Hong Kong Convention: Inventory of Hazardous Materials and Green Passport
The IHM links hazardous materials to their locations and quantities on the individual ship. Part I is maintained during the operational life; Parts II and III are prepared before recycling. In dry dock, the inventory is checked against removals and new installations.
Operational Explanation
The IHM is a documented map of hazardous materials present on the ship. A relevant entry links the material, item of equipment or structural element, location and approximate quantity. This information allows the material to be found when equipment is modified and supports preparation for recycling.
| IHM part | Content and stage |
|---|---|
| I — structure and equipment | Relevant hazardous materials contained in the structure or equipment, with locations and approximate quantities. Maintained and updated throughout the operational life. |
| II — operational waste | Relevant operationally generated waste to be delivered with the ship to the recycling facility. Prepared before the final survey once recycling has been decided. |
| III — stores | Relevant stores and other items to be delivered with the ship, with quantities and locations. Prepared before the final survey once recycling has been decided. |
Part II for recycling is not the routine record of every waste stream produced during docking: those collections and deliveries are followed through the ship’s and yard’s waste plans. HKC, regulation 5; MEPC.379(80), §§3.1, 4.3–4.7.
The Hong Kong Convention entered into force on 26 June 2025. Docking is an opportunity to update the IHM after removals and new installations and arrange survey and certification with the Administration or authorised organisation. An old Green Passport is supporting information to verify, not automatic evidence of IHM compliance.
Green Passport is the term used in IMO’s 2003 guidelines for a document on potentially hazardous materials, to be maintained throughout the ship’s life and delivered to the recycler. It explains the origin of this information collection, but the document’s name does not establish the verification and certification required today. A.962(23), §5 — historical reference.
Regulatory Reference
Hong Kong Convention; MEPC.379(80) as amended by MEPC.405(83); EU 1257/2013, Articles 5, 8–12. The 2025 amendment clarifies cybutryne thresholds by sample type: do not apply one threshold indiscriminately to wet paint and hull coating samples.
HKC regulation 10.1.1 requires an initial survey before entry into service or issue of the International Certificate on Inventory of Hazardous Materials. The final survey, before withdrawal from service and commencement of recycling, verifies the completed IHM, that the Ship Recycling Plan reflects the inventory and contains information on establishing, maintaining and monitoring Safe-for-entry/Safe-for-hot work conditions, and the recycling facility’s valid authorization (regulation 10.1.4). Hong Kong Convention, regulation 10.
The Inventory of Hazardous Materials (IHM) must follow the individual ship and its modifications. For existing ships within HKC scope, the general deadline is 26 June 2030 or before recycling if earlier; check EU obligations separately.
Scope of Application
Check Party flag or authority and HKC exclusions: ships below 500 GT, warships and government non-commercial service, and ships operating throughout their life solely in waters under their flag State’s jurisdiction. For the EU regime, separately check flag, port calls and its exclusions.
| Regime to identify | Relevant document and obligation |
|---|---|
| HKC, ship within the Convention’s scope | Verified IHM and HKC survey/certification process. Existing ships follow the stated transitional period; ships destined for recycling also require completion of the inventory and the final survey. |
| EU, Member State flag ship within the Regulation’s scope | IHM and inventory certificate under Articles 5 and 8–9; the deadline for existing ships was 31 December 2020. |
| EU, third-country ship within the Regulation’s scope calling at a Member State port or anchorage | IHM and Statement of Compliance under Article 12, an obligation applicable from 31 December 2020. |
The HKC 2030 deadline does not defer EU obligations already applicable. HKC also provides for no more favourable treatment of non-Party ships: consider the port-call authorities as well as the flag. EU 1257/2013, Articles 2, 5, 8–12 and 32; HKC, article 3.4 and regulation 5.2.
Procedure / How to Complete It
The IHM responsible person links each change to an identifiable entry and the installed material’s documents. Material Declarations provide material information; Supplier’s Declarations of Conformity address whether the related Material Declaration meets the guideline requirements and identify the responsible entity. Retain the relevant documents with change dates and added or deleted entries. MEPC.379(80), §§4.3, 5.2, 6 and 7.
- Identify the applicable regime, individual deadline and any flag implementation requirements.
- Reconcile IHM Part I against completed work, removed components and installed materials.
- Collect relevant Material Declarations and Supplier’s Declarations of Conformity; document gaps and verification.
- Arrange survey and certification without assuming automatic issue at HSSC renewal.
- Before recycling, also complete Parts II and III and the final survey/certification process.
Practical Example
Equipment is replaced during docking: check the IHM location and supplier documents. Section 4.3.2 of the guidelines does not require updating for identical parts or coatings; establish identity before applying this exception.
If a different pump model is installed, link the product’s identity and documents to its engine-room location, check the relevant materials and update the changed entries. The responsible person records the change and retains the inventory version consistent with the work; a generic invoice alone does not describe the material, location and quantity.
What Typically Goes Wrong
Confusing a Green Passport with a verified IHM, leaving the inventory unchanged since first issue, or applying the HKC 2030 deadline to EU documents already due.
Common Mistakes Mistake Library
| Mistake | Consequence | How to avoid it |
|---|---|---|
| Treating a Green Passport as automatic evidence of IHM compliance | Inventory and certification not evidenced | Check content, updates and acceptance under the applicable regime |
| Leaving Part I unchanged since first issue | Modifications and installed materials cannot be located in the inventory | Link removals and new installations to location, documents and change date |
| Applying the HKC 2030 deadline to EU documents already due | Applicable port-call obligation not met | Check flag, port call and documents required by the EU regime separately |
What the PSCO Checks
Operational Tips
- Assign responsibility for IHM updates.
- Link each change to its location and documentation.
- Distinguish survey planning from compliance already required.
Preparation checklist
- Scope and deadlines checked
- Removals and installations reconciled
- Supplier documents available
- IHM and certification consistent
- EU requirements checked separately
FAQ
Related Topics
Certified substantive revision: 13 October 2026 · page fingerprint a81f0157c97a