IHM Compliance for Ship Suppliers: What to Document Before Delivery

IHM compliance is no longer a topic only for ship recycling yards. For ship owners, ship managers, procurement teams, sustainability officers, HSEQ managers and marine suppliers, the Inventory of Hazardous Materials has become part of daily purchasing, documentation and vessel lifecycle management.

In ship supply, the question is not only whether the item can be delivered on time. Buyers also need to know whether the supplied item contains hazardous materials that must be declared, tracked or supported with documentation.

This is why IHM compliance ship supplier processes matter. A supplier may deliver technical stores, chemicals, spare parts, deck equipment, electrical components, gaskets, insulation materials, paints, batteries or machinery parts. Some of these products may contain substances that are relevant to the vessel’s IHM records.

A well-structured IHM documentation process helps procurement teams avoid missing Material Declarations, incomplete Supplier’s Declarations of Conformity, poor traceability and last-minute compliance gaps during audits, class reviews or vessel lifecycle updates.

AVS Global Ship Supply & Catering supports ship owners, ship managers, procurement teams, sustainability officers and HSEQ managers with Technical Stores, marine chemicals, spare parts, deck supplies and global ship supply coordination across international ports.

For related technical and chemical categories, see Marine Chemicals. For wider sustainability context, review ESG in maritime procurement. For IHM-related supply requests, submit your requirement through Quick Quote.

What IHM Means: Hong Kong Convention and EU SRR

IHM stands for Inventory of Hazardous Materials. It is a ship-specific inventory that identifies hazardous materials present in the ship’s structure and equipment, and in certain cases materials, wastes and stores relevant to recycling preparation.

The purpose of IHM is to improve safety, environmental protection and traceability during the vessel’s operational life and eventual recycling.

Hong Kong Convention

The Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships was adopted by the IMO in 2009 and entered into force on 26 June 2025.

The Convention creates requirements for ships and ship recycling facilities. For vessels, one of the central requirements is to develop, maintain and verify an Inventory of Hazardous Materials.

Under the Hong Kong Convention framework, ships that go for recycling must carry an IHM specific to that vessel. The IHM supports safe recycling by identifying hazardous materials and helping recycling facilities plan the work properly.

EU Ship Recycling Regulation

The EU Ship Recycling Regulation also requires ships within its scope to carry an IHM. This includes EU-flagged ships and third-country ships calling at EU ports or anchorages, depending on the vessel type and regulatory scope.

For procurement teams, this means that IHM documentation is not only an end-of-life matter. During normal vessel operation, purchases and replacements may affect the vessel’s IHM records.

Why Suppliers Matter

Ship suppliers are part of the IHM chain because new products may introduce hazardous materials onboard. If the supplier does not provide the correct declaration, the buyer may struggle to update the vessel’s IHM database.

Supplier documentation is especially important for:

Technical stores
Spare parts
Electrical equipment
Cables and lighting
Pumps and valves
Gaskets and sealing materials
Insulation materials
Paints and coatings
Marine chemicals
Batteries
Filters
Deck equipment
Fire safety items
Machinery components

Not every supply item requires the same level of documentation, but procurement teams should know which categories need IHM attention.

Hazardous Materials Tracked Onboard

IHM focuses on hazardous materials that may be present in ship structure, equipment, components, coatings, systems, stores or waste streams depending on the IHM part and vessel situation.

For suppliers, the practical question is simple: does the delivered item contain a hazardous material that needs to be declared?

Common IHM-Relevant Materials

Materials commonly associated with IHM review may include:

Asbestos
Polychlorinated biphenyls
Ozone-depleting substances
Anti-fouling systems containing controlled substances
Heavy metals
Lead compounds
Mercury compounds
Cadmium compounds
Hexavalent chromium compounds
Certain flame retardants
Radioactive substances where applicable
Hazardous chemicals
Batteries containing regulated substances
Materials in electrical and electronic equipment

The exact declaration requirement depends on the applicable regulation, IHM table, product type and vessel scope.

Product Categories That Need Attention

Ship suppliers should pay special attention when supplying:

Gaskets
Packing materials
Insulation products
Brake linings
Electrical cables
Switchboards
Lamps and lighting units
Batteries
Paints and coatings
Adhesives
Sealants
Pumps
Valves
Filters
Refrigeration equipment
Firefighting components
Hydraulic components
Electronic control units
Deck machinery parts

These products may contain materials that need to be declared, even when the item looks routine from a purchasing perspective.

