IHM and ship recycling

The HKC enters into force on 26 June 2025. Vessels, equal to and above 500 GT, with flags party to the HKC must have an International Certificate on Inventory of Hazardous Materials (ICIHM). Non-party flags, upon entering waters of a party to the HKC, must have a Statement of Compliance on Inventory of Hazardous Materials (SoC IHM). The documentation should be issued at the first renewal survey on or after 26 June 2025 and harmonized with other statutory requirements by 26 June 2030.

All new ships with flags party to the HKC or non-party flags upon entering waters of a party to the HKC must have an ICIHM or SoC IHM according to the Hong Kong Convention, starting from 26 June 2025. A “new ship” is a ship:

• for which the building contract is placed on or after 26 June 2025 (the entry into force of the HKC) or,
• in the absence of a building contract, whose keel is laid, or which is at a similar stage of construction, on or after 26 December 2025 (six months after the entry into force of the HKC) or
• the delivery of which is on or after 26 December 2027 (30 months after the entry into force of the HKC).

Yes. According to Article 3.4 of the Hong Kong Convention, all ships that operate internationally and call at ports of a country that have ratified the HKC must comply with the requirements of the HKC (i.e. shall have an IHM or IRR SoC).

The HKC enters into force on 26 June 2025; however, ships in operation will have time until 26 June 2030 to comply. Therefore, it would be best to request the HKC IHM International Certificate or SoC at the next IHM renewal survey after the entry into force date. As long as your vessel has a maintained and up-to-date IHM as per the EU Ship Recycling Regulation (SRR) requirements, your vessel automatically complies with the HKC requirements.

To be qualified as a Fully Approved HazMat Expert, after attending the two-day HazMat Training Lite course (Approved Hazmat Expert), you must take part in an additional one-on-one training, the IHM Job Supervision (formerly called
witnessing) course.

After successful completion of the two-day HazMat Training Lite course and the IHM Job Supervision course, and upon passing the exam, you will receive the Fully Approved HazMat Expert Certificate.

To pass the exam, you must answer at least 60% of the questions correctly.

Please contact us for more details.

DNV implements approval schemes for companies involved in IHM services. The schemes are:

• HazMat Expert Company (approval of IHM inspection company)
• HazMat Expert Lab (approval of laboratories)

The company approval is for the IHM inspection, sampling and reporting, while laboratory approval is for the analysis. Both are carried out during a one-day company audit at the supplier’s premises in line with ISO 9001.

For the HazMat Expert Company approval, the prerequisite is to have at least one staff employed as a Fully Approved HazMat Expert – and for the HazMat Expert Lab approval, the prerequisite is that the audited company possess a valid DNV HazMat Expert qualification or an equal qualification issued by a Recognized Organization.

For laboratory approval, the accreditation of ISO 17025 is required. The quality control schemes – such as quality control, training of staff, control of laboratories, IHM manual – will be checked.

After successful completion of the audit, the Approval of Service Supplier (AoSS) Certificate is issued by DNV and published in the DNV Approval Finder.

DNV offers the class notation Recyclable regarding a ship’s hazardous materials status.

The class notation Recyclable has the same requirements as for the development of IHM Part I for new and existing ships as per EU Ship Recycling Regulation (EU SRR). See detailed information in the DNV Rules for Recycling

The IHM Manager (IHMM) is a self-service software solution for IHM Maintenance, which is a statutory requirement as per the Hong Kong Convention and the EU Ship Recycling Regulation. The IHMM tool is available under Vessel Services on the DNV customer portal.

Customers can find the User Guide and demo videos of the tool on this page, even if you have not yet subscribed to the IHMM tool. At the bottom of the page, you can find a link to the Marketplace page through the “Get subscription” link.

Yes. For IHM maintenance, the shipowner should collect MDs and SDoCs for all the purchased items that fall into the scope of IHM Part I.

