Hong Kong Convention – Ship Recycling

C25025 | 28 April 2025

Notice to: Ship Owners / Managers/ Operators / Surveyors:

The Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships (the Hong Kong Convention), adopted on 15 May 2009 will enter into force on 26 June 2025. It aims to ensure that ships at the end of their operational lives are recycled safely and without posing unnecessary risks to human health and safety or the environment.

The Hong Kong Convention

The Hong Kong Convention places responsibilities and obligations, for all environmental and safety aspects relating to ship recycling, on all parties concerned:

• Shipowners,
• Shipbuilding yards,
• Ship recycling facilities,
• Flag States,
• Port States, and
• Recycling States.

The Convention addresses all the issues around ship recycling, including:

• the fact that ships sold for scrapping may contain environmentally hazardous substances such as asbestos, heavy metals, hydrocarbons, ozone-depleting substances and others;
• concerns about working and environmental conditions in many of the world’s ship recycling facilities.

Regulations in the Convention cover:

• the design, construction, operation and preparation of ships to facilitate safe and environmentally sound recycling, without compromising the safety and operational efficiency of ships;
• the operation of ship recycling facilities in a safe and environmentally sound manner; and
• the establishment of an appropriate enforcement mechanism for ship recycling, incorporating certification and reporting requirements.

An appendix to the Convention provides a list of hazardous materials, the installation or use of which is prohibited or restricted in shipyards, ship repair yards, and ships of Parties to the Convention.

Ship recycling yards will be required to provide a Ship Recycling Plan, specifying how each ship will be recycled, depending on its particulars and its inventory.

Inventory of Hazardous Materials (IHM)

Ships must have on board a ship-specific Inventory of Hazardous Materials, prepared and verified in line with IMO guidelines.

The inventory (IHM) consists of:

• Part I: Materials contained in the ship structure or equipment;
• Part II: Operationally generated wastes (Oil and waste remaining on board, etc.);
• Part III: Stores (Household electronics, etc.

IHM Part I

Part I of the inventory (IHM) for a new ship is developed by the shipbuilder at the time of construction. For existing ships, it may be developed with hazmat expert investigation and analysis, as an alternative to the new-ship method, where it is not feasible.

New ships are defined as ships:

1. for which the building contract is placed on or after the entry into force of the Convention on 26 June 2025; or
2. in the absence of a building contract, the keel of which is laid, or which is at a similar stage of construction on or after six months after the entry into force of the Convention (26 December 2025); or
3. the delivery of which is on or after 30 months after the entry into force of the Convention (26 December 2027). By the date of delivery of the ship Existing ship “Existing ship” means a ship which is not a new ship. Not later than five years after the entry into force of the Convention: 25 June 2030 or before going for recycling if this is earlier.

It is the responsibility of the shipowner to establish a system for the maintenance of Part I of the inventory (IHM) and to properly maintain and update it. Such a system should include:

1. designating a person as responsible for maintaining and updating the inventory (IHM);
2. establishing and supervising a system to ensure the necessary updating of the inventory (IHM) in the event of a new installation;
3. maintaining the inventory (IHM), including dates of changes or new deleted entries and the signature of the designated person; and
4. providing related documents as required for the survey or sale of the ship.

Deadlines

The deadline for providing new ships with the IHM Part 1 is by the date of delivery of the ship. The deadline for providing existing ships with the IHM Part 1 is not later than five years after the entry into force of the Convention: 25th June 2030, or before going for recycling if this is earlier.

IHM Part II & III

Parts II and III of the inventory (IHM) are to be developed by the shipowner before recycling. The shipowner completes the inventory (IHM) by adding Parts II and III to Part I.

Surveys

Surveys for compliance with the Hong Kong Convention should be harmonized with other statutory surveys.

Ships will be required to have:

• Initial Survey:
  The first survey before the ship is put into service, or the first survey for an existing ship before the International Certificate on Inventory of Hazardous Materials is issued. This survey verifies that Part I of the inventory (IHM) is per the requirements of the Convention. The International Certificate on Inventory of Hazardous Materials is issued once the survey has been completed.
• Renewal Survey:
  To be carried out at intervals not exceeding five years. This survey verifies that Part I of the inventory (IHM) complies with the requirements of the Convention. The International Certificate on Inventory of Hazardous Materials is issued once the survey has been completed.
• Additional Survey:
  This survey is carried out at the request of the shipowner after a change, replacement, or significant repair of the structure, equipment, systems, fittings, arrangements, and material. The survey is carried out such as to verify that a ship complies with the requirements of the Convention and Part I of the inventory (IHM) after such a change, replacement, or significant repair and that Part I of the inventory (IHM) has been updated accordingly. The International Certificate on Inventory of Hazardous Materials is endorsed once the survey has been completed.
• Final Survey:
  This survey is carried out before the ship is taken out of service and before the recycling of the ship has started. The main points to be verified are:
  • The inventory of hazardous materials – Parts I, II and III – meets the requirements of the Convention.
  • The ship recycling plan developed by the ship recycling facility complies with the requirements of the Convention and has been approved by the competent authority(ies), i.e., the recycling state(s).
  • The ship recycling facility(ies) where the ship is to be recycled holds a valid authorization per the Convention. The ship is issued with an International Ready for Recycling Certificate once the survey has been completed.
• Occasional Survey:
  The Convention does not define an occasional survey. However, ROs may carry out an occasional survey when there is a change of the name of the ship, flag administration, company, etc.

Guidelines to support Implementation

The following guidelines have been developed and adopted by IMO’s Marine Environment Protection Committee to assist States in the implementation and enforcement of the Convention’s technical standards:

• 2011 Guidelines for the Development of the Ship Recycling Plan, adopted by resolution MEPC.196(62);
• 2012 Guidelines for Safe and Environmentally Sound Ship Recycling, adopted by resolution MEPC.210(63);
• 2012 Guidelines for the Authorization of Ship Recycling Facilities, adopted by resolution MEPC.211(63);
• 2012 Guidelines for the survey and certification of ships under the Hong Kong Convention, adopted by resolution MEPC.222(64);and
• 2012 Guidelines for the inspection of ships under the Hong Kong Convention, adopted by resolution MEPC.223(64).
• 2023 Guidelines for the development of the Inventory of Hazardous Materials, adopted by resolution MEPC.379(80).

Regulation (EU) No 1257/2013 on Ship Recycling (EU-SRR)

Regulation (EU) No. 1257/2013 on Ship Recycling (EU-SRR), which came into effect in December 2013, applies controls to ships and ship recycling facilities based on the Hong Kong Convention.

Requirements such as the development of the inventory of hazardous materials (IHM) are applied:

• from December 31 2018, for EU flagged new ships,
• from December 31 2020, for EU flagged existing ships and
• from December 31 2020, for non-EU flagged ships calling at a port or anchorage of an EU member state.

For the IHM, new and existing EU flagged ships must comply with Article 5 of the Regulation, and non-EU flagged ships must comply with Article 12.

For non-EU flagged ships, a statement of compliance (SOC) is to be issued per Article 12.6 of the Regulation after verification of the IHM by the relevant authorities of a non-EU country whose flag the ship is flying or an organization authorized by them, per the national requirements. These documents are issued by, or on behalf of, the Flag state.

Act now

Ship Owners/ Managers/ Operators/ Surveyors are to take note of the contents of the relevant requirements of the Convention, and associated Guidelines, together with any Flag State procedures and be guided accordingly.