Inventory of Hazardous Materials (IHM)

EU Ship Recycling Regulation (EU SRR)

The European Union (EU) adopted the EU Ship Recycling Regulation (SRR) 2013 (Regulation (EU) No. 1257/2013), which entered into force on 30 December 2013. The EU SRR was introduced to address the environmental and human health risks associated with ship recycling. By promoting safe and sustainable practices, the regulation aligns with the EU's broader environmental goals and supports the principles of the Hong Kong Convention (HKC).

Application

This regulation applies to ships 500 gross tonnage and above, that:

• Fly the flag of an EU member State, or
• Fly the flag of a third country calling at EU ports or anchorages

This includes submersibles, floating craft, platforms, self-elevating platforms, floating storage units (FSUs), and floating production, storage and offloading (FPSOs) units, as well as a vessel stripped of equipment or being towed. 

Key Requirements

1.     Prohibition or Restriction of Hazardous Materials

For EU flagged ships, the installation or use of certain hazardous materials on ships is prohibited or restricted.

2.     Inventory of Hazardous Materials (IHM)

Any ship subject to this regulation must have on board an Inventory of Hazardous Materials (IHM), which:

• Is ship specific.
• Identifies hazardous materials listed in Annex I (prohibited/restricted) and Annex II.
• Is kept up to date throughout the ship’s operational life.
• Follows the standard format set out in Appendix 2 of the International Maritime Organization (IMO) Guidelines.
• Is verified either by the administration or a Recognized Organization (RO) authorized by it.

3.     Visual/sampling Check Plan

Existing ships must prepare a plan describing the visual or sampling check by which the IHM is developed, in accordance with the relevant IMO Guidelines.

4.    Ship Recycling Plan

Prior to recycling, a ship recycling plan in line with the HKC must be developed and approved by the competent authority.

5.     Ship Recycling Facilities

Shipowners should ensure that ships destined to be recycled are only recycled at ship recycling facilities that are included in the European List.

6.     Ready for Recycling Certificate

Prior to recycling, ships must obtain a Ready for Recycling Certificate issued by the administration or a RO authorized by, following the approval of the ship recycling plan.

Maintenance

The shipowner is responsible for the maintenance of Part I of the IHM throughout the ship’s operational life. The IHM must be updated in the following cases:

1.     New Installations

When new machinery, equipment or other materials are installed on board the vessel, the item is to be provided with the Supplier’s Declarations of Conformity (SDoC) and Material Declarations (MD). If the installed equipment contains hazardous material in quantities above the threshold values, it must be included in the IHM Part I.

A supplement to the IMO/MD form should be included, referencing the presence (or absence) of the two additional hazardous materials (perfluorooctanesulfonic acid [PFOS] and hexabromocyclododecane [HBCDD]) listed only in the EU SRR.

2.     Removal or Replacement of Items

When items listed in IHM Part I are removed or replaced, the IHM Part I must be updated. However, if identical parts or coatings are installed or applied, updating is not required.

3.     Change of Vessel Particulars

In the event of a change in the ship’s particulars, such as change of flag/owner, the IHM Part I is to be updated.

Note: All the relevant documentation (e.g., SDoC and MD or sampling reports in case of random sampling) should be collected and maintained in the ship’s archive. 

Certification and Surveys

From 31 December 2020, EU-flagged ships must carry on board a ship-specific Inventory Certificate supplemented by Part I of the IHM and non-EU flagged ships a Statement of Compliance (SoC) also supplemented by Part I of the IHM. Both documents must be issued by the administration or a RO authorized by it.

The Inventory Certificate/Statement of Compliance is issued after the initial survey. Ships are required to undergo a renewal survey every five years and additional surveys in case of change, replacement, or significant repair of the structure, equipment, systems, fittings, arrangements and material, which has an impact on the IHM.

Before a ship proceeds to a recycling facility a final survey is conducted to verify that the IHM (Parts I, II and III) and the ship recycling plan comply with the requirements and that the ship recycling facility where the ship is to be recycled is included in the European List. After successful completion of a final survey, a Ready for Recycling Certifcate (RfRC) is issued by the administration or a RO authorized by it.