DNV follows what is written in the Hong Kong Convention (HKC) and the EU Ship Recycling Regulation (EU SRR). HKC Regulation 5.3 states: “Part I of the Inventory of Hazardous Materials shall be properly maintained and updated throughout the operational life of the ship, reflecting new installations containing Hazardous Materials listed in Appendix 2 and relevant changes in ship structure and equipment, taking into account the guidelines developed by the Organization”. It refers to the MEPC IHM Guidelines, which state under 4.1.4: “The checking of materials as provided in paragraphs 4.1.2 and 4.1.3 above should be based on the Material Declaration furnished by the suppliers in the shipbuilding supply chain.”

Some flags published circulars stating that other solutions which ensure reliable information on the presence of hazardous materials on board ships can be accepted, such as the use of purchase order procedures that require suppliers to provide an SDoC and MD in the applicable formats whenever the supplied item contains hazardous materials listed in Annexes I/II of the EU SRR.

At DNV, we support this approach; however, we cannot guarantee that it will be accepted by all stakeholders such as other flag states, port state administrations or Recognized Organizations. Therefore, we strongly recommend the collection of MDs/SDoCs until the requirement is changed in the MEPC IHM Guidelines.

The IHM renewal survey is usually harmonized with the main class renewal survey conducted every five years. The requirements are as below:

• A vessel-specific, maintained and updated Inventory of Hazardous Materials (IHM Part I) shall be provided on board together with the valid compliance declaration and previous IHM. The updated IHM must also have correct ship particulars on the cover page and should preferably have a revision record.
• The procedure for maintaining the IHM Part I shall be on board and be integrated into the safety management system.
• The Inventory of Hazardous Materials (IHM Part I) shall be consistent with the arrangement, structure and equipment of the vessel.

The approved IHM Part I will be examined and compared with the updated IHM Part I, supplemented by new Material Declarations (MDs) and Suppliers’ Declarations of Conformity (SDoCs).

In case new equipment is installed on board, the MD and SDoC shall be available. In the case of removed equipment, the IHM Part I must be updated to reflect the deletion of the hazardous material.

According to Article 8 of the Hong Kong Convention, Port State Control (PSC) shall be limited to verifying that either an IHM certificate or a Ready for Recycling certificate is on board, both supplemented by the verified IHM, which, if valid, shall be accepted for the inspection. EU/EEA/UK ports will check for the EU IHM certificate or SoC, while other ports will check for the HKC IHM International Certificate or SoC.

A detailed inspection may be carried out where a ship does not carry a valid certificate or there are clear grounds for believing that:

• the condition of the ship or its equipment does not correspond substantially with the particulars of the certificate and/or IHM Part I or
• there is no procedure implemented on board the ship for maintenance of IHM Part I.

A ship may be warned, detained, dismissed or excluded from the ports or offshore terminals under the jurisdiction of a Member State in the event that:

• it fails to submit to the relevant authorities of that Member State a copy of the IHM certificate or the Ready for Recycling certificate or
• non-compliance with the control measures for hazardous materials listed in Appendix 1 to the HKC or Annex I to the EU SRR are identified.

A Member State taking such action shall immediately inform the administration concerned.

IHM Part II regarding operationally generated waste and IHM Part III regarding stores shall be prepared by the shipowner once the decision has been taken to send the ship for recycling. IHM Parts II and III can be prepared by the crew or, if the shipowner prefers, a hazmat expert.

For IHM Parts II and III preparation, please refer to the MEPC.379(80) IHM Guidelines as below:

• Refer to 4.4 and 4.5 on page 8 for IHM Parts II and part III development requirements.
• Refer to Table C and Table D on pages 14 and 15 for the potentially hazardous materials.
• Refer to the IHM Parts II and III example tables on pages 18 to 21.
• Additionally, IHM Parts II and III investigation reports with supporting documents – such as inventories, recordings, log books, site pictures – attached as appendices should be provided to DNV for approval.