The Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships (HKC) entered into force on 26 June 2025 — transforming the Inventory of Hazardous Materials from a compliance document into an operational requirement with real enforcement. Every ship of 500 GT and above must now maintain a certified IHM listing all hazardous materials in the vessel's structure and equipment, updated throughout the ship's entire operational life, and verified through initial, renewal, and additional surveys. For EU-flagged ships and all vessels visiting EU ports, the EU Ship Recycling Regulation (EU SRR No. 1257/2013) has been in force since 31 December 2020 with even stricter requirements — 15 hazardous materials versus 13 under the HKC, and mandatory recycling at facilities listed on the European List of Approved Ship Recycling Facilities. The materials involved are genuinely dangerous: asbestos in engine room insulation releases carcinogenic fibres when damaged; PCBs in older electrical equipment and paint are persistent environmental toxins; lead and mercury in batteries, paints, and instruments cause neurological damage; ozone-depleting substances in refrigeration and fire suppression systems destroy the atmospheric ozone layer; and TBT in anti-fouling coatings is toxic to marine life at extremely low concentrations. Since 1 January 2011, no asbestos-containing materials are permitted on board ships — even for repairs. Ships built before 1 July 2002 may contain legally installed asbestos that must be managed through an Asbestos Management Plan. Non-compliance with IHM requirements results in port state detention, fines, and reputational damage that affects charter availability. For superintendents and safety officers, IHM management is the intersection of environmental compliance, crew health protection, and vessel commercial viability. To see how Marine Inspection digitalises IHM maintenance, material declaration tracking, and supplier compliance across your fleet, book a Marine Inspection demo.
IHM Part I, Part II, Part III: What Each Contains
What: All hazardous materials contained in the ship's structure and equipment — materials that are an integral part of the vessel.
When prepared: During construction (new builds) or by survey of existing ships. Must be maintained and updated throughout the vessel's operational life.
Examples: Asbestos in insulation, PCBs in electrical equipment, lead in paint, mercury in instruments, ODS in refrigeration, TBT in anti-fouling coatings, heavy metals in electronic components.
Certification: Verified by initial survey. International Certificate on IHM (ICIHM) or Statement of Compliance (SoC IHM) issued.
What: Wastes generated during the ship's normal operation that are potentially hazardous at the recycling facility.
When prepared: Before the vessel is sent for recycling — not required during operational life. Prepared by shipowner once the decision to recycle is made.
Examples: Bilge water, fuel oil residues (sludge), oily rags, used filters, sewage, cargo residues, incinerator ash, chemical cleaning residues.
What: Regular consumable goods carried on board that may contain hazardous materials but are not integral to the ship's structure.
When prepared: Before the vessel is sent for recycling — not required during operational life. Prepared by shipowner at end of operational life.
Examples: Paints, cleaning chemicals, lubricating oils, spare parts containing hazardous substances, batteries, fluorescent tubes, medical waste.
