Inventory of Hazardous Materials (IHM): EU Ship Recycling Regulation Guide

The Inventory of Hazardous Materials (IHM) is one of those regulatory requirements that catches yacht operators off guard. Unlike MARPOL plans or ISM documentation that have been part of the compliance landscape for decades, the IHM obligation entered the superyacht world relatively recently and is still poorly understood across the fleet. The regulatory picture involves two parallel instruments — the EU Ship Recycling Regulation and the IMO Hong Kong Convention — that overlap but are not identical. This guide explains what is required, when it applies, how to build and maintain an IHM, and where vessels most commonly fall short.

The Regulatory Framework

EU Regulation 1257/2013 — Ship Recycling Regulation

The EU Ship Recycling Regulation (SRR) is the primary driver of IHM requirements for vessels calling at EU ports. It entered into force on 30 December 2013, with IHM obligations applying from 31 December 2020. The regulation requires:

All EU-flagged vessels of 500 GT and above must have an IHM on board, verified by the flag state or a recognised organisation (class society), with a corresponding certificate (the Inventory Certificate or Statement of Compliance).
All non-EU flagged vessels of 500 GT and above calling at EU ports must have an IHM Part I on board and carry a Statement of Compliance issued by the flag state or a recognised organisation.
The IHM must be maintained and updated throughout the vessel’s operational life.

Yacht Applicability: The 500 GT threshold means many superyachts above approximately 45-50 metres LOA are caught by this regulation. If your vessel is 500 GT or above and trades in EU waters — which virtually all Med-based yachts do — you need an IHM. The regulation does not distinguish between commercial vessels and yachts.

IMO Hong Kong Convention

The Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships was adopted in 2009 and entered into force on 26 June 2025, following ratification by Bangladesh and Liberia. The Convention requires:

Ships of 500 GT and above to maintain an IHM
The IHM to be verified and certified by the flag state
The IHM to be maintained throughout the ship’s operational life
Existing ships to have an IHM prepared no later than five years after the Convention’s entry into force (by June 2030 for existing ships)

IMO Resolution MEPC.379(80) — 2023 Guidelines for the IHM

Adopted in July 2023, MEPC.379(80) provides updated guidelines for the development, maintenance, and verification of the IHM. It replaces the earlier guidelines in MEPC.269(68) and aligns the IHM requirements under the Hong Kong Convention with the EU SRR to the extent possible. Key provisions include:

Standardised format for IHM Part I, Part II, and Part III
Guidance on sampling and analysis methodology
Maintenance procedures for keeping the IHM current
Verification and certification requirements

The most recent update, MEPC.405(83) adopted in April 2025, addresses cybutryne threshold amendments in the IHM guidelines.

IHM Structure: Parts I, II, and III

The IHM consists of three parts, each serving a distinct purpose:

Part	Title	Content	When Required
Part I	Materials contained in ship structure and equipment	Hazardous materials present on board, with locations and approximate quantities	From delivery (new ships) or by compliance date (existing ships). Must be maintained throughout operational life.
Part II	Operationally generated wastes	Waste materials generated during the ship’s normal operation (e.g., oily sludge, sewage, garbage)	Prepared prior to recycling
Part III	Stores	Stores and consumables on board that may contain hazardous substances (e.g., paints, cleaning chemicals, oils)	Prepared prior to recycling

For operational vessels, the immediate obligation is Part I only. Parts II and III are developed when the vessel enters a ship recycling facility, though preparing a preliminary Part II/III is considered good practice and aids in waste management planning.

What Materials Are Listed in Part I?

Part I must identify the following hazardous materials if present in the vessel’s structure, systems, or equipment:

Material	Common Locations on Superyachts
Asbestos	Gaskets, insulation (older vessels), brake linings, fire blankets, pipe lagging
Polychlorinated biphenyls (PCBs)	Older transformers, capacitors, cable insulation, some sealants
Ozone-depleting substances	Refrigerants (R-22, R-141b), halon fire suppression (older vessels), foam insulation blown with ODS
Anti-fouling compounds (TBT)	Hull coatings on vessels built before 2008 AFS Convention
Cadmium and cadmium compounds	Batteries (NiCd), brazing alloys, some coatings
Hexavalent chromium compounds	Primer coatings, corrosion inhibitors
Lead and lead compounds	Paints, batteries, cable sheathing, solder
Mercury	Thermometers, fluorescent tubes, some switches and relays
Polybrominated biphenyls/diphenyl ethers (PBB/PBDE)	Flame retardants in textiles, foam, electronic enclosures
Polychlorinated naphthalenes	Wood treatment, cable insulation (rare on modern vessels)
Radioactive substances	Smoke detectors (Am-241), some gauging equipment
Certain shortchain chlorinated paraffins (SCCPs)	Sealants, adhesives, flame retardants in rubber and PVC
Perfluorooctane sulfonic acid (PFOS)	Fire-fighting foams (AFFF), some coatings

