Lloyd’s Register (LR) has provided summary of the Hong Kong Convention’s key requirements and implications ahead of its June 2025 enforcement.
The 2009 IMO Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships (HKSRC or the Convention) will come into effect on 26 June 2025. Ships flying the flag of a party to the Convention, and ship recycling facilities in countries that are parties to the Convention, must comply with its requirements. The Convention aims to ensure that ship recycling is conducted in a safe, environmentally sound, and responsible manner.
Applicability of HKSRC
It applies to new and existing ships of 500 GT and above engaged in international voyages. These include submersibles, floating craft, floating platforms, self-elevating platforms, Floating Storage Units (FSUs), Floating Production Storage and Offloading Units (FPSOs), and vessels stripped of equipment or being towed.
Exceptions include warships, naval auxiliaries, and ships used for government non-commercial service.
Key requirements
1. Inventory of Hazardous Materials (IHM)
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New ships must have an approved IHM onboard at delivery and hold valid HKSRC certification. “New ships” refers to 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. -
Existing ships (from 26 June 2030) must develop and maintain an IHM throughout their operational life and hold valid IHM HKSRC certification.
2. Final survey & certification
Ships destined for recycling must undergo a Final Survey and obtain an International Ready for Recycling Certificate prior to the commencement of recycling.
3. Ship recycling facilities
Facilities must be authorised and hold a Document of Authorisation for Ship Recycling (DASR).
Interplay of recycling regulations
From 26 June 2025, two global regulations will impact ship recycling:
- HKSRC 2009
- Basel Convention
The Basel Convention governs transboundary movements of hazardous waste and requires prior informed consent from receiving countries. Ships compliant with HKSRC may still breach Basel rules if making a final voyage to a recycling facility in a country that is not a member of the OECD.
There is currently legal uncertainty regarding the precedence between these regulations.
In the interim, the IMO has published:
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HKSRC.2/Circ.1 – Provisional guidance on the implementation of the Hong Kong and Basel Conventions with respect to the transboundary movement of ships intended for recycling.
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A set of FAQs on the subject.
