The Hong Cong Convention will enter into force soon

’The Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships, 2009’ will enter into force on 26th June 2025.

This article explains the content and requirements of the Convention.

１．The Hong Kong Convention

The Hong Cong Convention, ’The Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships, 2009’ was adopted in 2009 to protect human health, safety and the environment when dismantling and recycling ships. The Convention will enter into force on 26 June 2025, having fulfilled the requirements for entry into force in 2023. The ships covered are those of 500GT or more.

２．Requirement to shipowner

Requirement to shipowner is below;

• Each ship of 500 GT and above shall have a certified Inventory of Hazardous Materials (IHM)
• Ship Recycling Facilities (SRF) shall be authorized by their competent authorities and shall only accept ships that comply with the HKC requirements

３． Inventory of Hazardous Materials (IHM) 

An IHM is a list that lists the location and quantity of hazardous substances (e.g. asbestos) present on a ship. It is common for existing ships to have an IHM prepared by a specialist.

４．Timeflame

New Ship：Ships for which a construction contract is concluded after the entry into force of the Convention (after 26 May 2026) will be equipped with IHMs at the time of delivery.

Existing Ship：An IHM must be prepared and in compliance with the Regulations within five years of the entry into force of the Convention (by 26 June 2030) or when the vessel is to be decommissioned, whichever is earlier. Please note, however, that Liberian-flagged vessels are required to have an IHM prepared and hold an international certificate by the 26 June 2025.

５．Procedure to receive International Certificate on IHM

The procedure for bringing an existing vessel into compliance with the Convention is generally as follows

• Shipowner or shipmanager request expert to make IHM
• IHM is prepared by an expert (at this time, it is common for the expert to visit the ship, conduct a survey, and take samples)
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• The RO (class) approves the IHM and issues an Interim SOC (Statement of compliance) or SOC.
• Flag administration issue International Certificate on IHM based on the SOC.

The details of the procedure vary depending on the ship's registry, so please contact the RO or the competent authorities for details. Please note that Panama has not yet been notified regarding the issuance of International Certificates

６．Relation between Hong Cong Convention and EU regulation

EU has already put the EU Regulation on Ship Recycling into effect and in operation prior to the IMO. Even non-EU-flagged vessels are required to maintain IHMs from 2021 for vessels calling at EU ports, so that many vessels may already have IHMs.
The procedure to comply with the Ship Recycling Convention when a ship holds an IHM that complies with the EU Regulations and possesses a SOC varies depending on the ship's registry, so please contact your RO or flag for details.
In general, the EU Regulations have been developed to follow the Hong Cong Convention with respect to IHMs, so there is no need to create a new IHM.

７．References

Class NK Ship Recycle Convention

2023 GUIDELINES FOR THE DEVELOPMENT OF THE INVENTORY OF HAZARDOUS MATERIALS

Maintaining and updating part I of the Inventory during operations with the Hong Kong Convention

Compliance with the Hong Kong Convention For Liberian flagged vessels