Do I need to notify Rijkswaterstaat when I receive hazardous and noxious substances transported by sea?

Businesses that receive bulk cargoes of hazardous and noxious substances (HNS) that have been carried by sea must notify this to Rijkswaterstaat. A threshold of 15,000 tonnes for received and imported cargoes applies.

Notification requirement for receipt of hazardous substances

The Netherlands aims to ratify the HNS Convention in 2024. This convention establishes an international fund for compensation to be paid in the event of accidents at sea involving hazardous substances. For such a fund to work, it is necessary to know the volume of HNS transported by sea.

That is why there is a notification requirement for businesses that receive bulk volumes of these substances by sea. There is a list of notifiable substances on the website of the HNS Convention.

Minimum tonnage for reporting HNS

Businesses that receive at least 15,000 tonnes of hazardous or noxious substances (HNS) by sea are subject to a notification requirement. Both liquid and solid HNS fall under this rule.

There are 2 exceptions:

  • persistent oil is notifiable from 150,000 tonnes;
  • any amount of LNG, no matter how small, is notifiable.

No costs during test phase

Notification by receivers of shipments of hazardous or noxious substances (HNS) transported by sea is currently still being tested. In this testing phase:

  • businesses can practise notifying HNS;
  • the volume of HNS being transported by sea will become clear;
  • receivers can get used to the notification system for bulk shipments of HNS.

The HNS Convention will enter into force no earlier than 18 months after 12 countries have ratified it. Receivers of HNS will then pay a contribution into the international compensation fund.

Annual stocktake

Businesses have to compile an overview of the hazardous and noxious substances that they received and imported in the previous calendar year, and send it to no later than 15 March each year.

Receivers should report shipments of HNS transported by sea using the correct notification form.

See also the explanation on using the HNS notification form.