FAQ

IHM questions, answered

What the regulations require for regulated vessels — and how MANTIS helps you keep on top of it.

IHM basics

What is an Inventory of Hazardous Materials (IHM)?
An IHM is a ship-specific record of hazardous materials. Part I identifies relevant materials in the ship's structure and equipment and is maintained throughout its operational life. Part II covers operationally generated waste and Part III covers stores; Parts II and III are completed when the ship is prepared for recycling.
Why does the IHM matter?
The Hong Kong Convention and EU Ship Recycling Regulation require an IHM for ships within their respective scope. Both use 500 GT as a threshold, but flag, operating area, port calls, ship use and specific exclusions also matter. The IHM supports hazardous-material control, certification, inspection and safer recycling.
What regulations does MANTIS cover?
MANTIS is structured around the Hong Kong Convention, EU Regulation 1257/2013 and the 2023 IMO IHM Guidelines (MEPC.379(80)), including the 2025 amendment in MEPC.405(83). It helps operators organise the record; it does not determine scope, verify an IHM or issue certificates.

Do I need one?

Which vessels need an IHM?
The Hong Kong Convention generally applies to ships of 500 GT and above flying the flag of a Party, subject to exclusions including warships, government non-commercial ships and ships operating throughout their life only in the waters of their flag State. Non-party ships may face equivalent checks in Party ports. The EU SRR separately covers EU-flagged ships and third-country ships calling at EU ports or anchorages, subject to its scope and exclusions.
I'm not EU-flagged — why does the EU regulation apply to me?
Article 12 of the EU SRR applies to third-country ships calling at an EU port or anchorage, subject to the Regulation's scope and exclusions. An in-scope ship carries an IHM and a Statement of Compliance issued or endorsed by the relevant third-country authority or an organisation it authorises. HKC certification is a separate question.
Does vessel use change IHM scope?
Yes. Gross tonnage is only one factor. Flag, commercial or government use, operating area and port calls also matter. The HKC excludes warships, government non-commercial ships, ships below 500 GT and ships operating throughout their life only in waters under their flag State's jurisdiction. Confirm the specific case with the flag administration or its authorised recognised organisation.
What are the deadlines?
The EU SRR onboard-compliance date for existing ships was 31 December 2020 and is already in force. Under the Hong Kong Convention, new ships within scope have required an ICIHM since 26 June 2025. Existing ships within scope must comply no later than 26 June 2030, or before going for recycling if that happens earlier. IMO guidance says the initial IHM survey for an existing ship should be harmonised with other applicable statutory renewal surveys, but the first renewal survey after June 2025 is not a universal compliance deadline.
We're building a new vessel — when does the IHM start?
For a new ship within scope, Part I is developed during design and construction using Material Declarations and Supplier's Declarations of Conformity from the supply chain. It is verified by an initial survey before the ship enters service. “New ship” is a defined Convention category, so confirm the project's status and certification route with the flag administration or its authorised recognised organisation.
Our existing vessel has no IHM yet — what now?
Part I for an existing ship is developed through five steps: collect available information, assess it, prepare a visual or sampling check plan, complete the onboard checks, and prepare Part I with its supporting documentation. The shipowner may use expert help, but the verifying administration or recognised organisation must remain independent.

What's in an IHM

What's the difference between Part I, II and III?
Part I lists hazardous materials in the ship's structure and equipment and is maintained throughout the vessel's life. Part II covers operationally generated wastes and Part III covers stores — both are only compiled when a decision to recycle is taken. In service, Part I is the focus.
What are Table A and Table B materials?
Table A contains materials controlled under the Hong Kong Convention, including asbestos, PCBs, ozone-depleting substances and specified anti-fouling systems. Table B contains additional materials recorded in Part I when present above the applicable threshold. The authoritative lists and thresholds are in MEPC.379(80), as amended.
Do I need to maintain Part II and Part III now?
No — Parts II and III are only compiled when you decide to recycle the vessel. During the operational life, Part I is what you keep current. MANTIS lets you hide Part II and III per vessel if you don't track them, and switch them back on later.

