Supporting Safe & Sustainable Ship Recycling: HKC Compliance
IMPLEMENTATION OF THE IMO HONG KONG CONVENTION FOR SHIP RECYCLING
Achieving Safe and Environmentally Sound Ship Recycling
As part of global efforts to improve safety and environmental sustainability in the maritime sector, the International Maritime Organization (IMO) adopted the Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships (HKC). The convention sets out comprehensive requirements to ensure that ship recycling activities are conducted in a safe, controlled, and environmentally responsible manner.
Under the HKC, ships of 500 gross tonnage (GT) and above engaged in international voyages that have reached the end of their economic life are required to be recycled at authorized ship recycling facilities, certified through a Document of Authorization to Conduct Ship Recycling (DASR). To support this process, vessels must be equipped with a certified Inventory of Hazardous Materials (IHM), covering Part I, Part II, and Part III.
Key Implementation Dates
Starting 26 June 2025, all new ships must carry a certified IHM Part I onboard as a condition for operation. Meanwhile, existing ships are granted a transitional period until 26 June 2030 to fulfill this requirement.
Additionally, in line with global standards, Indonesia's Ministry of Transportation Regulation No. 24 of 2022 mandates that Indonesia-flagged vessels of 100 GT and above destined for dismantling must also comply with similar IHM-related requirements.
BKI supports shipowners and recycling facilities in achieving full compliance with the Hong Kong Convention (HKC) for safe and environmentally sound ship recycling.
Starting 26 June 2025, the Hong Kong International Convention (HKC) will come into force—establishing new global standards for the safe and environmentally sound recycling of ships.
Applicability:
All ships 2500 GT engaged in international voyages are required to carry the Inventory of Hazardous Materials (IHM) Part I and ensure the recycling process is conducted only at authorized recycling facilities.
Construction Stage
At the construction stage, ships must be provided with:
- Inventory of Hazardous Materials (IHM) – Part I
- International Certificate on Inventory of Hazardous Materials
Operation Stage
During the operational life of the ship, the following must be maintained and updated:
- Inventory of Hazardous Materials (Part I)
- International Certificate on IHM
These must remain valid and accurate throughout the ship's active service.
Recycling Preparation Stage
Prior to recycling, ships must be provided with:
- IHM Part I, II & III (Updated)
- International Certificate on IHM
- Appointed Ship Recycling Facility
- Ship Recycling Plan (SRP) by the recycling facility
- International Ready for Recycling Certificate (IRRC)
At Ship Recycling Facilities
Ship recycling yards or facilities must be provided with:
- Ship Recycling Facility Plan (SRFP)
- Document of Authorization to Conduct Ship Recycling (DASR)
The Inventory of Hazardous Materials (IHM) identifies all hazardous substances onboard and ensures they are properly managed throughout the ship's life. It consists of:
IHM Part I
Hazardous materials embedded in ship's structure or equipment (e.g. asbestos, PCBs, heavy metals)
IHM Part II
Waste generated during operation (e.g. sewage, sludge)
IHM Part III
Consumables such as lubricants, paints, and batteries
Important Note: Only Part I is mandatory during the ship's operational life. Part II and III are required before the vessel is sent for recycling.
1. For New Ships
IHM Part I must be developed during the design and construction stage with full material traceability from suppliers.
2. For Existing Ships
IHM Part I is compiled through onboard hazardous materials surveys conducted by certified hazmat professionals or approved service providers. The documentation must be verified by a Recognized Organization (RO) appointed by the flag state.
3. Maintenance
IHM Part I must be regularly updated for any changes to:
- Structural material
- Equipment
- Operational substances or port regulations
Owners may manage this internally or outsource to certified hazmat experts.
As Indonesia's national classification society, BKI provides end-to-end support for shipowners and recycling facilities in meeting the requirements of the Hong Kong Convention (HKC) and related national and international regulations.
Our Services Include:
Verification and Approval of IHM Part I, II & III
Comprehensive verification services to ensure compliance with HKC standards
Issuance of Statement of Compliance (SoC)
Official documentation proving compliance with convention requirements
Awareness Training and IHM Maintenance Guidance
Specialized training programs and ongoing support for IHM management
Compliance Timeline Summary
26 June 2025: All new ships must carry certified IHM Part I
26 June 2030: Existing ships must be fully compliant with IHM requirements