What Is an IHM and Why Is It Required?
The IHM (Inventory of Hazardous Materials) is a ship-specific official inventory document that records the location, type and approximate quantity of hazardous materials present in a vessel’s structure, equipment and operational processes. In the industry it was formerly known as the “Green Passport.”
The purpose of the IHM can be summed up in a single sentence: throughout a ship’s operational life, and especially at the recycling stage, hazardous materials must be identified, tracked and safely managed without causing harm to human health or the environment.
The IHM requirement rests on two key pieces of international legislation:
1. EU Ship Recycling Regulation (EU SRR — EU No. 1257/2013): In force since 31 December 2020, the IHM is mandatory for all EU/EEA-flagged vessels as well as all third-country-flagged vessels of 500 GT and above calling at EU ports.
2. Hong Kong Convention (HKC): The IMO’s international convention on ship recycling entered into force on 26 June 2025, following ratification by 24 contracting states. As of that date, the IHM ceased to be an EU-specific requirement and became a globally binding obligation. The entry into force of the Hong Kong Convention established the first globally binding provisions on ship recycling, creating new obligations and significant liability risks for shipowners, shipyards, ship recycling companies and suppliers.
Which Vessels Require an IHM Certificate?
Existing ships within the scope of the Hong Kong Convention must obtain an ICIHM (International Certificate on the Inventory of Hazardous Materials) or a Statement of Compliance (SoC) at the first renewal survey; this process began on 26 June 2025 and must be completed by 26 June 2030.
In practical terms, the IHM requirement covers the following vessel categories:
EU/EEA-flagged vessels (under the EU SRR):
- Every EU/EEA/UK-flagged vessel of 500 GT and above, regardless of size or type
- The obligation to carry an Inventory Certificate (IC) has been in effect since 31 December 2020
Third-country-flagged vessels calling at EU ports (under the EU SRR):
- All vessels of 500 GT and above calling at EU ports must carry a Statement of Compliance (SoC) and, in addition, hold an IHM showing the location and approximate quantities of the hazardous materials present in the ship’s structure or equipment.
Under the Hong Kong Convention:
- The HKC entered into force on 26 June 2025, and existing ships must carry an approved and valid IHM Part I on board, together with a valid ICIHM, no later than 26 June 2030.
Newbuild vessels:
- New vessels for which the building contract is signed after the HKC’s entry into force must have an IHM in place at the delivery stage.
Important note: The world fleet comprises approximately 53,000 ships within the scope of the HKC. According to DNV estimates, with the full implementation of the EU SRR around 30,000 ships already carry an IHM Certificate or Statement of Compliance; however, approximately 23,000 ships will need to obtain a certified IHM in the coming years.
What Are the Differences Between IHM Part I, Part II and Part III?
The IHM document consists of three parts covering different stages of the ship’s life cycle:
IHM Part I — Hazardous Materials in Structure and Equipment
IHM Part I lists hazardous materials that form part of the ship’s structure or equipment, such as asbestos in bulkheads, lead in paints and harmful insulation.
This is the only part that carries a legal obligation, is certified, and must be actively maintained throughout the vessel’s operational life. It must be updated whenever new equipment or materials are installed.
Materials that must be recorded under EU SRR Annex I:
- Asbestos and asbestos-containing materials
- Ozone-depleting substances (ODS)
- Polychlorinated biphenyls (PCB)
- Perfluorooctane sulfonate (PFOS)
- Anti-fouling systems and compounds
Materials to be investigated “as far as practicable” under EU SRR Annex II:
- Lead and lead compounds
- Mercury and mercury compounds
- Cadmium and cadmium compounds
- Organotin compounds
- Radioactive sources
- Electronic components containing certain heavy metals
IHM Part II — Operationally Generated Wastes
IHM Part II lists potentially hazardous wastes generated during the ship’s operation, such as oil residues, chemical residues and machinery sludge.
This part is prepared only when the ship is sent for recycling. It is not required during normal operational periods.
IHM Part III — Hazardous Stores Held on Board
IHM Part III covers items stored on board, such as spare parts, batteries, cleaning products and potentially harmful paints.
Together with Part II, it is prepared before the ship’s final voyage to recycling. IHM Parts II and III may be prepared by the crew or by a hazardous materials (hazmat) expert.
How Is an IHM Prepared?
The IHM preparation process differs depending on whether the ship is a newbuild or an existing vessel.
For Newbuild Vessels
For newbuild vessels, IHM Part I is prepared during the design and construction stages using Material Declarations (MD) and Suppliers’ Declarations of Conformity (SDoC) provided by suppliers. These documents certify whether each piece of machinery, equipment, material and coating installed on the ship contains hazardous materials.
