More than a decade since its adoption in 2009, the 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.
Relevant for shipyards, suppliers, ship owners and managers, flag states as well as ship recycling facilities.
Background to the Hong Kong Convention
Considering the critical situation of ship recycling facilities and the need for an effective and globally applicable instrument for ship recycling, the IMO decided to develop a legally binding instrument on ship recycling. “The Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships” (HKC) was adopted in 2009. The HKC enters into force 24 months after the ratification conditions are met, which will be 26 June 2025.
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.
Key requirements
The key requirements can be summarized in two main points:
- Each ship of 500 GT and above shall have a certified Inventory of Hazardous Materials (IHM)
- Ship Recycling Facilities (SRF) shall be authorized by their competent authorities and shall only accept ships that comply with the HKC requirements
Impact on newbuilds and ships in service
All ships of or above 500 GT shall have a certified IHM on board. With the EU SRR, regardless of their flag or trading area, most shipyards already offer IHM preparation for newbuilds, so the additional impact of the HKC is not expected to be large.
Ships in service shall comply with this requirement by 26 June 2030 or before going to recycling if this is earlier. The world fleet consists of about 53,000 vessels within the scope of HKC. DNV estimates that with the full application of the EU SRR, about 30,000 vessels are already carrying an IHM Certificate or Statement of Compliance. Still, a large volume of about 23,000 vessels would need to be equipped with a certified IHM over the coming years.
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.
Impact on ship recycling practices globally
According to BIMCO, some 15,000 ships will over the next 10 years require recycling, an average of 1,500 per year. 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.
Each SRF shall prepare a Ship Recycling Facility Plan (SRFP) which shall include a system for ensuring implementation of the HKC requirements, such as:
- A policy for ensuring safety and protection of the environment
- A training programme for the safe and environmentally sound operation of the SRF
- An emergency preparedness and response plan
- A record-keeping system
- A system for reporting emissions, accidents, incidents, occupational diseases and other adverse effects to workers’ safety and the environment
Recommendations
Ship owners and managers, shipyards and ship recycling facilities are advised to familiarize themselves with the compliance requirements of the HKC. DNV will issue further guidance in the coming period to prepare for the implementation of the HKC.
References
- IHM and Ship Recycling topic page
- IHM Manager (IHMM) marketplace page
- For customers: Access to IHM Manager (IHMM) in the portal
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