NEWS

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.

The 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.

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.