Overview

It is known that ships may contain environmentally hazardous substances (e.g. asbestos, heavy metals, PBC's), and the recycling of a ship at the end of its life is associated with many worker health and safety, and environmental concerns. As such, the IMO Hong Kong Ship Recycling Convention (HKSRC) aims to ensure that the recycling of ships does not pose an unnecessary risk to human health, safety or the environment.


The HKSRC has requirements for:

  • the design, construction, operation and preparation of ships to facilitate safe and environmentally sound recycling, without compromising the safety and operational efficiency of ships;
  • the operation of ship recycling facilities in a safe and environmentally sound manner; and
  • the establishment of an enforcement mechanism for ship recycling, incorporating certification and reporting requirements.

Requirements of the HKSRC

There are three main areas that the HKSCR imposes requirements for:

  1. Ships in service require an Inventory of Hazardous Materials (IHM) to be developed and maintained, and an associated valid International IHM certificate to be held.
  2. Ships going for recycling are required to have a valid International Ready for Recycling certificate, having completed all Final Survey requirements.
  3. Ship Recycling Facilities are required to hold a valid Document of Authorisation of Ship Recycling (DASR).

Application of the HKSRC

The HKSRC applies to all ships of 500GT and over on international voyages including:
Submersibles;

  • Floating craft;
  • Floating platforms;
  • Felf elevating platforms;
  • Floating Storage Units (FSUs);
  • Floating Production Storage and Offloading Units (FPSOs); and
  • A vessel stripped of equipment or being towed.

Exceptions are, warships, naval auxiliary, ships used for government non-commercial service.
 
The HKSRC also applies to ship recycling facilities operating in a country which is party to the convention.

Key dates for compliance

The HKSRC enters into force on 26 June 2025 following ratification of flag states with sufficient vessel tonnage and recycling capacity. 
 
Shipowners

Once in force shipowners will need to ensure that they have a properly regulated method of building, operating and recycling a ship, that safeguards both crew and recycling facility workers safety, whilst minimising the environmental impact. Specifically:

  • From 26 June 2025 new ships* will be required to have an approved and certified Inventory of Hazardous Materials (IHM) onboard upon delivery.
     
    * “New ships” means a ship:
    - for which the building contract is placed on or after 26 June 2025; or
    - in the absence of a building contract, the keel of which is laid or which is at a similar stage of construction on or after 26 December 2025; or
    - the delivery of which is on or after 26 December 2027.
     
  • By 26 June 2030 existing ships will have to have an approved and certified IHM Part I onboard.

  • From 26 June 2025 ships going for recycling will have to:
    - be recycled at a ship recycling facility which has a valid Document of Authorisation for Ship Recycling (DASR).
    - hold an approved and valid IHM Parts I, II and III
    - have a ship specific recycling plan, in compliance with the Hong Kong Convention, developed by their chosen ship recycling facility 
    - have a ready for recycling certificate onboard.

Manufacturers and Shipbuilders:

Will need to ensure that they complete / compile the required Material Declarations (MD) and Supplier Declarations of Conformity (SDoC) for any items being supplied to the ship which are part of the ships structure or fitted equipment. For shipbuilders they will need to use the MD and SDoC to comply an IHM during the build process.
 
Ship Recycling Facilities

From 26 June 2025 - ship recycling facilities will have to have a valid DASR and issue ship specific recycling plans for each ship they plan to recycle.