The Hong Kong Convention Enters into Force on 26 June 2025: A New Era in Ship Recycling

A significant international regulation concerning environmental protection and human health in the maritime sector will enter into force on 26 June 2025. The Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships (hereinafter the “Hong Kong Convention” or “HKC”), adopted by the International Maritime Organization (IMO) on 15 May 2009, aims to ensure that ships reaching the end of their operational life are recycled in a manner that does not pose risks to human health or the environment.

The Convention reached its entry-into-force criteria in 2023, having been ratified by at least 15 States, representing more than 40% of the world’s merchant fleet by gross tonnage, and having a combined ship recycling capacity of no less than 3%.

Purpose and Scope of the Convention

The primary objective of the Hong Kong Convention is to minimize the risks posed by hazardous wastes generated during the ship recycling process. To achieve this, the Convention establishes international standards in the following areas:

• Establishment and operation of ship recycling facilities

• Control and management of hazardous materials

• Occupational health and safety measures, emergency preparedness, and reporting mechanisms

• Certification and inspection requirements

The Convention applies to all new and existing ships of 500 gross tonnage and above engaged in international voyages. This includes submarines, floating platforms, Floating Storage Units (FSUs), Floating Production Storage and Offloading Units (FPSOs), and other similar maritime vessels. However, warships, naval auxiliary vessels, and government-operated non-commercial ships are excluded from the scope.

Classification of New and Existing Ships

According to the Convention:

Ships are considered "new" if:

• The construction contract was signed on or after 26 June 2025

• In the absence of a contract, the keel was laid on or after 26 December 2025

• The delivery date is on or after 26 December 2027

All ships not meeting these criteria are classified as existing ships and are subject to a transitional compliance period.

Key Obligations Introduced by the Convention

1. Inventory of Hazardous Materials (IHM)

Both new and existing ships are required to prepare and maintain an Inventory of Hazardous Materials (IHM) that identifies the type, quantity, and location of hazardous substances onboard. The IHM consists of:

• Part I – Hazardous materials contained in the ship's structure and equipment

• Part II – Operationally generated waste

• Part III – Stores

  
  

  New ships: Must be delivered with a valid IHM and a Hong Kong Ship Recycling Certificate (HKSRC) by 26 June 2025

  Existing ships: Must have a valid IHM and relevant certification no later than 26 June 2030

  
  

2. Ship Recycling Certificates

Documents required during the recycling process include:

• International Ready for Recycling Certificate (IRRC) – Issued following the final survey prior to the commencement of recycling

• Document of Authorization for Ship Recycling (DASR) – Granted to authorized ship recycling facilities by national authorities

  
  

3. Authorized Ship Recycling Facilities

Ship recycling operations must be conducted at authorized facilities that comply with IMO guidelines and national regulations. Facilities must submit a Ship Recycling Facility Plan that addresses:

• Worker safety and training

• Emergency response plans

• Hazardous material management

• Monitoring and reporting procedures

Implementation and Inspection

The Convention is supported by detailed IMO guidance and technical documentation. Compliance is assessed through:

• Verification of the ship’s IHM and relevant certificates

• Inspections to ensure adherence to recycling standards

• On-site audits of ship recycling facilities

  
  

Interaction with the Basel Convention

Due to the overlap with the Basel Convention on the Control of Transboundary Movements of Hazardous Wastes, the IMO has issued HKSRC.2/Circ.1, providing provisional guidance to ensure alignment and avoid regulatory conflict when ships are transported across borders for recycling.

Conclusion

The Hong Kong Convention introduces a universal legal framework for sustainable and safe ship recycling. Shipbuilders, shipowners, port authorities, and recycling yards must ensure full compliance with the Convention's requirements by its entry into force in June 2025. Failure to comply may result in regulatory, commercial, and reputational consequences.

It is therefore essential for all stakeholders in the maritime industry to begin preparations without delay.