Marine Chemicals and IHM

Marine chemicals may also require careful documentation. Some chemicals may be relevant to hazardous material tracking, safety data management, onboard storage and environmental control.

Procurement teams should not treat chemical purchases as simple consumables. The Safety Data Sheet, product composition, hazard classification and intended onboard use should be reviewed.

For chemical procurement context, see Marine Chemicals.

MARPOL and Environmental Context

IHM is mainly connected with hazardous material inventory and ship recycling, but it also supports wider environmental management. Buyers and HSEQ teams often connect IHM with broader pollution prevention, waste handling and environmental compliance systems.

For wider regulatory background, see IMO and MARPOL.

Material Declarations and SDoC from Suppliers

Supplier documentation is the practical bridge between the purchased item and the vessel’s IHM database. The most important supplier documents are usually the Material Declaration and the Supplier’s Declaration of Conformity.

These are often referred to together as MD and SDoC.

What Is a Material Declaration?

A Material Declaration identifies whether a supplied product contains hazardous materials above the relevant threshold. It usually includes product details, supplier details, material information and declaration status.

A Material Declaration may include:

Supplier name
Product name
Product model or part number
Manufacturer name
Quantity or unit
Hazardous material status
Material name
Approximate quantity or concentration
Location in the product
Applicable IHM table reference
Date of declaration
Responsible person
Signature or company confirmation

For buyers, the Material Declaration helps determine whether the item affects the vessel’s IHM records.

What Is a Supplier’s Declaration of Conformity?

The Supplier’s Declaration of Conformity is a supplier statement confirming that the supplied item and the related Material Declaration are accurate according to the supplier’s knowledge and documentation system.

An SDoC may include:

Supplier company details
Product or item reference
Declaration scope
Confirmation of accuracy
Reference to the Material Declaration
Name and title of responsible person
Signature
Date
Contact details

The SDoC supports traceability and accountability.

MD and SDoC Together

The Material Declaration explains what is in the product. The Supplier’s Declaration of Conformity confirms the supplier’s responsibility for that declaration.

Together, they help:

Update the vessel’s IHM
Support class or RO review
Improve supplier traceability
Reduce audit gaps
Support ESG and HSEQ reporting
Clarify whether hazardous materials are present
Avoid undocumented substitutions

Procurement teams should request MD and SDoC where the product category or company procedure requires them.

Procurement Workflow with IHM Considerations

IHM compliance should be included in procurement workflow before the order is confirmed. Waiting until the item is delivered creates risk because the supplier may not be able to provide missing declarations quickly.

A practical workflow helps buyers, suppliers and technical teams avoid delays.

Step 1: Identify IHM-Relevant Categories

The buyer should first identify whether the item may require IHM documentation.

High-attention categories include:

Technical stores
Electrical components
Mechanical spare parts
Insulation materials
Sealing products
Gaskets
Paints and coatings
Batteries
Lighting equipment
Marine chemicals
Fire safety components
Machinery parts
Refrigeration components
Deck equipment

These categories should be flagged during RFQ preparation.

Step 2: Add IHM Requirements to the RFQ

The RFQ should not only ask for price and delivery time. It should also ask whether IHM documents are required and available.

A strong RFQ may include:

Item description
Product model
Manufacturer reference
Quantity
Vessel name
Delivery port
Required delivery date
IHM documentation requirement
Material Declaration requirement
Supplier’s Declaration of Conformity requirement
Safety Data Sheet where applicable
Non-asbestos declaration where applicable
Substitution approval rule
Required document submission deadline

This makes the supplier’s responsibility clear before quotation.

Step 3: Review Supplier Documentation

Once documents are received, procurement and HSEQ teams should check:

Product name matches the quotation
Part number matches the supplied item
Supplier details are complete
Declaration date is valid
Signature or responsible person is present
Hazardous material status is clear
Threshold information is included where required
SDS and MD information are consistent
Any hazardous material is clearly identified
Documents are in a usable format

If documents are incomplete, the buyer should ask for correction before delivery where possible.

