Important updates on Inventory of Hazardous Materials (IHM)

Inventory of Hazardous Materials (IHM) – mandatory for Ships and Yachts >500 GT flying the flag of an EU/EEA member state, or third-party flagged vessels calling at European ports


The end of the year is fast approaching and so are two separate actions required by Managers/Operators before the 01 Jan 2021 – Inventory of Hazardous Materials (IHM) and the ISM Maritime Cyber Risk Management which you can read in this article.


Two regulations are presently governing the IHM issues:



Inventory of Hazardous Materials (IHM) is a structured system to control hazardous materials onboard ships and achieve compliance with the EU Ship Recycling Regulation (EU SRR) and Hong Kong Convention (HKC) for the Safe and Environmentally Sound Recycling of Ships.


From December 31, 2020, any ship or yacht which is 500 GT or over, regardless of flag, will require a valid and certified IHM on board if calling at an EU port or anchorage. Non-EU flagged vessels can also be certified against EU SRR by complying with the HKC IHM requirements.


Transport Malta issued Merchant Shipping Notice 163 to draw attention of all concerned to a Notice recently adopted by the Commission providing Guidelines on the enforcement of obligations under the EU Ship Recycling Regulation No. 1257/2013 relating to the Inventory of Hazardous Materials (IHM).


The above-mentioned Notice 163, refers to the obligation to carry on board an IHM with a certificate or statement of compliance as appropriate, as from 31 December 2020, and provides guidance considering the disruptions caused by Covid-19, for a harmonised approach towards enforcement by the EU port States authorities during ship inspections carried out as from the said deadline.


It is also prudent to be reminded of previous Transport Malta Merchant Shipping Notices No.147 and 163 concerning the implementation of the EU Ship Recycling Regulation.


For more information, or for assistance in the matters please don’t hesitate to contact us here.