Hong Kong Convention and how to obtain IHM certification for ship recycling

The Hong Kong Convention (HKC) on ship recycling enters into force on 26 June 2025 and requires all internationally trading vessels of 500 GT and above to have on board an International Certificate on Inventory of Hazardous Materials (ICIHM) at the latest by 26 June 2030. This news describes how ship owners/managers can obtain the required ICIHM. It also summarizes the HKC requirements for IHM maintenance and ship recycling.

Relevant for ship owners and managers.

Hong Kong Convention certification

RThe Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships (HKC) enters into force on 26 June 2025 and requires existing vessels of 500 GT and above to have on board an International Certificate on Inventory of Hazardous Materials (ICIHM) at the latest by 26 June 2030 or before going to recycling if this is earlier.

Not only vessels flying the flag of a state that has ratified the HKC, but also those flying the flag of non-party states must comply with the HKC when entering the waters of a party to the HKC. In accordance with Article 3.4 of the HKC, this is to ensure that no favourable treatment is given to vessels sailing with the flag of non-party states to the HKC. Therefore, even if the flag of a vessel has not yet ratified the HKC, vessels that are trading internationally must obtain an IHM Statement of Compliance (SoC).

Many vessels already have an approved IHM and an IHM certificate confirming compliance with the EU Ship Recycling Regulation (EU SRR) and/or an IHM certificate or SoC confirming compliance with the HKC. These vessels are additionally required to obtain an ICIHM (or SoC).

According to Regulations 5.2 and 10.5 of the HKC, the implementation of the HKC should be harmonized with other applicable statutory IMO instruments. When DNV is authorized by the relevant flag administration for issuance of the ICIHM (or SoC), DNV will harmonize the issuance of the ICIHM (or SoC) with other statutory surveys. This means the first main class renewal survey after 26 June 2025 and before 26 June 2030, unless the flag administration instructs otherwise.

How to obtain an ICIHM (or SoC)

The process of obtaining an ICIHM (or SoC) depends on whether a vessel already holds an approved IHM certificate or SoC for either the EU SSR and/or the HKC. Based on each vessel’s specific status, relevant Retroactive Requirements (RRs)
have been issued under “Vessel status” in the My Services portal via Veracity, which guide owners/managers on how to obtain the required ICIHM (or SoC).

These are the principles:

  • Vessels in DNV class, without any IHM certificate/SoC foreither the EU SSR and/or HKC:
    Unless there is an ongoing IHM approval, these vesselshave been issued an RR1051e with a due date matching thenext main class renewal survey. The IHM Part I must be preparedand submitted for approval by DNV, followed by aninitial IHM survey. If a vessel already has an ICIHM (or SoC) from another Recognized Organization (RO) or the flagadministration, the existing certificate may be presented toDNV through DATE for RR deletion.
  • Vessels, regardless of class, with an IHM certificate for theEU SRR from DNV, but without an HKC IHM certificate or SoC:
    These vessels have been issued an RR1051f indicating thatno re-approval of the IHM is required and an ICIHM (or SoC)needs to be issued alongside the existing IHM certificatefor EU SSR. An ICIHM (or SoC) based on the existing IHMPart I must be requested at the next EU SSR IHM renewalsurvey between 26 June 2025 and 25 June 2030, harmonizingwith the main class renewal.
  • Vessels, regardless of class, with an IHM certificate or SoCfor the HKC from DNV:
    These vessels have been issued an RR1051g informingthat an ICIHM (or SoC) must be requested at the next IHMrenewal survey between 26 June 2025 and 25 June 2030 (harmonized with the main class renewal).

IHM approval via My Services

To streamline the process, ship owners/managers canrequest IHM Part I, II and III approvals through the MyServices portal via Veracity: Vessel services -> Approval ofdocumentation -> Manuals, plans and other documents. Thescreenshot in the Appendix aims to illustrate how to order IHM approval.

There are four different approval options identified in the portal, where ship owners/managers may request:

  • An initial approval of the IHM Part I,
  • A re-approval of the IHM Part I,
  • A conversion of an earlier IHM approval from HKC to EU SSR,
  • An IHM Part II and III approval.

IHM maintenance

As a statutory requirement, the IHM Part I must be continuously updated and maintained. Hence, to remain compliant with the HKC, ship owners/managers must:

  • Maintain and update the IHM Part I regularly,
  • Assign an IHM Designated Person (IHM DP) responsible for the IHM maintenance activities,
  • Update the IHM if new or removed materials affect hazardous content,
  • Ensure ship particulars are always current.

Ship owners/managers should implement an IHM maintenance procedure as part of the Safety Management System (SMS). The designated IHM DP is responsible for coordinating the collection of Material Declarations (MDs) and Supplier Declaration of Conformities (SDoCs) from suppliers whenever new products are purchased and installed on board as fixed items within the scope of the IHM Part I.

Whenever new hazardous materials are brought on board, the IHM Part I must be updated accordingly. Similarly, if existing hazardous materials are removed or if their quantities change, the IHM Part I must be revised. Additionally, the IHM cover page must be updated when there is a change in the vessel’s name, flag, owner or manager.

The IHM certificate/SoC will refer to the latest IHM applicable at the time of the certificate issuance.

DNV’s IHM Manager software may be used for the maintenance of IHM, and DNV also offers training for IHM maintenance (see link below).

Ship recycling

From 26 June 2025 onwards, ships destined for recycling must hold an International Ready for Recycling Certificate (IRRC). To obtain the IRRC, the IHM Parts I, II and III must be prepared and approved by DNV (when authorized) or by the vessel’s the flag administration.

Additionally, a ship-specific ship recycling plan must be prepared by a ship recycling facility which holds a valid Document of Authorization for Ship Recycling.

Applicable requirements may vary depending on the location of the vessel’s flag at the time the decision is taken for recycling. For detailed guidance on compliance, refer to DNV’s latest publication, “Safe and green ship recycling for shipowners – compliance with the HKC and EU regulations” (see link below).

Recommendations

Ship owners and managers are advised to familiarize themselves with the compliance requirements of the HKC and to begin preparations for obtaining the ICIHM for their vessels.
To get started:

  • Log into the My Services portal via Veracity and check the “Vessel status” section to identify which RRs apply to your vessels.
  • Based on the RRs, initiate the appropriate steps to obtain the ICIHM or SoC.
  • Submit the IHM Part I or request issuance of the ICIHM at next renewal survey.  

References

Contact

  • For customers:
    DATE - Direct Access to Technical Experts via My Services on Veracity.
  • Otherwise:
    Use our office locator to find the nearest DNV office.