HONG KONG CONVENTION (HKC)

In 2005, the International Maritime Organization (IMO) General Assembly adopted Resolution A.981(24), which directed the Marine Environment Protection Committee (MEPC) to develop a new legally binding instrument for ship recycling. On 15 May 2009, the Hong Kong Convention (HKC) for the Safe and Environmentally Sound Recycling of Ships was adopted in Hong Kong, China, in order to ensure that ships, when being recycled after reaching the end of their operational lives, do not pose any unnecessary risks to human health, safety and to the environment

The accession by Bangladesh and Liberia on 26 June 2023, triggered the entry into force of the HKC, which entered into force on 26 June 2025.

Application

This regulation applies to:

• Ships of 500 gross tonnage (GT) and above that are engaged in international trade and:
  • Flying the flag of a party to the Convention, or
  • Operating under the authority of a flag of a party to the Convention.

This includes submersibles, floating craft, floating platforms, self-elevating platforms, floating storage units (FSUs), and floating production, storage and offloading (FPSOs) units, including a vessel stripped of equipment or being towed.

The following flag States have ratified the HKC as of 14 July 2025:

Note: Even if the ship’s flag has not ratified the HKC, it must have a Statement of Compliance (SoC) on the Inventory of Hazardous Materials on board when operating in the waters of a state that is a party to the HKC. 

Key Requirements

1.     Prohibition of Hazardous Materials

The use of certain Hazardous Materials listed in Appendix 1 is prohibited and/or restricted.

2.     Inventory of Hazardous Materials (IHM)

Any ship subject to this regulation must have on board an Inventory of Hazardous Materials (IHM), which:

• Identifies as Part I, Hazardous Materials listed in Appendices 1 and 2 to this Convention, their location and approximate quantities.
• Is verified either by the Administration or by any person or organization authorized by it
• Clarifies compliance with the above material prohibition/restriction.
• Is kept up to date.

3.     Visual/sampling Check Plan

Existing ships must prepare a plan describing the visual or sampling check by which the IHM is developed, in accordance with the relevant IMO Guidelines.

4.     Ship Recycling Plan

Prior to recycling, a ship recycling plan must be developed and approved by the competent authority.

5.     Ship Recycling Facilities

Ships flying the flag of a party can only be dismantled at authorized Ship Recycling Facilities that comply with the standards set forth in the Convention and hold valid authorization (DASR).

6.     International Ready for Recycling Certificate

Prior to any recycling activity taking place, ships must be certified as ready for recycling by the Administration or RO. This certificate is valid for three months.

Maintenance

The shipowner is responsible for the maintenance of Part I of the IHM throughout the ship’s operational life. The IHM must be updated in the following cases:

1.     New Installations

When new machinery, equipment, or other materials are installed onboard the vessel, the item is to be provided with the Supplier’s Declarations of Conformity (SDoC) and Material Declarations (MD). If the installed equipment contains hazardous material in quantities above the threshold values, it must be included in the IHM Part I.

2.     Removal or Replacement of Items

When items listed in IHM Part I are removed or replaced, the IHM Part I must be updated. However, if identical parts or coatings are installed or applied, updating is not required.

3.     Change of Vessel Particulars

In the event of a change in the ship’s particulars, such as change of flag/owner, the IHM Part I is to be updated.

Note: All the relevant documentation (e.g., SDoC and MD or sampling reports in case of random sampling) should be collected and maintained in the ship’s archive. A single SDoC may refer to several items of conformity declarations as long as each item and its related product information and supplementary information can be clearly identified. 

Certification and Surveys

New ships of 500 GT and above contracted on or after 26 June 2025 must have an IHM in place upon delivery. Upon completion of the initial survey, the RO or flag Administration will issue International Certificate on Inventory of Hazardous Materials (ICIHM).

Existing ships must meet the HKC requirements within five years of the Convention's entry into force on 26 June 2025, or before going for recycling if that occurs earlier. Ships proceeding to a recycling facility may have the initial and final surveys held concurrently.

Ships are required to have a renewal survey every five years. An additional survey (either general or partial) shall be conducted at the shipowner's request after a change, replacement or significant repair, which has an impact on the IHM.

Ship recycling, prior to the ship being taken out of service and before the recycling of the ship has started, a final survey is conducted to verify that the IHM (Parts I, II and III) and the ship recycling plan comply with the requirements and that the ship recycling facility where the ship is to be recycled holds valid authorization (DASR). After successful completion of a final survey, an International Ready for Recycling Certificate (IRRC) is issued by the administration or a RO authorized by it.

Note: IHM renewal surveys need to be harmonized with other statutory surveys.