Step 4: Control Substitutions

Substitutions are common in ship supply, especially under urgent delivery pressure. However, substitution can create IHM problems.

If the supplier proposes an alternative product, the buyer should request updated documentation.

Substitution review should include:

New product name
New manufacturer
New Material Declaration
New SDoC
Safety Data Sheet if applicable
Technical equivalence
Hazardous material status
Chief engineer or superintendent approval
HSEQ approval where required

A technically acceptable substitute may still be unacceptable if documentation is missing.

Step 5: Store Documents in the IHM File

IHM-related documents should be stored in a structured way so that the vessel, technical team, HSEQ team and class or RO can access them when needed.

A practical folder structure may include:

Vessel name
Purchase order number
Product category
Supplier name
Delivery date
MD and SDoC
SDS
Certificates
Delivery note
Related correspondence
Approval record

Good document control makes future IHM maintenance easier.

Class Society and Recognized Organization Role

Class societies and Recognized Organizations play an important role in IHM verification and certification, depending on flag, regulatory framework and vessel scope. They may review the IHM, verify documentation and issue or support the required certificate or statement.

For procurement teams, the key point is that class or RO review depends on reliable supplier documentation.

What Class or RO May Check

A class society or Recognized Organization may review:

IHM Part I
Supporting supplier documents
Material Declarations
Supplier’s Declarations of Conformity
Hazardous material locations
Approximate quantities
IHM maintenance records
Change records
Technical documentation
Survey records
Certificate or Statement of Compliance status

If supplier documents are missing or weak, IHM verification becomes more difficult.

Buyer Responsibility vs Supplier Responsibility

The ship owner or ship manager is normally responsible for maintaining the vessel’s IHM. However, suppliers support that responsibility by providing accurate documents for the products they deliver.

A practical division is:

Buyer identifies IHM-relevant items.
Supplier provides MD and SDoC where required.
Technical team confirms product use and location.
HSEQ team checks document completeness.
IHM service provider or responsible person updates the IHM.
Class or RO verifies as required.

This process depends on cooperation across the supply chain.

Why Supplier Auditability Matters

Suppliers may be audited or reviewed for IHM-related processes, especially when they provide technical items, chemical products or repeated fleet supplies.

A buyer may ask suppliers about:

Document control
Material declaration process
Manufacturer traceability
Hazardous material screening
Substitution control
Non-asbestos declarations
SDS availability
Staff awareness
Record retention
Response time for document requests

For procurement and sustainability teams, supplier auditability is part of responsible sourcing.

IMPA and ISSA References

Marine procurement teams may also use industry bodies and purchasing references to standardize communication and supplier expectations. IMPA and ISSA can support common understanding in marine purchasing and ship supply processes.

Maintaining IHM Through the Vessel Lifecycle

IHM is not a one-time document prepared only when a ship is new or ready for recycling. It must be maintained through the vessel’s life as equipment is replaced, repaired, upgraded or removed.

This is where procurement discipline becomes important.

When IHM Should Be Updated

IHM may need to be updated when:

New equipment is installed
Spare parts are replaced
Hazardous material status changes
Paints or coatings are applied
Insulation is replaced
Batteries are installed or removed
Electrical components are changed
Machinery components are replaced
Materials are removed during repair
Supplier documents show hazardous content
Vessel undergoes conversion or major repair

The IHM database should reflect changes that affect hazardous material inventory.

Who Maintains the IHM Database?

The ship owner or ship manager usually assigns responsibility for maintaining IHM records. This may involve the technical department, HSEQ team, superintendent, vessel crew, IHM expert or external service provider.

Procurement supports the process by ensuring that documents are collected at the purchasing stage.

Why Lifecycle Maintenance Matters

Poor IHM maintenance can create problems during:

Port State Control checks
Class or RO review
Internal audits
ESG reporting
Vessel sale
Fleet compliance review
Major repair
Ship recycling preparation
HSEQ investigations

Keeping the IHM updated reduces future correction work and supports regulatory readiness.

ESG and Sustainability Connection

IHM is also connected with ESG because it supports transparency, hazardous material control, environmental protection, worker safety and responsible ship recycling.

