HKC ICIHM vs EU SRR Statement of Compliance: which applies to your yacht?

If you have started reading into IHM requirements, you have probably hit the same confusion almost everyone does: there appear to be two sets of rules, two certificates, and two acronyms that look interchangeable but are not. The Hong Kong Convention talks about an ICIHM. The EU Ship Recycling Regulation talks about an Inventory Certificate and a Statement of Compliance. Are they the same thing? Do you need both?

This is the explainer that the broad IHM guides tend to skip. Here is how the two regimes relate — and what it means for a yacht that may be in scope of both.

Start with the inventory, not the certificate

The most useful thing to understand first: both regimes are built on the same underlying document — the Inventory of Hazardous Materials itself. Part I (materials in structure and equipment), Part II (operational waste), and Part III (stores) are structured the same way under both. The technical reference both lean on is the 2023 IHM Guidelines, IMO resolution MEPC.379(80).

So the certificate is the output. The inventory is the thing. A yacht that maintains one well-kept Part I inventory is most of the way to satisfying either regime. The differences are in who issues which document, and when.

The EU SRR route — the older of the two

The EU Ship Recycling Regulation (Regulation 1257/2013) has applied to EU-flagged vessels of 500 GT and above since 31 December 2020, and to large commercial ships before that. It also reaches non-EU-flagged vessels of 500 GT and above that call at EU ports.

Under the EU SRR, an in-scope vessel carries:

• An Inventory of Hazardous Materials (the Part I/II/III document), and
• A certificate confirming it — an Inventory Certificate for EU-flagged ships, or a Statement of Compliance for non-EU-flagged ships calling at EU ports.

For a Mediterranean-based yacht that regularly calls at ports in France, Italy, Spain, or Greece, the EU SRR has been the operative regime for several years — well before the global Convention arrived.

The HKC route — now global

The Hong Kong International Convention entered into force on 26 June 2025. It extends the same essential obligation worldwide: ships of 500 GT and above on international voyages carry a certified, maintained IHM, regardless of flag.

Under the HKC, the operative document is the International Certificate on the Inventory of Hazardous Materials (ICIHM), issued by your flag State administration or an authorised Recognised Organisation — in practice, usually your class society.

We cover what the Convention coming into force changed in our HKC briefing.

So do you need both?

This is where it pays to talk to your flag State and class society, because the answer depends on your specific flag and trading pattern. But the structural picture is reassuring:

• The inventory is shared. You do not maintain two separate Part I documents.
• Where a yacht is in scope of both — for example, a non-EU-flagged yacht that trades into EU ports and is also on international voyages under the HKC — the certificates are issued against the same underlying inventory.
• The IMO and the EU have worked toward harmonisation precisely so that compliance with one is, in practice, close to compliance with the other. The EU has moved to align its regime with the Convention now that the HKC is in force.

In other words: maintain the inventory properly, and the certification question becomes an administrative one for your class society to resolve, not a second compliance programme to run.

A worked example

Consider a 52 m yacht, 650 GT, Cayman Islands flag, classed with Lloyd’s Register, based in Antibes and cruising the western Mediterranean each season.

• HKC: In scope — over 500 GT, on international voyages. Needs an ICIHM, issued via the flag administration / class society.
• EU SRR: In scope as a non-EU-flagged vessel calling at EU ports — needs a Statement of Compliance.
• The inventory: One Part I/II/III document underpins both certificates. Maintained once, presented to whichever inspector asks.

The crew’s job is not to run two systems. It is to keep one inventory current — and to know which certificate is presented in which port.

What this means for how you keep records

Because the inventory is shared and the certificates are issued against it, the practical priority is the same under either regime: keep Part I current, hold the supporting documentation, and track the certificate dates. A change at a refit updates the inventory once; both certificates inherit that update at the next survey.

This is exactly the case for keeping the inventory in a structured workspace rather than as a static document drafted once and filed. The certificate any given port asks for may differ; the discipline behind it does not.

If you are still working out whether your yacht is in scope of one regime, both, or neither, our IHM applicability checker walks through flag, tonnage, build year, and EU port calls — and our complete guide to IHM for superyachts sets out the full picture.

MANTIS is IHM compliance management software for superyachts. It keeps Part I/II/III records and supporting documentation current, tracks certificate expiry and survey intervals across both the HKC and EU SRR regimes, and generates survey-pack PDFs for class society review. Start free beta →