Ship Recycling Under the Hong Kong Convention: What Changed in 2025

The scale of the activity

The Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships entered into force on 26 June 2025, sixteen years after adoption. It is now the global framework for how ships end their lives.

Recycling volumes have been low relative to the fleet, and the fleet is ageing — average age by vessel count rose 1.8% in a year. A large recycling wave is arriving, and it will arrive into a regulated regime for the first time.

What the convention requires

For ships in service

Inventory of Hazardous Materials (IHM). Every in-scope ship must carry an IHM Part I, identifying hazardous materials in the structure and equipment, with their approximate location and quantity. It must be:

• Developed by a competent person, typically involving sampling and analysis
• Approved and certified, with an International Certificate on Inventory of Hazardous Materials
• Maintained throughout the ship's life — updated whenever new materials come aboard through repairs, retrofits or conversions

That maintenance obligation is where most operators fall short. An IHM developed once at certification and never updated is not compliant, and it will be examined at survey and at PSC.

At end of life

• IHM Parts II and III are added, covering operationally generated wastes and stores.
• International Ready for Recycling Certificate is issued following a final survey.
• The ship must be recycled at a facility authorised under the convention, operating to an approved Ship Recycling Facility Plan.
• A ship-specific recycling plan is prepared by the facility, based on the IHM.

Interaction with the EU regime

The EU Ship Recycling Regulation predates the convention and applies to EU-flagged ships, requiring recycling at facilities on the European List. Non-EU-flagged ships calling at EU ports must carry a valid IHM.

The two regimes are similar in structure but not identical, and the practical position for a mixed fleet is that you comply with both. Key differences to watch: the list of hazardous materials covered, facility approval criteria and the treatment of beaching methods.

`[VERIFY]` The relationship between the EU regime and the now-in-force convention has been under review — check the current position before publishing.

What owners should be doing now

1. Audit the IHM. Is it current? Has it been updated after the last dry docking, retrofit or equipment replacement? Who is responsible for updating it?

2. Build IHM maintenance into the procurement process. Every new item brought aboard should be checked against the hazardous materials list, with a Material Declaration and Supplier's Declaration of Conformity obtained. If purchasing does not collect these, the IHM decays from the day it is certified.

3. Plan the exit early. Recycling value, facility selection and certification take time. Owners who begin at the point of sale get the options that are left.

4. Consider the reputational dimension. Cash buyers, flag changes and last-voyage arrangements attract attention from financiers, charterers and NGOs. Financing documents increasingly include responsible recycling covenants.

5. Understand the value implications. Recycling value depends on lightweight displacement, steel prices, location and facility standard. Higher-standard facilities pay less per tonne. That difference is the price of the reputational and legal protection.

Practical IHM maintenance