Inventory of Hazardous Materials (IHM)

Ships will be required to develop and maintain throughout the ship’s life an Inventory of Hazardous Materials (IHM) in accordance with resolution MEPC.379(80) that consists of three parts:

• Part I: Is prepared during the design and construction phase of the ship. It includes hazardous materials listed in Appendices 1 and 2 of the HKC and Annexes 1 and 2 of European Union’s (EU) Ship Recycling Regulation (SRR). This part details the hazardous materials contained in the ship’s structure and equipment, including their location and approximate quantities. The Inventory also contains diagrams showing the locations of materials listed in Appendix 1 and Annex 1 (Location Diagram of Hazmat).
• Part II: Is developed before the ship recycling process. It includes operationally generated wastes that are potentially hazardous to the environment and human health at ship recycling facilities. Their approximate quantities and locations should be listed.
• Part III: Is developed before the ship recycling process. It includes stores like regular consumable goods, which may potentially contain hazardous materials that are not integral to a ship. This part should provide a general description including the name of the item (e.g., TV set), manufacturer, quantity and location.

A quality management system shall be established to safeguard the quality and continuity of the IHM which includes the identity of the designated person, a system for maintaining and updating the Inventory, records of new installations, repairs, maintenance and modifications to a ship or ship’s IHM designated person and records of changes to the Inventory.

IHM PART I

The hazardous materials listed in Appendix 1 of the HKC and Annex 1 (EU SRR) are prohibited and/or restricted on the new installations:

*In accordance with the International Maritime Organization (IMO) Resolution MEPC.331(76), the application or reapplication of anti-fouling systems containing cybutryne has been prohibited as of 1 January 2023. In response to this, the revised guidelines MEPC.379(80) were introduced, designates anti-fouling systems containing cybutryne as a prohibited hazardous material. Cybutryne threshold values are 1,000 mg/kg for hull samples and 200 mg/kg for wet paint containers

**Further to IMO Resolution MSC.532(107), from 1 January 2026, both new and existing ships are prohibited from using or storing extinguishing media containing PFOS.

The hazardous materials in Appendix 2 and Annex 2, when used on board the ship above their threshold values, shall be reported in the Inventory:

Additional Guidelines

• Loosely Fitted Equipment: There is no need to list loosely fitted equipment in Part I of the Inventory. Such equipment that remains on board when the ship is recycled should be listed in Part III.
• Batteries: Batteries containing lead acid or other hazardous materials that are fixed in place should be listed in Part I of the Inventory. Conversely, loosely fitted batteries, including consumer batteries and batteries in stores, should be listed in Part III of the Inventory.
• Grouping of Similar Materials: Similar materials or items that contain hazardous materials potentially exceeding the threshold value can be listed together (not individually) in the IHM, with their general location and approximate amount specified.
• Exemptions:
  • Materials listed in Table 2 that are inherent in solid metals or metal alloys, such as steels, aluminum, brasses, bronzes, plating and solders, provided they are used in general construction (e.g., hull, superstructure, pipes, or housings for equipment and machinery), are not required to be listed in the Inventory.
  • Although electrical and electronic equipment is required to be listed in the Inventory, the amount of hazardous materials potentially contained in printed wiring boards (printed circuit boards) installed in the equipment does not need to be reported in the Inventory.

• Potentially Containing Hazardous Material: For existing ships, if the equipment, system and/or area of the ship are not accessible for a visual check or sampling check, they should be classified as "potentially containing hazardous material” and their approximate quantity and location should be listed in Part I of the Inventory and be indicated separately in the "Remarks" column of the Inventory.
• Spare Parts: If any of the Material Declarations for spare parts contain hazardous materials above the respective threshold values, these spare parts are to be documented in an appendix to Part 1 of the IHM. When these spare parts are used, Part 1 of the IHM is to be updated accordingly.

IHM Part I for Existing Ships

Due to the enforcement of the Hong Kong Convention from 26 June 2025, some existing ships with IHM Part I may be able to undergo a simple verification by an attending surveyor, while others may need to submit an updated IHM Part I for review.

• Existing ships that do not require IHM Part I technical submission:

Existing ships with a reviewed IHM Part I according to the resolution MEPC.269(68) or/and EU SRR (EU No.1257/2013) do not require IHM Part I technical submission. These ships should ensure that they:

1.     Have the ABS review letter of the IHM Part I in accordance with resolution MEPC.269(68) or/and EU SRR.

2.    Revise the IHM Part I in accordance with resolution MEPC.379(80) if necessary, or present documentation that the vessel’s hull coating is cybutryne-free.

