The Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships (HKC) is set to enter into force on June 26, 2025. This landmark convention introduces crucial requirements for the management of hazardous materials on board ships, aiming to ensure safer and more environmentally sound ship recycling practices globally.
Key Requirements of the HKC
All existing vessels of 500 GT and above are mandated to carry an International Certificate on Inventory of Hazardous Materials (ICIHM) on board by June 26, 2030, or earlier if the vessel is scheduled for recycling. Importantly, the HKC’s reach extends beyond ships flying the flag of a state that has ratified the convention. Vessels from non-party states must also comply with the HKC when entering the waters of an HKC party, ensuring fair treatment and preventing preferential status for non-compliant ships (Article 3.4 of the HKC). Therefore, all internationally trading vessels, regardless of their flag state’s ratification status, will need to obtain an IHM Statement of Compliance (SoC).
Many vessels may already possess an approved IHM and a certificate complying with the EU Ship Recycling Regulation (EU SRR) and/or an IHM certificate or SoC confirming HKC compliance. These vessels are still required to obtain the ICIHM (or SoC) to meet the new convention’s specific certification requirements.
Harmonization with Statutory Surveys
In line with Regulations 5.2 and 10.5 of the HKC, the implementation of the Convention is designed to be harmonized with other applicable statutory IMO instruments. DNV, when authorized by the relevant flag administration, will align the issuance of the ICIHM (or SoC) with other statutory surveys. This typically means the ICIHM will be issued during the first main class renewal survey after June 26, 2025, and before June 26, 2030, unless otherwise instructed by the flag administration.
How to Obtain an ICIHM (or SoC)
The process for obtaining an ICIHM (or SoC) is tailored to whether a vessel already holds an approved IHM certificate or SoC for either the EU SRR and/or the HKC. DNV has issued specific Retroactive Requirements (RRs) under the “Vessel status” section in its My Services portal via Veracity, guiding owners and managers based on their vessel’s current status:
- Vessels in DNV class without any IHM certificate/SoC (EU SRR or HKC): Unless IHM approval is already underway, these vessels are assigned RR1051e with a due date aligning with their next main class renewal survey. They must prepare and submit IHM Part I for DNV approval, followed by an initial IHM survey. If an ICIHM (or SoC) already exists from another Recognized Organization (RO) or flag administration, it can be presented to DNV for RR deletion.
- Vessels (regardless of class) with an IHM certificate for EU SRR from DNV, but no HKC IHM certificate/SoC: These vessels receive RR1051f, indicating that re-approval of the IHM is not needed. An ICIHM (or SoC) should be requested alongside the existing EU SRR IHM certificate at the next EU SRR IHM renewal survey between June 26, 2025, and June 25, 2030, harmonized with the main class renewal.
- Vessels (regardless of class) with an IHM certificate or SoC for HKC from DNV: These vessels are issued RR1051g, instructing them to request an ICIHM (or SoC) at their next IHM renewal survey between June 26, 2025, and June 25, 2030 (harmonized with the main class renewal).
IHM approval via My Services: Shipowners and managers can streamline the IHM Part I, II, and III approval process through DNV’s My Services portal (Veracity: Vessel services -> Approval of documentation -> Manuals, plans and other documents). The portal offers four distinct approval options: initial IHM Part I approval, re-approval of IHM Part I, conversion of an earlier HKC IHM approval to EU SRR, and IHM Part II and III approval.
IHM Maintenance
Continuous updating and maintenance of IHM Part I is a statutory requirement for HKC compliance. Shipowners and managers must:
- Regularly maintain and update IHM Part I.
- Assign an IHM Designated Person (IHM DP) responsible for maintenance activities.
- Update the IHM whenever new materials are installed or existing materials affecting hazardous content are removed or changed.
- Ensure ship particulars (name, flag, owner, manager) on the IHM cover page are always current.
An IHM maintenance procedure should be integrated into the vessel’s Safety Management System (SMS). The IHM DP is responsible for collecting Material Declarations (MDs) and Supplier Declaration of Conformities (SDoCs) from suppliers for new fixed items within the scope of IHM Part I. The IHM certificate/SoC will refer to the latest applicable IHM at the time of its issuance. DNV offers its IHM Manager software for maintenance and provides training for IHM maintenance activities.
Ship Recycling
From June 26, 2025, onwards, ships intended for recycling must hold an International Ready for Recycling Certificate (IRRC). To obtain this, IHM Parts I, II, and III must be prepared and approved by DNV (when authorized) or the vessel’s flag administration. Additionally, a ship-specific ship recycling plan must be developed by a ship recycling facility that holds a valid Document of Authorization for Ship Recycling.
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Source: DNV
