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.

l      ~30,000 ships are already certified under the EU SRR.

l      An estimated ~23,000 vessels still need IHM certification in line with HKC requirements.

APPLICABILITY

l      Ships more than 500 gross tonnage

l      Ships flying with the flag of a Party

l      Ships flying with the flag of a non-Party operating under Party’s authority

l      Ship Recycling Facilities (SRFs) operating under Party's jurisdiction

Impact on Ship Operators

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

Part I: Structure and equipment

Part II: Operationally generated waste (before recycling)

Part III: Stores and consumables (before recycling)

IHM Part I must be:

l      Kept up to date

l      Reflect changes due to repairs, retrofits, or material replacements

IHM Maintenance are required:

In accordance with the citation from MEPC.379(80) sections 4.3.1 and 4.3.3, it is essential that the IHM Part I is properly maintained and updated. This includes ensuring the continuity of the Inventory, particularly in relation to the name, flag, and shipowner, which should reflect the most current particulars of the ship.

Shipowners are required to develop an IHM Maintenance procedure and/or manual that is incorporated into the shipowner’s safety management system. Additionally, they must designate an individual responsible for IHM Maintenance, commonly referred to as the IHM Designated Person (IHM DP). The standard procedure for maintaining the Inventory involves gathering a Material Declaration (MD) and a Supplier Declaration of Conformity (SoC) for items suspected of containing hazardous materials supplied to the ship[1] for new installations and repair activities. An indicative list of suspected items is available in the MEPC.379(80) guidelines.

If a hazardous material is identified above the designated threshold values in a product, the IHM DP is required to update the Inventory and issue a new revision that includes the date and revision number. The IHM DP must also document the activities performed in a change log.

To effectively manage IHM Maintenance, which is centralized, fully digitalized, and meticulously maintained, ship owners or managers may engage the services of a reliable third-party service provider. This provider will manage all administrative aspects of IHM Maintenance at either a vessel or fleet level.

During the IHM renewal survey, in accordance with Regulation 10.1.2, the survey must confirm that Part I of the IHM meets the convention's requirements. This necessitates that both the shipowner and the ship ensure the Inventory is properly maintained to prevent any deficiencies from being identified during the survey.