Why maintaining IHM compliance is harder than getting certified
When the Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships (HKC) entered force in June 2025, it extended earlier requirements like the EU Ship Recycling Regulation (EU SRR) to cover virtually every vessel trading internationally. Every ship must now maintain an up-to-date Inventory of Hazardous Materials (IHM Part I) throughout its operational life, not just at the moment of certification.
Most owners already hold their certificates. The challenge is to keep them valid while managing day-to-day procurement across fleets, suppliers, and ports.
On paper, the process sounds simple: tag hazardous items, collect the correct Material Declarations (MDs) and Supplier Declarations of Conformity (SDoCs), and stay audit-ready. In reality, it’s rarely that straightforward.
I’ve seen procurement teams burn countless hours chasing suppliers, matching certificates to orders, and reconciling spreadsheets. One seven-vessel fleet we worked with estimated they had been spending more than 4,000 hours per year purely on IHM administration.
Where traditional workflows go wrong
The real problem isn’t intent, it’s timing. Procurement teams need to keep vessels running, so orders go out first and compliance catches up later. By then, the supplier has delivered and moved on.
At that point, the leverage is gone. The supplier has delivered, been paid, and moved on to the next job. Their incentive to chase down or complete documentation is minimal. That’s why teams end up spending weeks following up, sending reminders, and escalating through multiple layers just to collect a few missing certificates.
The result is predictable: growing backlogs, inconsistent supplier engagement, and surveyors finding gaps when they test documentation trails.
Learn more about IHM as a Service
See how Marcura helps shipowners simplify IHM Part I maintenance and stay audit-ready under the Hong Kong Convention 2025.
When to tag and when not to isn’t always clear
Over-tagging and under-tagging make things worse. Different class societies interpret requirements in slightly different ways, and the regulation itself leaves room for judgement.
Faced with uncertainty, some teams over-tag everything to stay on the safe side, overwhelming suppliers with requests that don’t all apply. Others tag too little and risk non-conformities when surveyors check documentation. Without shared intelligence on how similar items have been classified before, every team ends up reinventing the wheel.
How compliance by design removes these bottlenecks
The vast majority of IHM problems aren’t born out of negligence. Instead, they come from process design where compliance is treated as a bolt-on.
That’s why we built IHM as a Service around a simple idea: make compliance part of procurement from the start, not a bolt-on afterwards. The way this works is based around five core principles:
Flagging hazards early changes behaviour. AI scans RFQ (request for quote) and purchase orders to highlight line items likely to contain hazardous materials. Both buyer and supplier see those flags before quoting. That early visibility changes behaviour: suppliers prepare documentation sooner, and buyers understand compliance risks before they commit.
Automation replaces follow-ups, not judgment. Once an order is placed, the platform automatically requests documentation, tracks responses, and sends reminders. Hundreds of back-and-forth emails disappear. Procurement teams can focus on quality and accuracy instead of chasing paperwork.
Expert oversight where it matters. Automation handles volume; expertise handles nuance. Our Control Tower team - compliance specialists trained in classification-society standards - reviews ambiguous items, approves supplier reclassifications, and validates anomalies. Their feedback trains the system’s machine-learning model, improving tagging accuracy with every transaction.
Making life easier for suppliers. Suppliers often tell us their biggest frustration is recreating the same forms for repeat orders. That’s something we’re addressing. We’ve made it easy for suppliers to access reuse existing certificates, so they don’t have to start from scratch. And we’ll soon introduce the ability to generate new ones using pre-filled MD/SDoC templates.
Shared transparency that removes uncertainty. Procurement teams, vessel crews, and managers share the same dashboards showing which orders are complete, which documents are pending, and which suppliers regularly deliver on time. If a Port State Control surveyor boards, crews can access every certificate from the cloud within seconds.
Together, these steps turn what used to be a reactive, manual process into a predictable, transparent workflow. The result: fewer admin hours, faster turnaround, stronger supplier accountability, and confidence that every order and vessel can stand up to inspection.
The wider value of a structured data foundation
IHM compliance may be the current requirement, but the same data framework will support the next generation of maritime regulation. Every product transacted through ShipServ carries structured attributes—its IHM status, documentation completeness, and supplier reliability.
Because that structure is flexible, it can easily expand to cover Scope 3 emissions or future environmental metrics. In other words, solving today’s compliance burden also builds the foundation for smarter, data-driven sustainability management tomorrow.
Lessons learned from implementation
Across fleets already using IHM as a Service, three lessons keep surfacing:
Clarity drives efficiency. When everyone understands exactly which items require documentation, administrative hours fall dramatically.
Consistency builds trust. Suppliers engage more willingly when every request follows the same predictable pattern.
Confidence replaces anxiety. Procurement, crews, and managers all operate from a single, auditable record. No surprises during inspection.
A good example is d’Amico Group, which manages a fleet of more than 70 vessels from Rome, Mumbai, and Singapore. Facing mounting regulatory complexity, they digitised their IHM and supplier-vetting workflows using ShipServ.
Procurement teams now capture documentation early in the RFQ process, standardise categories, and maintain full visibility across suppliers and fleets, all within one platform.
Practical next steps for shipowners
If your organisation still relies on manual follow-ups and disconnected records, start by asking three questions:
Can we produce an audit-ready IHM report for any vessel, at any time?
Are hazardous materials identified before each order is placed?
Do our suppliers clearly understand what documentation is required, and when?
If any answer is “not always,” it may be time to rethink the process.
The vast majority of IHM problems aren’t born out of negligence. Instead, they come from process design where compliance is treated as a bolt-on.
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