The Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships (the "Hong Kong Convention") will enter into force on 26 June 2025, introducing a globally standardized framework for ship recycling. The Convention aims to mitigate environmental and occupational risks by imposing statutory obligations on ships and ship recycling facilities. Bureau Veritas Marine & Offshore presents below a detailed overview of the key requirements.
Application of the Convention
The Hong Kong Convention is applicable to new and existing ships* of 500 gross tonnage (GT) and above engaged in international voyages. Furthermore, its scope extends to ship recycling facilities operating under the jurisdiction of a Party to the Convention.
*Refer to below definition of “new ship” and “existing ship”
Key Requirements for Ships & Recycling Facilities
The convention has distinct mandatory requirements for both ships and ship recycling facilities where the ships will be recycled:
Ships are required to:
Comply with ban/restriction for 4 Hazardous Materials listed in Appendix 1 of the Convention (i.e. Asbestos, ODS, PCB, AFS).
Develop and maintain an Inventory of Hazardous Materials (IHM) during the lifetime of the ship.
Be recycled at an authorized Ship Recycling Facility
Ship recycling facilities are required to:
be authorized by the Competent Authority of a Party in which they operate
prepare/adopt a Ship Recycling Facility Plan (SRFP)
Develop a ship-specific Ship Recycling Plan (SRP) before any recycling of a ship can take place
Implementation timeline for initial survey & Certification
The Convention differentiates between new and existing ships with respect to the implementation timeline for IHM compliance, survey and certification:
New ships shall have a reviewed IHM on board and hold a valid “International Certificate on Inventory of Hazardous Materials”.
An initial survey should be conducted before the ship is put in service, in line with regulation 10.1.1 of the Convention and para.3.1.1 of MEPC.222(64).
“New ship” means a ship (regulation 1.4):
.1 for which the building contract is placed on or after 26 June 2025 (entry into force of the Convention); 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 26 December 2025 (six months after entry into force of this Convention); or
.3 the delivery of which is on or after 26 December 2027(30 months after the entry into force of this Convention).
Existing ships shall have a reviewed IHM on board and hold a valid “International Certificate on Inventory of Hazardous Materials” not later than 26 June 2030 taking into account the 2012 Guidelines for the survey and certification of ships under the Hong Kong Convention (MEPC.222(64)).
Harmonization of surveys: Unless otherwise instructed by the flag initial survey for the existing ship shall be carried out at or before the renewal survey of other statutory certificates on or after 26 June 2026. The term of the certificate shall be harmonized with other statutory certificates in line with regulations 5.2 and 10.5 of the Convention and para.3.1.2 of MEPC.222(64).
“Existing ship” means a ship which is not a new ship (regulation 1.3).
The Central role of the Inventory of Hazardous Materials (IHM)
For Ships, a fundamental requirement is the Inventory of Hazardous Materials (IHM). Each ship falling within the Convention's scope is required to develop and maintain an IHM, which identifies and quantifies hazardous materials present in the ship's structure, equipment, and systems. This inventory serves as a critical informational tool for recycling facilities, facilitating the safe and environmentally sound management of hazardous substances during the recycling process. Prior to being recycled, ships are also required to undergo a Final Survey and be issued an "International Ready for Recycling Certificate".
The IHM is structured in three parts:
Part I – maintained throughout ship life
Parts II & III – developed at end-of life and prior to recycling
Development of Inventory of Hazardous Materials (IHM), Part I
The method for developing Part I of the Inventory of Hazardous Materials (IHM) differs based on whether the ship is classified as a new or existing ship .
• For new ships, the IHM shall be compiled during the design and construction phase using Material Declarations (MDs) and Supplier’s Declarations of Conformity (SDoCs) obtained directly from manufacturers and suppliers, ensuring comprehensive identification of hazardous materials listed in Appendices 1 and 2 to the Convention, as required under regulation 5.1 of the Convention.
• In contrast, for existing ships, the IHM shall be developed through a combination of document review and targeted Visual and/or Sampling Checks conducted onboard, due to the lack of original material declarations. In addition, these ships shall identify at least the hazardous materials contained in Appendix 1
These distinctions shall be recognized in the development, approval, and maintenance of the IHM in accordance with the Convention and the 2023 Guidelines for the development of the Inventory of Hazardous Materials (res. MEPC.379(80)) as amended by res. MEPC.405(83)
Survey and Certification of ships before recycling:
For a ship designated for recycling, the Hong Kong Convention mandates specific statutory requirements which conclude with the issuance of the “International Ready for Recycling Certificate” (IRfRC). Prior to its issuance, the ship must undergo a Final Survey. This survey is to verify that:
The ship's Inventory of Hazardous Materials (IHM) is fully completed, incorporating Part I, Part II (operationally generated hazardous wastes), and Part III (stores potentially containing hazardous materials).
A ship-specific Ship Recycling Plan (SRP), developed by an authorized ship recycling facility in conjunction with the shipowner, is established based on the completed IHM.
The selected ship recycling facility is authorized in accordance with the Convention's provisions.
The IRfRC, issued following a successful Final Survey, shall normally be valid for a period not exceeding three months, specifically to enable the ship's final voyage.
Interplay with UN Basel convention
The entry into force of the Hong Kong Convention necessitates a consideration of its relationship with the Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and their Disposal. Both international instruments address the management of hazardous materials, albeit with distinct focuses: the Basel Convention generally governs the transboundary movement of hazardous waste, while the Hong Kong Convention specifically regulates the safe and environmentally sound recycling of ships.
Pending finalization of discussions between the IMO and the Basel Convention, IMO approved the Provisional guidance on the implementation of the Hong Kong and Basel Conventions with respect to the transboundary movement of ships intended for recycling (HKSRC.2/Circ.1).