Surveys & certificates

Will I get a certificate or a Statement of Compliance?
The document depends on flag and regime. The HKC uses an ICIHM. The EU SRR uses an Inventory Certificate for EU-flagged ships and a Statement of Compliance for in-scope third-country ships. Since 2026, the EU Inventory Certificate format can also serve under the HKC where both apply; this does not replace the third-country Statement of Compliance route. Compare the routes →
Who issues the certificate?
An HKC ICIHM is issued by the flag administration or a person or organisation it authorises after successful survey. Under the EU SRR, the administration or its recognised organisation issues an Inventory Certificate; the relevant third-country authority or an organisation it authorises issues or endorses a Statement of Compliance.
How often is the IHM certificate renewed?
Under the HKC and EU SRR, the administration specifies the renewal-survey interval, which must not exceed five years. Part I must still be maintained between surveys as relevant changes occur. Survey timing may be harmonised with other statutory surveys, but the applicable authority confirms the schedule. Preparing for renewal →
What happens during the survey?
The initial survey verifies that Part I and its supporting documentation meet the applicable requirements and are consistent with the ship. For an existing ship, document assessment and the planned visual or sampling checks are completed while developing Part I; the authorised surveyor then verifies the resulting inventory. Renewal surveys verify that Part I remains compliant.
How long does the survey take?
It varies with the vessel's size, age and how complete the existing documentation is — there's no fixed figure, and a vessel with good build records and a current Part I is quicker than one reconstructed from scratch. Your class society or IHM provider will scope it.

Keeping it current

Who is responsible for keeping the IHM up to date?
The shipowner must ensure Part I is maintained during the ship's operational life. IMO guidance recommends designating a responsible person, establishing a system for new installations, recording dated changes and retaining supporting documents for survey or sale. MANTIS records that work; formal verification and certification remain with the relevant authority.
What are Material Declarations (MD) and Supplier's Declarations of Conformity (SDoC)?
A Material Declaration states whether Table A or B materials are present in a supplied product above the applicable thresholds and, where present, their mass. The related Supplier's Declaration of Conformity provides assurance that the MD contains the required information and identifies the responsible supplier entity.
Do I need an MD/SDoC even if a product has no hazardous materials?
For products covered by the supplier-declaration process, the MD records both positive and negative declarations — whether Table A or B materials are present above threshold. A negative declaration is therefore useful evidence. The process does not apply indiscriminately to every consumable or chemical that will not form part of the finished product.
We replaced a part with an identical one — do we update the IHM?
The IMO Guidelines say Part I does not need to be updated when identical parts or coatings are installed or applied. Keep the procurement and supporting evidence required by the ship's maintenance procedure. A non-identical addition, removal, replacement or coating renewal must be assessed under the new-installation process and Part I updated where required.
What about a refit?
During a refit, assess machinery, equipment and coating additions, removals and replacements under the IHM new-installation process. Obtain the relevant MDs and SDoCs through the supply chain, retain the evidence and update Part I where required. Identical parts and coatings do not require a Part I update. The refit briefing →
What triggers an IHM update?
Part I should be reviewed when machinery or equipment is added, removed or replaced, when hull coating is renewed, and after repair or conversion. It is updated under the new-installation rules unless identical parts or coatings are used. If flag, owner or operator changes, continuity and conformity of Part I should also be confirmed.

