IHM and ship recycling

Ready for Recycling Certificate

With entry into force on 26 June 2025, the IMO’s Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships (HKC) requires that ships, equal to and above 500 GT and going for recycling, must have an International Ready for Recycling Certificate (IRRC). This requirement will be applicable for ships flying the flag of a party to the HKC and all ships going to be recycled at a facility in a country which is a party to the HKC.

At the same time, the EU Ship Recycling Regulation (EU SRR) requires that EU/EEA/UK-flagged ships going for recycling are issued a Ready for Recycling Certificate (RfRC). Thus, to comply with both regulations, those ships will be issued two certificates: the RfRC and the IRRC. However, DNV can prepare a harmonized certificate if the flag approves. 

EU/EEA-flagged ships  shall only be sent to recycling facilities included in the European List of approved ship recycling facilities. For UK vessels going for recycling, the UK list of approved ship recycling facilities shall be used. It is important to note that the UK has adopted the requirements of the EU SRR into its national law by amendments in SI 2019/277 and SI 2020/1429. 

The process to obtain an IRRC according to the HKC is shown in Figure 1 below, and the process to obtain an RfRC is shown in Figure 2. The process is more or less the same and requires the shipowner to prepare the IHM Parts II and III and request approval together with the updated IHM Part I. The shipowner should find a ship recycling facility which has a Document of Authorization Ship Recycling (DASR) and is listed in the European List or the UK list if the ship is sailing under EU/EEA or UK flag, respectively. The completed IHM (Parts I, II and III) should be sent to the  ship recycling facility so that a Ship Recycling Plan (SRP) can be prepared. The shipowner shall request a final survey for on-board verification and issuance of the International Ready for Recycling Certificate. 

^{Figure 1: Process to obtain International Ready for Recycling Certificate (IRRC)}

^{Figure 2: Process to obtain Ready for Recycling Certificate (RfRC)}

Furthermore, end-of-life ships continue to be regulated by the Basel Convention. The Basel Ban amendment requires that end-of-life ships from EU/OECD countries can only be recycled in EU/OECD countries. However, according to the HKC, ships party to the HKC can go to any ship recycling facility which holds a DASR. This is in contradiction with the Basel Convention requirements. Therefore, until the Basel Convention is updated according to the HKSRC.2/Circ., a country which is a party to both the HKC and the Basel Convention should inform the Secretariat of the Basel Convention if they will follow the HKC requirements.

At the same time, according to the EU Waste Shipment Regulation, a ship can be recycled in an EU-listed facility outside OECD countries if the decision to recycle was taken while the ship was located outside the OECD (see Figure 3).

^{Figure 3:  EU Waste Shipment Regulation process}

How DNV can support: Please have a look at our Safe and green ship recycling for shipowners – Compliance with HKC and EU Regulations and contact us through DATE if you have any questions.