A Garbage Record Book is the log every covered vessel must keep to prove it handled waste in line with MARPOL Annex V, and the garbage record book requirements cover who has to maintain one, what each entry must contain, how it must be signed, and how long it must be retained. Ships of 100 gross tonnage and above, ships certified to carry 15 or more people, and fixed or floating platforms engaged in seabed exploration or resource extraction all fall within the rule. Getting it wrong invites detention at port, civil fines up to $25,000 per violation under U.S. law, and, for knowing violations, criminal prosecution.
Which Vessels Have to Keep One
MARPOL Annex V Regulation 10 sets the threshold. Three categories must maintain the book:
- Ships of 100 gross tonnage and above traveling to ports or offshore terminals under the jurisdiction of another MARPOL party.
- Ships certified to carry 15 or more persons on international voyages, regardless of tonnage.
- Fixed or floating platforms used for seabed exploration or mineral resource extraction.
Smaller vessels are still bound by MARPOL’s discharge restrictions but are not required to maintain the formal log. Covered ships obtain an official book through their flag state administration or an authorized nautical publisher; the books come pre-formatted with fields for each entry type.
What Each Entry Must Include
Every entry has to capture enough detail that an inspector can reconstruct exactly what happened and where. The required data points shift depending on whether the waste was discharged at sea, incinerated on board, or offloaded ashore.
For a discharge at sea, the entry records the date and time, the ship’s position in latitude and longitude, the MARPOL category letter, and the estimated amount in cubic meters. Cargo residue discharges at sea also require the ship’s position at both the start and stop of the operation, since these can stretch across a distance. Incineration entries follow the same pattern: date, time, position at start and stop, categories incinerated, and estimated volume for each category. When garbage goes to a port reception facility or is transferred to another ship, the entry records the port name or the receiving vessel’s name in place of a geographic position.
Volume estimates are inherently imprecise. The IMO acknowledges that accuracy varies, especially for continuously processed waste such as food scraps run through a grinder. Inspectors expect the estimate to be reasonable and consistent with what is actually visible in the ship’s waste storage.
Garbage Categories You’ll Enter
The book is split into two parts. Part I covers operational garbage; Part II covers cargo residues. Every entry uses a letter code.
Part I categories:
- A — Plastics: synthetic ropes, fishing nets, plastic bags, and any plastic product. Discharge at sea is banned outright.
- B — Food waste: spoiled provisions, scraps, and cooking byproducts.
- C — Domestic waste: paper, rags, glass, metal, bottles, and similar items from normal ship operations.
- D — Cooking oil: used frying oil and other cooking fats.
- E — Incinerator ashes: residue from onboard incineration, excluding ash from burned plastics, which falls under Category A.
- F — Operational waste: materials from cargo handling, maintenance, and deck operations.
- G — Animal carcasses: dead livestock or other animals carried on board.
- H — Fishing gear: nets, lines, traps, and other commercial fishing equipment.
- I — E-waste: electronic and electrical equipment waste.
Part II categories:
- J — Cargo residues not harmful to the marine environment: remnants of commercial goods that cannot be recovered during normal unloading.
- K — Cargo residues harmful to the marine environment: remnants classified as posing an environmental risk, with the strictest handling requirements.
Categorizing correctly matters. If a mixed batch contains items from more than one category, the strictest discharge rule among those categories applies to the entire batch.
Signing, Retention, and Inspection
Recording the data is only half the job. Each entry must be signed by the officer who supervised the discharge or incineration, at the time it happens. Backdating is a red flag inspectors are trained to spot. At the end of each completed page, the ship’s master adds a separate signature confirming oversight of the recorded operations.1International Maritime Organization. International Convention for the Prevention of Pollution from Ships (MARPOL)
The completed book has to stay on board for at least two years after the date of the last entry, along with any receipts from port reception facilities. During that window, Port State Control officers can demand to see it at any time. Inspectors routinely cross-check the log against the ship’s physical waste storage. If the log shows regular ground food waste discharges but the galley has no working comminuter, or if recorded volumes do not match what is visible in the garbage hold, the ship has a problem.
