The Hong Kong Convention (HKC) – Safe & Environmentally Sound Ship Recycling

Background

The IMO adopted the Hong Kong Convention in 2009 to address unsafe and polluting ship recycling practices.

The Convention enters into force on 26 June 2025, 24 months after ratification thresholds were met.

Due to delayed ratification, the EU Ship Recycling Regulation (EU SRR) was introduced in 2013 and has been fully applicable since 31 December 2020, preparing the industry for HKC alignment.

• ~30,000 ships are already certified under the EU SRR.
• An estimated ~23,000 vessels still need IHM certification in line with HKC requirements.

Key Requirements

1. All vessels ≥ 500 GT:

• Must carry an International Certificate on Inventory of Hazardous Materials (ICIHM) if flying the flag of a Party to the Convention.
• Ships flying non-Party flags must carry a Statement of Compliance on IHM (SoC IHM) when entering HKC Party jurisdictions.

2. Ship Recycling Facilities (SRFs):

• Must be authorized by competent authorities.
• May only accept ships that are compliant with HKC.

HKC vs EU Ship Recycling Regulation (EU SRR)

✅ Both require a certified IHM and authorized SRFs

Compliance Timeline

Impact on Ship Operators

Operators must develop and maintain a certified Inventory of Hazardous Materials (IHM) throughout the ship's operational life:

• Part 1: Structure and equipment
• Part 2: Operationally generated waste (before recycling)
• Part 3: Stores and consumables (before recycling)

IHM Part I must be:

• Kept up to date
• Reflect changes due to repairs, retrofits, or material replacements

Updates are required when:

• A component with hazardous materials is added or removed
• Structural or equipment changes occur (e.g., ballast water retrofit, engine upgrades)

📌 Responsibility for maintaining and updating IHM lies with the ship operator/ISM Company.

Additional Considerations

• Ships compliant with EU SRR and holding a SoC with HKC can convert to ICIHM if their flag is a Convention Party — mostly a paperwork process.
• Ships with EU SRR compliance but no HK SoC must obtain certification.
• Under HKC, only the Recognized Organization (RO) responsible for statutory certification may issue ICIHM due to survey harmonization.

Impact on Ship Recycling Facilities

• ~1,500 ships/year will need dismantling in the next decade (BIMCO).

• Facilities must obtain a Document of Authorization for Ship Recycling (DASR) — valid for up to 5 years.

• Each facility must prepare a Ship Recycling Facility Plan (SRFP) including:

  • Environmental and safety policies
  • Worker training systems
  • Emergency preparedness
  • Emissions, incident, and health reporting mechanisms

Next Steps for Stakeholders

✔ Verify flag state participation in HKC
✔ Check each vessel’s IHM certification status
✔ Coordinate with your RO for HKC compliance

Need Help?

NAVIREGO supports shipowners, managers, and yards in:

• Preparing or converting ICIHM and SoC documentation
• Verifying compliance pathways
• Understanding requirements across HKC and EU SRR

Contact us to discuss your fleet's compliance roadmap.