New-Build vs. Existing Vessels: For new vessels, the IHM is developed from supplier Material Declarations (MDs) and Suppliers' Declarations of Conformity (SDoCs) collected during construction. For existing vessels, the IHM requires a combination of visual inspection, sampling, and laboratory analysis. The sampling campaign is the most expensive and disruptive part of the IHM process for existing yachts — plan it around a scheduled yard period.

Developing an IHM for an Existing Superyacht

The Sampling Campaign

For existing vessels without an IHM, the process typically involves:

Document review — Collect all available construction documentation, paint specifications, material certificates, and equipment data sheets. This reduces the scope of physical sampling.
Visual inspection — Walk the vessel with a qualified IHM surveyor to identify potential locations of hazardous materials based on construction period, materials visible, and equipment age.
Sampling plan — Develop a sampling plan covering all suspect materials. The EU Technical Guidance and MEPC.379(80) specify minimum sampling requirements.
Physical sampling — Collect material samples for laboratory analysis. Common samples include:
- Paint chip samples from hull, superstructure, and interior coatings
- Gasket and jointing material samples from machinery
- Insulation samples from pipe lagging and bulkhead linings
- Cable insulation samples
- Deck covering adhesive samples
Laboratory analysis — Accredited laboratory analysis of samples for the listed hazardous materials.
IHM compilation — Compile the IHM Part I document based on findings, including location tables, material quantities, and supporting analysis certificates.

Cost and Timeline

Element	Typical Range
Sampling survey (on board)	2-5 days depending on vessel size and access
Laboratory analysis	3-6 weeks from sample submission
IHM compilation and reporting	2-4 weeks after lab results
Class verification and certification	2-4 weeks
Total elapsed time	2-4 months
Cost (50-80m yacht, existing vessel)	Varies significantly by vessel age, size, and complexity. Obtain quotes from accredited IHM surveyors.

Practical Tip: Schedule the sampling campaign during a yard period when spaces are accessible and equipment is stripped down for maintenance. Sampling gaskets from machinery that is running is impractical and adds significant cost. Coordinate with the class surveyor to combine the IHM verification with other class activities to minimise additional survey fees.

Maintaining the IHM

This is where most vessels fail. Developing the initial IHM is a one-time exercise. Maintaining it is an ongoing obligation that runs for the life of the vessel.

When Does the IHM Need Updating?

The IHM must be updated whenever:

Materials are removed — e.g., asbestos gaskets replaced with non-asbestos alternatives during a refit
Materials are added — e.g., new equipment installed that contains listed hazardous materials
Structural modifications — any yard work involving new coatings, insulation, or structural materials
Equipment replacement — new HVAC systems, electrical equipment, fire suppression systems

The Maintenance Plan

MEPC.379(80) and MEPC.405(83) require that the vessel have a documented IHM Maintenance Plan. This plan should describe:

Element	Description
Responsible person	Who on board is responsible for IHM maintenance (typically the Chief Engineer)
Update triggers	When an update is required (material change, refit, equipment change)
Supplier documentation	How Material Declarations and SDoCs are collected from suppliers for new equipment/materials
Change log procedure	How changes are recorded and the IHM Part I is amended
Verification schedule	When the IHM is re-verified by class (at each renewal survey, as a minimum)
Documentation archive	Where supporting documents (lab certificates, MDs, SDoCs) are stored

Material Declarations and Supplier Compliance

For every new material or equipment item installed on board after the IHM is developed, the vessel should obtain either:

A Material Declaration (MD) — a declaration from the supplier listing the hazardous materials present in the product, or confirming their absence
A Supplier’s Declaration of Conformity (SDoC) — a higher-level declaration confirming the product does not contain any of the listed hazardous materials above threshold levels

In practice, collecting MDs from marine equipment suppliers is straightforward — most major manufacturers (Caterpillar, MTU, Carrier, ABB) have IHM-compliant material declarations available. The challenge is with non-marine suppliers — furniture manufacturers, interior fit-out companies, and decorative material suppliers used during refits. The Chief Engineer or project manager must insist on MDs from all suppliers as a procurement condition.