A vessel can be detained for inadequate or missing records. Detention means the ship sits in port until the deficiency is fixed, which translates directly into lost revenue for the operator. Serious discrepancies can trigger deeper investigations and criminal referrals.
Electronic Garbage Record Books
Paper is not the only option anymore. MARPOL permits electronic Garbage Record Books when the system has been approved by the ship’s flag state administration.2International Maritime Organization. Guidelines for the Implementation of MARPOL Annex V – Supplement
Approval is not a rubber stamp. The IMO’s guidelines under Resolution MEPC.312(74) set detailed technical requirements any electronic system must satisfy:
- Role-based access control with a unique login and password for every user. No shared accounts.
- Audit logging that records who made or changed every entry, tied to a unique identifier.
- Tamper protection so that once saved, entries cannot be deleted or altered without the change being recorded automatically. Both the original entry and any amendment remain visible.
- Master verification through an additional authentication factor, not just the same login credentials.
- Status tracking, with each entry carrying a status such as “pending” or “verified.” Amending a verified entry automatically reverts its status to pending.
- Automatic backup to offline storage every time entries change. Offline backups must be encrypted and stored in a read-only format.
The electronic system must be part of the ship’s IT business continuity plan, with documented recovery procedures for system failure. Offline records should be digitally signed by the master in PDF or an equivalent format. In electronic systems, entries are grouped as a “group of electronic entries” instead of by physical page, and the master signs off on each group.
Logging Accidental Loss of Fishing Gear
Not every piece of garbage in the ocean is intentionally discharged. MARPOL Annex V includes an exception for the accidental loss of synthetic fishing nets or synthetic material during net repairs, provided the crew took all reasonable precautions. The exception does not excuse the crew from logging the event. The loss still has to be recorded with the date, time, position, description of the lost gear, and an estimated amount.
The distinction between accidental loss and deliberate abandonment matters during an investigation. Abandoned fishing gear is a serious pollution violation; gear lost despite precautions is an exception to the discharge rules. A prompt, specific book entry is the primary evidence that the loss was genuinely accidental. Ships that fail to log the event lose the benefit of the exception.
What Noncompliance Costs in U.S. Waters
In the United States, MARPOL is enforced through the Act to Prevent Pollution from Ships (APPS), codified at 33 U.S.C. § 1901 and following. The U.S. Coast Guard conducts inspections, and the penalties are substantial.
Civil penalties reach up to $25,000 per violation for breaching any MARPOL requirement, including incomplete or missing Garbage Record Book entries. Each day of a continuing violation counts as a separate offense, so costs escalate quickly. A separate provision targets fraud: making a false or fictitious entry in any required record carries a civil penalty of up to $5,000 per false statement.4Office of the Law Revision Counsel. 33 USC 1908 – Penalties for Violations
Criminal exposure is more serious. A person who knowingly violates MARPOL or its implementing regulations commits a class D felony under federal law,4Office of the Law Revision Counsel. 33 USC 1908 – Penalties for Violations which carries a maximum sentence of up to 10 years in prison.5Office of the Law Revision Counsel. 18 USC 3559 – Sentencing Classification of Offenses “Knowingly” is the key word. Unintentional errors typically stay in civil territory, but deliberately falsifying the log, hiding waste, or ordering illegal discharges can put individuals in prison.
The Management Plan and Placards Sit Alongside the Book
The Garbage Record Book does not stand alone, and inspectors will ask for two related items during any serious check. Every ship of 100 gross tonnage and above, every ship certified to carry 15 or more people, and every fixed or floating platform must carry a Garbage Management Plan. This written document lays out the ship’s procedures for collecting, storing, processing, and disposing of waste and designates the person or persons responsible for carrying out the plan.
Every ship of 12 meters or more in length must also display placards notifying crew and passengers of the discharge requirements. The placards must be written in the crew’s working language and, for ships on international voyages, in English, French, or Spanish as well. The management plan sets the procedures, the placards communicate the rules to everyone on board, and the record book proves the rules were followed.