The 15 Hazardous Materials: What Must Be Inventoried
| # | Hazardous Material | Where Found on Ships | Health / Environmental Risk | Regulation |
|---|---|---|---|---|
| 1 | Asbestos | Engine room insulation, gaskets, brake linings, pipe lagging, fire-resistant panels | Mesothelioma, lung cancer, asbestosis. Carcinogenic fibres released when damaged. | Banned on new ships since 2002 (SOLAS II-1/3-5). No ACMs allowed on board since Jan 2011. |
| 2 | PCBs | Older electrical equipment (transformers, capacitors), paint, caulking, insulation | Persistent organic pollutant. Bioaccumulates. Causes cancer, immune/reproductive damage. | HKC + EU SRR. Prohibited in new installations. |
| 3 | Ozone-Depleting Substances | Refrigeration, air conditioning (CFCs, HCFCs), fire suppression (halons) | Destroys atmospheric ozone layer. Controlled under Montreal Protocol. | HKC + EU SRR. New installations prohibited. |
| 4 | TBT Anti-Fouling | Hull anti-fouling paint systems (older vessels) | Extremely toxic to marine organisms at trace concentrations. Causes imposex in gastropods. | HKC + EU SRR. AFS Convention banned TBT since 2008. |
| 5 | Cadmium & Compounds | Batteries, pigments, coatings, soldering, electronic components | Kidney damage, bone disease, carcinogenic. Toxic to aquatic organisms. | HKC + EU SRR. Above threshold concentration. |
| 6 | Chromium VI | Paints, primers, anti-corrosion coatings, chromium plating | Carcinogenic. Causes respiratory sensitisation, skin ulceration. | HKC + EU SRR. Above threshold concentration. |
| 7 | Lead & Compounds | Paints, batteries, cable sheathing, bearing alloys, solders | Neurological damage, kidney damage, reproductive harm. Cumulative toxin. | HKC + EU SRR. Above threshold concentration. |
| 8 | Mercury & Compounds | Thermometers, barometers, switches, fluorescent tubes, batteries | Neurological damage, kidney damage. Bioaccumulates in marine food chain. | HKC + EU SRR. Above threshold concentration. |
| 9 | PBBs / PBDEs | Flame retardants in textiles, electronics, insulation foam, cable insulation | Endocrine disruption, persistent environmental pollutant. | HKC + EU SRR. Above threshold concentration. |
| 10 | Radioactive Substances | Older navigational instruments, smoke detectors, level gauges | Radiation exposure. Cancer risk from prolonged contact. | HKC + EU SRR. |
| 11 | Certain Shortchain Chlorinated Paraffins | Paints, rubber, sealants, metalworking fluids | Persistent, bioaccumulative, toxic to aquatic organisms. | HKC + EU SRR. |
| 12 | Organotin Compounds (as anti-fouling) | Anti-fouling paint systems | Toxic to marine organisms. Banned under AFS Convention. | HKC + EU SRR. |
| 13 | Cybutryne | Anti-fouling paints (biocide) | Toxic to aquatic organisms. Endocrine disruption potential. | HKC + EU SRR. |
| 14 | PFOS | Fire-fighting foams, coatings, cleaning agents | Persistent organic pollutant. Bioaccumulates. Banned under Stockholm Convention. | EU SRR only (not HKC). Additional EU requirement. |
| 15 | HBCDD | Insulation foam (polystyrene), textiles | Persistent, bioaccumulative, reproductive toxin. | EU SRR only (not HKC). Additional EU requirement. |
IHM Maintenance: Keeping the Inventory Current
An IHM is not a one-time document — it must be maintained and updated throughout the vessel's operational life. Every new installation, repair, or modification that introduces or removes hazardous materials must be reflected in the inventory. Book a Marine Inspection demo to see how the platform automates IHM maintenance with supplier declaration tracking.
How Marine Inspection Manages IHM Compliance
HKC vs EU SRR: Key Differences
Conclusion
The Inventory of Hazardous Materials has transitioned from a voluntary environmental initiative to an enforced international requirement with the Hong Kong Convention entering into force on 26 June 2025, joining the EU Ship Recycling Regulation that has been in force since December 2020. All ships of 500 GT and above must carry a certified IHM Part I listing hazardous materials in the vessel's structure and equipment — maintained and updated throughout the ship's operational life through Material Declarations and Supplier Declarations of Conformity from every supplier. The 13 hazardous materials under HKC (15 under EU SRR) include asbestos, PCBs, ozone-depleting substances, TBT, heavy metals, radioactive substances, and flame retardants — materials that cause cancer, neurological damage, reproductive harm, and environmental destruction when improperly handled during recycling. IHM maintenance requires a designated Hazmat expert, systematic MD/SDoC collection, update triggers for every installation or modification, and a 5-year renewal survey cycle. Pre-2002 vessels with asbestos require Asbestos Management Plans per MSC/Circ.1045. Non-compliance results in port state detention, fines, and commercial consequences. Marine Inspection provides the digital platform that keeps IHM Part I current, tracks material declarations from suppliers, manages survey certificates, and documents asbestos management — book a live demo today.
