SHIP RECYCLING CONVENTION (THE HONG KONG CONVENTION)

We hereby draw the attention of all Ship Owners, Managers, Operators and Charterers to the fact that the Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships, 2009 has entered into force on 26 June 2025 and therefore the following requirements should be complied with as set out below.

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.

Regulations in the new Convention cover: the design, construction, operation and preparation of ships so as 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.

Ships to be sent for recycling will be required to carry an inventory of hazardous materials, which will be specific to each ship. 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. Ships will be required to have an initial survey to verify the inventory of hazardous materials, renewal surveys during the life of the ship, and a final survey prior to recycling.

Ship recycling yards will be required to provide a Ship Recycling Plan, to specify the manner in which each individual ship will be recycled, depending on its particulars and its inventory. Parties will be required to take effective measures to ensure that ship recycling facilities under their jurisdiction comply with the Convention.

The Hong Kong Convention applies to Member States’ flagged ships (of 500 GT and above) and recycling facilities operating under the jurisdiction of countries party to the Convention. A key instrument is the implementation of an Inventory of Hazardous Materials (IHM) determined in the Convention and approved by the flag State administration or a recognized organization. The IHM is to be maintained and updated throughout the life cycle of vessels.
The Hong Kong Convention applies to:
New ships of 500 GT and above: Must have an IHM onboard and be certified upon delivery.
"New ship" means a ship:
.1 for which the building contract is placed on or after the entry into force of this 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 six months after the entry into force of this Convention; or
.3 the delivery of which is on or after 30 months after the entry into force of this Convention.
Existing ships of 500 GT and above: Must develop and maintain an IHM no later than five years after the entry into force of the Convention (i.e., by 26 June 2030) or before going for recycling, whichever comes first. The initial and renewal surveys should be harmonized with the surveys required by other applicable statutory instruments.
Ships destined for recycling of 500 GT and above: Must have an IHM (including Parts I, II, and III) and a Ready for Recycling Statement of Compliance prior to recycling.

The Hong Kong Convention excludes ships of less than 500GT, vessels operating solely on domestic routes, as well as warships, military auxiliary vessels and other ships used for non-commercial government service.

The IHM shall be ship specific and developed in accordance with MEPC.269(68) and shall be verified by a Recognized Organization (RO) as per the requirements of relevant resolutions and regulations. The official language to be used should be English. The Inventory shall consist of 3 parts as follows:

a. Part I: List of hazardous materials contained in ship structure or equipment, their location and approximate quantities and referred to the Appendices 1 and 2 of the Convention. This part needs to be properly maintained and updated throughout the operational ship’s life, reflecting new installations containing Hazardous Materials listed in Appendix 2 and relevant changes in ship structure and equipment.
b. Part II: List of operationally generated wastes onboard; this part is to be incorporated in the Inventory prior to recycling.
c. Part III: Stores; this part is to be incorporated in the Inventory prior to recycling.

Compliance with the Convention will be monitored via surveys and the presence on board of a valid International Certificate on the List of Hazardous Materials issued on the initial survey of the ship. Thereafter, the renewal survey must confirm that Part I of the IHM complies with the provisions of regulations 5 of the Annex to the Hong Kong Convention as amended. Prior to the vessel’s disposal, a final survey is to be carried out and an International Certificate of Readiness for Disposal issued.
Ship recycling facilities in the jurisdiction of State Parties are to be authorized by competent national authorities and are required to dispose of ships in line with the requirements of the Convention. Certified recycling facilities operating under a Ship Recycling Facility Plan are to develop individual Ship Recycling Plans tailored for each vessel in accordance to their IHM.
The status of this and other IMO conventions can be found on official IMO resources.
Please note that documents confirming a vessel's compliance with the Hong Kong Convention do not replace the documents required by Regulation (EU) No. 1257/2013 on Ship Recycling (EU-SRR). EU-flagged ships or other vessels calling at ports or anchorages of EU member states must ensure compliance with the requirements of the EU-SRR and have relevant supporting documents.

SING-LLOYD, as the Recognized Organization of for relevant Flag Administrations, is authorized to carry out the verification of IHM and issue the Statement(s) of Compliance.

References:
Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships, 2009 – The Hong Kong Convention
Resolution MEPC.269(68) - 2015, Guidelines for the Development of the Inventory of Hazardous Materials
Resolution MEPC.196(62) – 2011 Guidelines for the Development of the Ship Recycling Plan
Resolution MEPC.211(63) – 2012 Guidelines for the Authorization of Ship Recycling Facilities
Resolution MEPC.222(64) – 2012 Guidelines for the Survey and Certification of Ships under the Hong Kong Convention.