For Existing Vessels
For existing vessels, the process consists of five key steps:
1. Document Analysis (Desktop Study) Ship’s plans (general arrangement, machinery, equipment lists), build-date information and existing maintenance records are reviewed to identify areas and equipment that may contain hazardous materials. At this stage a Visual/Sampling Check Plan (VSCP) is prepared.
2. Vessel Attendance and Visual Survey An accredited HazMat expert boards the vessel to carry out the survey; the locations identified in the VSCP are visually inspected. Components that may contain hazardous materials are catalogued.
3. Sampling Samples are taken from materials that lack documentation or carry uncertainty. On an industry average, approximately 50 to 170 samples are collected per vessel; this figure varies considerably depending on the ship’s age and size.
4. Laboratory Analysis The samples taken are analysed in laboratories holding ISO 17025 accreditation. The presence and concentration of asbestos, PCB, heavy metals, ODS and other hazardous materials are determined.
5. Report Preparation, Approval and Certification The HazMat expert prepares the IHM report containing all findings. The report is submitted to the classification society or flag state administration, and on the basis of the approved document a Statement of Compliance (SoC) or International Certificate on the IHM (ICIHM) is issued.
How Many Days Does It Take to Prepare an IHM?
The time required to prepare an IHM varies depending on many factors, but a general framework can be outlined as follows:
| Stage | Duration |
|---|---|
| Document analysis and VSCP preparation | 3–10 working days |
| Vessel attendance and survey | 1–5 days (depending on ship size) |
| Sampling and shipment | 1–3 days |
| Laboratory analysis | 5–15 working days |
| Reporting and classification approval | 5–15 working days |
| Total estimated duration | 4–12 weeks |
For a large tanker or container ship the process may extend up to 3 months. On old and very large vessels, insufficient documentation increases the number of samples required, which in turn lengthens the laboratory stage.
For this reason, it is critical that shipowners start the IHM process early. For vessels facing a PSC inspection or calling at an EU port, the operational consequences of missing documentation can be extremely severe.
Who Can Prepare an IHM?
IHM reports are prepared by hazmat (hazardous materials) experts on the basis of document analysis and an on-site investigation involving sampling and visual checks.
The requirements that a competent IHM preparation firm should meet include:
-
Classification society approval: approved service supplier status from an IACS classification society (DNV, Lloyd’s Register, Bureau Veritas, ABS, RINA, ClassNK, KR, etc.) for IHM preparation and sampling/testing services. ISO 17020 certification or an equivalent standard, and ISO 17025 certification of the laboratories used, are further quality assurances to look for.
-
Individual HazMat expert competence: possessing the training, qualification and knowledge required to conduct hazardous materials surveys.
The shipowner is responsible for the preparation of IHM Part I. Appointing a specialist IHM firm is considered to fulfil the due diligence obligation needed to meet the relevant requirements of the Hong Kong Convention.
Important: the firm preparing the IHM must be independent of the classification society that surveys the ship and issues the certificate. This independence is essential for the impartiality and acceptability of the report.
Is an IHM Mandatory for Vessels Calling at EU Ports?
Absolutely yes. The EU Ship Recycling Regulation requires all EU-flagged vessels, as well as non-EU-flagged vessels calling at any port or anchorage of an EU member state, to carry an IHM on board as of 31 December 2020.
This requirement is reinforced by an enforcement mechanism: EU member states apply PSC provisions to verify that vessels—whether EU/EEA-flagged or not—carry a valid IHM Certificate/Statement of Compliance or a Ready for Recycling Certificate (RfRC).
A detailed inspection may be carried out on vessels that do not carry a valid IHM Certificate/Statement of Compliance or RfRC, or where there are clear grounds to believe that the condition of the ship does not correspond to the particulars of the certificate.
A new dimension added to the picture in 2026: EU Directive 2024/1203 provides for criminal liability for serious environmental crimes, and member states must transpose this directive into national law by 21 May 2026. The directive covers criminal sanctions for ship recycling violations, illegal shipments of hazardous waste and IHM non-compliance. Maritime operators may face criminal prosecution for the most serious violations.
Are an IHM Certificate and an IHM Report the Same Thing?
Although the two concepts are related, they are different documents:
IHM Report (HazMat Survey Report): the technical document produced as a result of the on-board survey and laboratory analyses carried out by the HazMat expert. It contains the location, type and quantity of hazardous materials; it is also the IHM Part I document itself.
IHM Certificate / Statement of Compliance: the official certificate issued by the classification society or flag state administration after it has reviewed and approved the IHM report. It comes in several forms:
| Document | Scope | Issued by |
|---|---|---|
| ICIHM (International Certificate on IHM) | Vessels within the scope of the HKC | Classification society / flag state |
| SoC (Statement of Compliance) | Third-country-flagged vessels under the EU SRR | Classification society / flag state |
| IC (Inventory Certificate) | EU/EEA-flagged vessels | Classification society / flag state |
| RfRC (Ready for Recycling Certificate) | EU-flagged vessels going for recycling | Classification society |
In short: the IHM report is a technical document; the IHM certificate is the legal document in which that report is approved by the competent authority. The document checked during PSC inspection, and required to be carried on board, is the certificate; the report is the basis on which the certificate rests.