Inspections & enforcement

Is a missing IHM update a detainable deficiency?
IMO inspection guidance says failure to update the IHM should not by itself constitute a detainable deficiency, but inconsistencies should be reported to the flag administration and corrected by the next survey. Failure to carry a required valid certificate or serious non-compliance with hazardous-material controls may warrant detention.
How does Port State Control inspect the IHM?
An initial Port State Control inspection checks the required certificate or equivalent documentation, the accompanying IHM and previous inspection reports. If there are clear grounds — such as missing, invalid or visibly inconsistent documents — the officer may conduct a more detailed inspection of hazardous-material controls and Part I. What PSC checks →
What happens if I miss the deadline or don't comply?
That's a matter for your flag administration and Port State Control, and consequences vary by jurisdiction — from findings to be rectified through to more serious enforcement where a required certificate is absent. The practical answer is to keep the IHM current so it never becomes an issue.
How much does an IHM cost?
Initial IHM creation depends on vessel size, age, and record quality, so your class society or IHM service provider should quote that work. MANTIS is self-serve software for maintaining the live record after setup: €59 per vessel per month or €590 per vessel per year. See pricing.

Using MANTIS

Can I import an existing IHM from Excel?
Yes. Part I supports bulk import from Excel using a standard column mapping, which is the quickest route if you're moving from an existing IHM document. Part II and III can be entered manually. Optional onboarding is available when an old record needs cleanup.
How does the survey pack work?
When you compose a survey pack, MANTIS lets you pick what to include — Part I inventory, certificate status, change log and more — with your adopted Maintenance Plan as the lead document. It assembles from the records you've kept current, ordered the way surveyors expect.
How does MANTIS handle supplier evidence?
MANTIS lets you keep supplier records, reuse supplier details in document requests, and send secure no-login upload links for MDs, SDoCs, SDSs, and supporting files. Delivered documents stay attached to the vessel context and supplier history, so evidence is not buried in email threads.
Is MANTIS a managed IHM service?
No. MANTIS is self-serve IHM software. Your crew, DP, superintendent, or manager keeps the live record current, while class, flag, and chosen specialists handle formal surveys, certification, sampling, and compliance decisions.
Why is MANTIS cheaper than managed IHM providers?
Managed providers price for expert staff doing the maintenance work for you. MANTIS prices as software because your team owns the day-to-day updates. That keeps the cost lower while preserving exportable evidence for class or specialist review.
How does the Maintenance Plan work?
The Maintenance Plan is your governing IHM document. Upload an existing one as a PDF, or generate a vessel-specific manual from your live data. To adopt a version, you confirm your Designated Person has reviewed it; MANTIS records who and when, and locks it. Later material changes flag it for regeneration.
Can multiple crew members access the same vessel?
Yes. You can invite people as owner, admin, member, or read-only viewer. Read-only is enforced at the database layer, not just hidden in the interface — so you can safely give a class surveyor or auditor view access with no risk they change anything.
We don't track Part II or Part III — can we hide them?
Yes. A per-vessel setting hides Part II (operational waste) or Part III (stores) across the inventory tabs, dashboard and survey pack. Nothing is deleted — it's display-only — so you can switch them back on at any time.
Can I manage multiple vessels from one account?
Yes. Fleet plans support multiple vessels under one organisation account with a shared dashboard. Owned and shared vessels are distinguished in the app, and each vessel's data is isolated — crew only see the vessels they're invited to.
Is my data stored in the EU?
Yes — your IHM and account data are stored in the EU (AWS Frankfurt), and our application sub-processors (email, error monitoring, product analytics) are EU-based. The one exception is Microsoft Clarity on our marketing site, which loads only if you consent and is processed by Microsoft in the US under the EU–US Data Privacy Framework. See the Privacy Policy.
What happens to my data if I leave?
You can request a full archive export or deletion of your data from Settings, and we'll confirm when it's done. Full archives are designed to include structured records and uploaded evidence documents. Commercial cancellation terms are handled in your vessel or fleet agreement. Our full retention terms are set out in the Privacy Policy.
Does MANTIS integrate with other vessel management systems?
Not yet. Custom integrations can be discussed for fleet customers — contact us to discuss your requirements.

Still have questions? info@mantis-ihm.com