Inventory of Hazardous Materials Reports

Use of non-hazardous materials in ship design, building and operation is governed by two regulations:

  1. Regulation (EU) No. 1257/2013 of the European Parliament and of the Council of 20 November 2013 on Ship Recycling (EU SRR)
  2. Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships, 2009 SR/CONF/45 (HKC)

The EU SRR and HKC are statutory requirements according to which, ship owners, ship builders, suppliers, recycling facilities and national authorities become responsible for ensuring the safe management of hazardous materials (hazmats) and for sustainable recycling of ships. A core requirement is the documentation of hazardous materials on board ships, called Inventory of Hazardous Materials (IHM), and the authorization of ship recycling facilities.
EU SSR enters into force on 31 Dec 2020 for all EU/EEA flagged ships and third part ships visiting EU/EEA ports and anchorages. HKC is not yet ratified.
The IHM is a list of hazardous materials that are present on a ship. The IHM quantifies and locates hazardous materials on board ships which are known to represent a potential hazard to people and the environment.

The IHM consists of three parts:

  • Part I: Hazardous materials contained in the ship’s structure and equipment
  • Part II: Operationally generated wastes
  • Part III: Stores

The IHM Part I is prepared either during the construction of the ship or while the vessel is in operation. It is maintained and kept up to date until the end of the ship’s life. Parts II and III are prepared prior to ship’s recycling.
For newbuilding projects, the IHM Part I is prepared by the shipyard and is based on Material Declarations (MD) and the Supplier’s Declaration of Conformity (SDoC).
For ships in operation, preparation IHM Part I is responsibility of ship owner. The EU SRR requires investigation of 15 hazardous substances, listed in Annexes I and II to the regulation.


We offer preparation of IHM reports by our hazmat experts. Reports are based on document analysis and on-board investigation through sampling and visual checks.
IHM Part I reports, which are prepared according to the MEPC.269(68) 2011 Guidelines for the Development of the Inventory of Hazardous Materials, shall be certified by the flag states or by recognized organizations (ROs).


The Hong Kong International Convention for the safe and environmentally sound recycling of ships
European Commission for ship recycling