How Does the Sampling Process for an IHM Work?
Sampling is the most technically critical stage of the IHM preparation process. The procedure works as follows:
1. Determining locations according to the VSCP The Visual/Sampling Check Plan (VSCP) prepared during the document analysis stage predefines the components and locations to be sampled. This plan ensures that the survey is ship-specific.
2. Sample types
- Solid material samples (paint, insulation, gaskets, flooring, etc.)
- Liquid samples (oil, coolant, hydraulic fluid, etc.)
- Surface wipe samples (for contamination screening)
3. Packaging and chain of custody Samples are placed in standard-compliant containers, labelled and sent to the laboratory under a strict chain-of-custody protocol. The chain-of-custody document records who each sample was taken from and handed to, and when and how it was transported.
4. Analysis methods The analysis methods used vary according to the applicable regulations, but the most common are:
- XRF (X-Ray Fluorescence): rapid field screening for heavy metal detection
- PLM (Polarised Light Microscopy): the gold-standard method for asbestos detection
- TEM (Transmission Electron Microscopy): detection of very low levels of asbestos
- GC-MS: detection of organic compounds (PCB, PFOS, etc.)
Threshold values: the regulations set threshold concentrations for each material. Findings above these values must be recorded in the IHM. For example, resolution MEPC.379(80), which entered into force on 1 July 2023, established current threshold values for anti-fouling systems and various hazardous materials.
How Is Asbestos Detected During the IHM Process?
Asbestos is the most critical hazardous material requiring special attention in the IHM process. There are several important reasons for this:
Historical prevalence: owing to its thermal-insulation and fire-resistance properties, asbestos was for many years widely used in shipbuilding for engine-room bulkheads, doors, pipe insulation and gasket materials.
Legal framework:
- Since 1 January 2011, asbestos-containing materials have been prohibited on ships, including for repair and replacement (SOLAS Regulation II-1/3-5). Asbestos has been banned on new ships since 1 July 2002.
- If asbestos is detected on a ship, the shipowner must immediately notify the flag state. The flag state may decide either to issue an exemption certificate or to grant the owner time for removal under the framework of MSC/Circ.1045.
Detection process:
- The document analysis reviews records relating to the build period and the materials used (with intensified screening particularly on vessels built before 2002)
- Samples are taken from suspect locations for PLM or TEM analysis
- In an accredited laboratory, the type of asbestos (chrysotile, crocidolite, amosite, etc.) and its concentration are determined
Asbestos Management Plan (AMP): Where asbestos cannot be removed immediately, an Asbestos Management Plan (AMP) documenting the location, condition and management procedures must be kept on board. Condition monitoring must be carried out regularly. Removal work must be performed by qualified experts following strict containment and disposal procedures.
What Is the Importance of the IHM Report in the Sale of a Ship?
The IHM increasingly plays a decisive role in ship sale-and-purchase transactions. This importance manifests itself in several distinct dimensions:
In terms of due diligence: The buyer wants to know in advance the hazardous-material burden of the vessel it is considering acquiring. A current IHM provides this information in a transparent and documented form. A missing or outdated IHM becomes a significant bargaining lever for the buyer in price negotiations.
In terms of financing and insurance: Some P&I clubs and marine insurers will not provide comprehensive insurance cover for vessels of a certain age and category without an IHM. Likewise, in ship financing the presence of an IHM has a positive effect on collateral value.
In terms of legal liability: Damage giving rise to compensation is most likely to relate to ship detention costs and fines paid to member states that shipowners and shipyards incur as a result of missing or inaccurate hazardous-material information. For this reason, a selling owner going to sale with a current IHM protects both the buyer and itself against potential future legal claims.
In terms of operational compliance: If the acquired vessel is going to call at EU ports, the absence of a valid IHM at the moment of handover creates an urgent compliance obligation for the new owner.
What Risks Await Ships Without an IHM?
Shipowners who fail to meet the IHM requirement face serious risks on multiple fronts:
1. PSC Detention and Port Delays
The port authorities of EU/EEA member states are empowered to check whether vessels carry a valid IHM Certificate, Statement of Compliance or Ready for Recycling Certificate. A vessel without an IHM, or with a serious discrepancy identified in its documentation, may be detained; detention triggers a cascade of rapidly rising charter breaches, agency and port costs.
2. Criminal Sanctions (From 2026)
EU Directive 2024/1203 provides for criminal liability for serious environmental crimes, including IHM non-compliance, and must be transposed into national law by member states by 21 May 2026. From that date, managers may face personal criminal liability for the most serious violations.