Refit Risk: A major interior refit that installs new joinery, upholstery, carpeting, and coatings without collecting Material Declarations from the suppliers will invalidate the IHM. The entire sampling and analysis exercise may need to be repeated for the affected areas. This is an expensive oversight that is entirely avoidable with proper procurement procedures.

Class Society Certification

EU-Flagged Vessels

EU-flagged vessels of 500 GT and above must have the IHM verified by the flag state or a recognised organisation (the vessel’s classification society). Successful verification results in the issuance of an Inventory Certificate under EU Regulation 1257/2013.

Non-EU Flagged Vessels

Non-EU flagged vessels calling at EU ports must carry a Statement of Compliance confirming that IHM Part I has been developed in accordance with the regulation. This can be issued by the flag state or a recognised organisation.

Hong Kong Convention

Under the Convention, flag state parties will issue an International Certificate on Inventory of Hazardous Materials following verification of the IHM. The format is specified in the Convention’s Appendix 3.

Verification Scope

Class society verification typically includes:

Review of the IHM Part I document for completeness and format compliance
Review of the sampling plan and laboratory analysis certificates
On-board verification that the IHM accurately reflects the materials present
Review of the maintenance plan and change log
Issuance of the certificate with endorsement at each annual survey

Common Gaps Found at Survey

Based on class society findings and port state control experience, the most common IHM deficiencies are:

IHM not on board — The vessel is above 500 GT, trades in EU waters, and has no IHM at all. This is a detainable deficiency under the EU SRR.
IHM not maintained — The initial IHM was developed but has not been updated following refits or equipment changes. The change log is empty despite known modifications.
No maintenance plan — The IHM Part I exists but there is no documented procedure for keeping it current.
Missing Material Declarations — New equipment installed during the last yard period has no supporting MDs or SDoCs. The IHM does not reflect the new installations.
Sampling deficiencies — The original sampling campaign was inadequate — insufficient samples for the vessel’s size, or key areas (e.g., accommodation insulation, cable trays) were not sampled.
Expired certificate — The Inventory Certificate or Statement of Compliance has passed its endorsement date because the annual survey was missed.
ODS discrepancy — The IHM lists ODS-containing equipment (e.g., R-22 systems) but the ODS Record Book under MARPOL Annex VI shows different equipment. The two documents must be consistent.

Port State Enforcement: The European Maritime Safety Agency (EMSA) has included IHM compliance in its Concentrated Inspection Campaign (CIC) priorities. Paris MoU port state control officers in Mediterranean and Northern European ports are actively checking for IHM compliance on vessels of 500 GT and above. Non-compliance can result in detention until the deficiency is rectified — a costly outcome for a yacht with a charter commitment.

Planning for Compliance

For vessels that do not yet have an IHM, the recommended approach is:

Confirm applicability — Verify the vessel’s gross tonnage. If 500 GT or above and trading in EU waters (or flagged to a Hong Kong Convention state party), the IHM is required.
Select an IHM provider — Choose a company accredited for IHM development (typically a hazardous materials consultancy with maritime experience). Class societies can recommend approved providers.
Schedule sampling — Align the sampling campaign with the next yard period to maximise access and minimise disruption.
Develop the IHM — Allow 2-4 months for the full process including lab analysis.
Obtain certification — Submit the completed IHM to the class society for verification and certification.
Implement maintenance — Establish the maintenance plan and change log. Brief the engineering team on the update triggers and MD collection requirements.

Regulatory References

EU Regulation 1257/2013 — Ship Recycling Regulation
EU Commission Implementing Regulation 2016/2325 — Format for the Certificate on Inventory of Hazardous Materials
Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships (2009)
IMO Resolution MEPC.379(80) — 2023 Guidelines for the Development of the IHM
IMO Resolution MEPC.405(83) — April 2025 Amendments to the IHM Guidelines (cybutryne threshold amendments)
IMO Resolution MEPC.269(68) — 2015 Guidelines (superseded by MEPC.379(80), but still referenced in some class requirements)
EU Regulation (EC) 1005/2009 — ODS Regulation (relevant to IHM ODS entries)
AFS Convention — International Convention on the Control of Harmful Anti-Fouling Systems (relevant to TBT entries)

The IHM is not a one-time exercise — it is a living document that must track every material change on your vessel for its entire operational life. Get it right at the outset, maintain it through every refit and equipment change, and you will pass survey without difficulty. Neglect it, and you are looking at detention, costly retrospective sampling, and a compliance gap that will follow the vessel until it is resolved.