Technical Notices

Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships (HKC) will finally enter into force on 26 June 2025 after ratification by Bangladesh and Liberia. The HKC is expected to have a significant global impact on ship recycling practices.

The long time needed for ratification of the HKC has caused the EU to take action, resulting in the EU Ship Recycling Regulation (EU SRR), which entered into force on 30 December 2013 and has been fully applicable since 31 December 2020. The EU SRR adopted the requirements of the HKC as well as some additional requirements. Although the EU SRR is only applicable on a regional level, it has prepared the industry for compliance with the HKC requirements.

The key requirements can be summarized in two main points:

1. Each ship of 500 GT and above shall have a certified Inventory of Hazardous Materials (IHM)

1. Ship Recycling Facilities (SRF) shall be authorized by their competent authorities and shall only accept ships that comply with the HKC requirements

| Application

• Ships in service shall comply with this requirement by 26 June 2030 or before going to recycling if this is earlier.
• New ships shall comply with this requirement by the date of delivery of the ship

 | Maintenance of the IHM

The maintenance of the IHM in case of any changes in the ship’s structure or equipment will become more important with the entry into force of the HKC, as Port State Control is expected to focus on IHM inspections globally.

Shipowners should implement the following measures in order to ensure the conformity of Part I of the inventory (IHM):

1. To designate a person as responsible for maintaining and updating the inventory (IHM) (i.e. to assign the designate person on procedural manual);
2. The designated person should establish and supervise a system to ensure the necessary updating of the inventory (IHM) in the event of new installation (i.e. to draw up a procedural manual);
3. To maintain the inventory (IHM) including dates of changes or new deleted entries and the signature of the designated person; and
4. To provide related documents as required for the survey or sale of the ship.

| Ship Recycling Facilities (SRF)

The impact on Ship Recycling Facilities (SRF) is expected to be significant.

Each party to the HKC shall establish a mechanism for authorizing SRFs to ensure that such SRFs meet the requirements of the HKC.

Such an authorization is called a Document of Authorization Ship Recycling (DASR) and will be valid for a maximum of 5 years. Authorized SRFs shall only accept ships that comply with HKC, which they are authorized to recycle.

| Surveys and certification

The kind of survey and certification required for a ship are listed below

Initial Survey

The first survey before the ship is put into service, or the first survey for an existing ship before the International Certificate on Inventory of Hazardous Materials is issued. This survey shall verify that Part I of the inventory (IHM) is in accordance with the requirements of the Convention. Once the survey has been completed, the International Certificate on Inventory of Hazardous Materials is issued.

Renewal Survey

The survey that shall be carried out at intervals not exceeding five years. This survey shall verify that Part I of the inventory (IHM) complies with the requirements of the Convention. Once the survey has been completed, the International Certificate on Inventory of Hazardous Materials is issued.

Additional Survey

As needed, this survey may be carried out at the request of the shipowner after a change, replacement, or significant repair of the structure, equipment, systems, fittings, arrangements, and material. The survey shall be carried out in such a way as to verify that a ship complies with the requirements of the Convention and Part I of the inventory (IHM) after such a change, replacement, or significant repair and that Part I of the inventory (IHM) has been updated, accordingly. Once the survey has been completed, the International Certificate on Inventory of Hazardous Materials is endorsed.

Final Survey

The survey shall be carried out prior to the ship being taken out of service and before the recycling of the ship has started. The main points to be verified are the followings.

• The inventory of hazardous materials – Parts I, II and III – meets the requirements of the Convention.
• The ship recycling plan developed by the ship recycling facility complies with the requirements of the Convention and has been approved by the competent authority(ies), i.e., the recycling state(s).
• The ship recycling facility(ies) where the ship is to be recycled holds a valid authorization in accordance with this Convention.

Once the survey has been completed, the ship is issued with an International Ready for Recycling Certificate.

Occasional Survey

The Convention does not define an occasional survey. However, our society occasionally carries out a survey which does not fall under a scope of the additional survey, as an occasional survey at the time of a change of the name of the ship, flag administration, company, etc.

 | Replacement of an existing Statement of Compliance

Existing Statement of Compliance on Inventory of Hazardous Materials (SoC) shall be replaced with an International Certificate on Inventory of Hazardous Materials, according to flag Administration instructions.