3. Rejection by Ship Recycling Facilities
Authorised ship recycling facilities within the scope of the Hong Kong Convention no longer accept vessels without an IHM. This leads to unexpected additional costs and delays for a vessel ready for recycling.
4. Insurance Disputes
In the event of an occupational accident or environmental pollution incident caused by hazardous materials, the insurer may refuse or limit damage compensation in the absence of an IHM.
5. Loss of Market Value
A second-hand vessel that does not carry a valid IHM suffers a serious loss of value in the eyes of buyers. It creates a significant disadvantage in both sale-price and charter negotiations.
How Is the Cost of an IHM Report Calculated?
The cost of preparing an IHM varies considerably from ship to ship. The main factors that determine the cost are:
The ship’s age: on older vessels, insufficient documentation means more samples are taken, which increases laboratory costs.
The ship’s size and type: on a large tanker or container ship, survey duration and the number of samples are far greater than on a small dry-cargo vessel.
Number of samples: on an industry average, 50 to 170 samples are taken per vessel. Each sample entails shipment, analysis and reporting costs.
Location of the specialist firm and travel costs: the expert must travel to the port where the vessel is located. Remote locations mean additional costs.
Classification society fees: the classification society’s tariff fees for approval and certificate issuance must also be taken into account.
IHM maintenance cost: once a certified IHM has been obtained, updates are mandatory whenever new equipment is installed. This ongoing maintenance cost must also be included in the budget.
As a general rule, comparing the cost of preparing an IHM against the daily port + charter costs of a possible PSC detention, or the opportunity cost of a ship sale process that has to be renegotiated due to a missing IHM, provides sufficient perspective.
What Is the Role of the IHM in Ship Recycling?
In the ship recycling process, the IHM is the fundamental document for safe, lawful and environmentally responsible recycling.
IHM Part I: informs the recycling facility which hazardous materials are located where and in what quantities. Without this information, the yard cannot allow workers to hot-cut a section containing asbestos, nor safely dispose of electrical switchboards containing PCB.
IHM Parts II and III (before the final voyage): these inventory the operational wastes and stored materials on board, providing a complete hazard map at the moment of delivery to the recycling facility.
Ready for Recycling Certificate (RfRC) under the EU SRR: All EU/EEA-flagged vessels intended to be sent to facilities on the European List must hold an RfRC and may only be sent to facilities on the European List of Ship Recycling Facilities.
Final-voyage requirements under the HKC: As of 26 June 2025, vessels going to an authorised ship recycling facility within the scope of the HKC must be equipped with the following documents:
- Approved and valid IHM Parts I, II and III
- A ship-specific recycling plan prepared by the ship recycling facility
- A ready for recycling certificate on board
From the Aliağa perspective: The 15th edition of the EU’s latest list of approved ship recycling facilities was adopted on 27 February 2026, and the list covers 41 authorised facilities in Europe and the United States, including Turkey. For the Aliağa yards on the list, IHM compliance is critical to safeguarding both national legislation and this international status.
How Are IHM Renewal and Updating Carried Out?
The process does not end once the IHM certificate is obtained; the IHM is a living, continually updated document.
Periodic Renewal (Renewal Survey)
The IHM certificate is subject to renewal survey in line with the other mandatory IMO certificates. According to DNV, for vessels with an existing EU SRR IHM Certificate or Statement of Compliance, the ICIHM application must be carried out at a renewal survey between 26 June 2025 and 25 June 2030, combined with the main class renewal survey.
Continuous Updating (Maintenance)
IHM Part I must be properly maintained and updated throughout the vessel’s operational life, reflecting new installations containing hazardous materials. The IMO guidelines (Res. MEPC.379(80) — Paragraph 5.2.1) require shipowners to appoint a person responsible for keeping the inventory up to date.
The update process is triggered in the following situations:
- Installation of new equipment or systems (especially paint, insulation, refrigeration and electrical equipment)
- Replacement of an existing component containing hazardous materials
- A decision to send the ship for recycling (preparation of IHM Parts II and III)
For every installation that triggers an update, a Material Declaration (MD) and Supplier’s Declaration of Conformity (SDoC) must be requested from the supplier and added to the IHM file.
Looking for a Reliable Partner for IHM Services?
At Orionis Shipping, our experienced expert team supports you in IHM preparation, document analysis, sampling coordination, management of the classification society approval process and IHM maintenance services. With the entry into force of the Hong Kong Convention, we help you complete your IHM documentation—fully compliant with both international inspections and EU SRR requirements—through the most efficient process possible.
Contact us for detailed information about IHM services and the process.
This content is for informational purposes only. For your legal obligations, rely on the current legislation of the IMO, classification societies such as DNV, Lloyd’s Register and Bureau Veritas, and your flag state administration, together with the advice of accredited experts.
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