annex V.

Why Non-HME Classification Matters

Many cleaning products marketed to the marine sector carry aquatic hazard classifications. While suitable for land-based industrial use, their routine discharge in enclosed or semi-enclosed marina environments can present cumulative ecological risk.

For operators seeking to demonstrate environmental due diligence, understanding whether a product is HME or Non-HME is critical.

Non-HME classification supports:

• Improved audit readiness

• Reduced regulatory exposure

• Alignment with international discharge criteria

• Clearer environmental reporting

As environmental scrutiny increases across the leisure and commercial marine sectors, documentation clarity is becoming as important as product performance.

Common Misunderstandings

There are several misconceptions frequently encountered:

“Biodegradable means Non-HME.”

Not necessarily. A product may be biodegradable yet still carry aquatic toxicity classifications.

“If it’s sold in a chandlery, it must be compliant.”

Retail availability does not automatically equate to regulatory alignment.

“MARPOL only applies offshore.”

While Annex V was developed for shipborne waste, its principles are increasingly referenced in marina and operational policy frameworks.

Clarity in terminology is therefore essential.

The Importance of Documentation

Non-HME claims should be supported by transparent documentation, including:

• Safety Data Sheets

• Hazard classification review

• Ingredient disclosure at regulatory level

• Formal MARPOL alignment statements

Without this evidence, claims of compliance are difficult to substantiate.

Conclusion

Non-HME under MARPOL Annex V refers to products that do not meet defined hazard thresholds for being harmful to the marine environment. It is a technical classification rooted in regulatory criteria, not a marketing label.

As awareness of environmental responsibility grows across the marine industry, understanding this distinction is fundamental for informed product selection and operational compliance.