For sustainability officers, IHM documentation can support:

Supplier due diligence
Environmental reporting
Safer recycling preparation
Hazardous material traceability
Audit trails
Responsible sourcing
Circular economy and waste control discussions

For broader sustainability context, see ESG in maritime procurement.

How AVS Supports IHM-Related Ship Supply Documentation

AVS supports procurement teams, sustainability officers and HSEQ managers by helping clarify document needs before supply and coordinating required supplier documentation where applicable.

AVS can support:

Technical stores supply
Marine chemicals supply
Spare parts sourcing
Deck equipment supply
IHM-related document collection
Material Declaration coordination
Supplier’s Declaration of Conformity coordination
Safety Data Sheet collection
Non-asbestos declaration request where applicable
Product substitution control
Multi-port delivery coordination
Supplier communication
Delivery documentation
Proof of delivery
Fleet-level procurement support

AVS helps buyers reduce documentation gaps by aligning product sourcing, technical review and compliance requirements before delivery.

Conclusion: IHM Compliance Starts Before Delivery

IHM compliance is not only a recycling-yard issue. It begins much earlier, during procurement, supplier selection, product approval and document collection.

For ship suppliers, the practical responsibility is to provide accurate product information and documentation when the supplied item may affect the vessel’s Inventory of Hazardous Materials. For buyers, the responsibility is to identify IHM-relevant categories, request the right documents and store them properly.

The best approach is simple: ask for IHM documents before confirming the order, control substitutions carefully and keep records linked to the vessel and purchase order.

AVS Global Ship Supply & Catering supports ship owners, ship managers, procurement teams, sustainability officers and HSEQ managers with technical stores, marine chemicals, spare parts, documentation coordination and global ship supply across international ports.

For IHM-related supply requests, technical stores, marine chemicals, spare parts or documentation-sensitive vessel supply, submit your requirement through Quick Quote.

FAQ

What is IHM in maritime?

IHM means Inventory of Hazardous Materials. It is a ship-specific inventory that identifies hazardous materials present in the ship’s structure, equipment and relevant materials depending on the IHM scope.

Is IHM mandatory for all vessels?

IHM requirements depend on vessel type, flag, size, trading area and applicable regulation. EU SRR and the Hong Kong Convention create IHM obligations for ships within their scope.

What is the Hong Kong Convention?

The Hong Kong Convention is an IMO convention for safe and environmentally sound ship recycling. It entered into force on 26 June 2025 and includes requirements related to hazardous materials and ship recycling preparation.

What documents must a supplier provide?

Depending on the product, suppliers may need to provide a Material Declaration, Supplier’s Declaration of Conformity, Safety Data Sheet, technical document, certificate, non-asbestos declaration or other supporting documentation.

What is an MD-SoC?

MD means Material Declaration. SoC or SDoC means Supplier’s Declaration of Conformity. Together, they document whether hazardous materials are present and confirm supplier responsibility for the declaration.

How does AVS support IHM compliance?

AVS supports IHM-related procurement by coordinating product information, supplier documents, Material Declarations, Supplier’s Declarations of Conformity, Safety Data Sheets and delivery documentation where applicable.

Is IHM only for ship recycling?

No. IHM is used for safe recycling, but it must be maintained during the vessel’s operational life. Procurement, repair, replacement and product substitution can all affect IHM records.

Does IHM apply to provisions?

Most standard provisions are not the main focus of IHM. However, packaging, chemical products, galley equipment, appliances or special materials supplied with provisions may still require review depending on company procedure and product type.

How often is IHM updated?

IHM should be updated whenever relevant equipment, materials or components are installed, replaced, removed or modified in a way that affects hazardous material records.

Who maintains the IHM database?

The ship owner or ship manager is usually responsible for maintaining the IHM database. The task may involve technical teams, HSEQ teams, superintendents, vessel crew, IHM service providers and suppliers.

Can suppliers be audited for IHM compliance?

Yes. Suppliers may be reviewed or audited for document control, hazardous material declarations, substitution control, traceability, SDS availability and response to IHM documentation requests.

What hazardous materials are most common?

Common IHM-relevant materials may include asbestos, PCBs, ozone-depleting substances, certain anti-fouling system materials, heavy metals, lead, mercury, cadmium, chromium compounds and certain hazardous chemicals.

IHM Compliance for Ship Suppliers