On completion of a satisfactory IHM Part I review and survey, the surveyor will issue a survey report for compliance and issue the IHM certificates as appropriate.

• Existing ships that require IHM Part I technical submission:

Existing ships with a reviewed IHM Part I according to the resolutions MEPC.197(62) or/and MEPC.179(59) and existing ships without an IHM Part I should:

1.     Develop their IHM Part I plan according to resolution MEPC.379(80),

2.     Submit to ABS the updated IHM Part I for review.

On completion of a satisfactory review and survey, the surveyor will issue the IHM certificates as appropriate.

Overview

Ship recycling falls under a complex international and regional, which primarily consists of the Hong Kong Convention (HKC), the Basel Convention and its Ban Amendment, the European Ship Recycling Regulation (EU SRR), and the European Waste Shipment Regulation (EU WSR).

Hong Kong Convention (HKC)

Under this convention, shipowners must choose a Ship Recycling Facility (SRF) that holds a Document of Authorization to conduct Ship Recycling (DASR). A DASR is issued to a competent authority in recycling states parties to HKC to each authorized yard within their jurisdiction. A SRF’s limitations such as the size, type of ship, and quantities of hazardous materials that it is permitted to accept will be listed in the DASR.

Currently, several SRFs in India, Turkey, China and Bangladesh have been issued DASRs. Each signatory party must report to the IMO the list of authorized facilities operating within its jurisdiction. This information is recorded in a dedicated module within the Global Integrated Shipping Information System (GISIS), the online platform developed by the IMO.

Prior to recycling, the Inventory of Hazardous Materials (IHM) should be updated and verified in order to incorporate Part II for operationally generated waste and Part III for stores, in addition to the properly updated Part I. 

Shipowners must also provide the SRF with all available information relating to the ship to enable the SRF to develop the Ship Recycling Plan, specifying the manner in which the ship will be recycled, depending on its particulars and its inventory.

Before the ship enters the SRF the vessel’s operators should minimize the amount of cargo residues, remaining fuel oil, and waste remaining on board. In the case of tankers, the vessel should arrive at the SRF with cargo tanks and pump room(s) in a condition that is ready for certification as Safe-for-entry, or Safe-for-hot work.

Upon successful completion of the final survey, the ship will be issued an International Ready for Recycling Certificate (IRRC). The IRRC’s is valid for 3 months. However, it may be extended by the administration or by any person or organization authorized by it for a single point to point voyage to the SRF.

The shipowner shall notify the administration in due time and in writing of the intention to recycle a ship in order to enable the administration to prepare for the survey and certification required by HKC.

Basel Convention

The Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and their Disposal, adopted on 22 March 1989, introduced mandatory global requirements, aimed to protect human health and the environment against the adverse effects of hazardous wastes and other wastes, requiring special consideration.

To address the challenges faced by developing countries in managing waste in an environmentally sound manner, parties to the Basel Convention adopted the “Ban Amendment” in 1995 and entered into force on 5 December 2019. This amendment prohibits all transboundary movements of hazardous wastes intended for final disposal, reuse, recycling, or recovery from countries that are members of the Organization for Economic Co-operation and Development (OECD), EU, and Liechtenstein to non-OECD countries (primarily developing countries and countries with economies in transition) countries.

The Basel Convention also applies to the transboundary movement of end-of-life ships for recycling, although it does not explicitly refer to ships or the concept of a “flag state”. Under this framework ships from OECD or EU countries are restricted to being recycled only within other OECD or EU countries. In contrast, under the Hong Kong Convention (HKC) provisions, ships can be recycled at authorized facilities in non-OECD countries, provided they hold a DASR. To address this IMO has published a provisional guidance circular, HKSRC.2/Circ.1, which  indicates  countries that are parties to both the HKC and the Basel Convention, should notify the Basel Convention Secretariat that the HKC's requirements will be applied, and confirm that appropriate measures are in place to ensure environmentally sound management of hazardous wastes, as required by the Basel Convention. HKC's requirements will be applied, and confirm that appropriate measures are in place to ensure environmentally sound management of hazardous wastes, as required by the Basel Convention's requirements will be applied, and confirm that appropriate measures are in place to ensure environmentally sound management of hazardous wastes, as required by the Basel Convention.

While the HKC and EU SRR deal with ship recycling, the Basel Convention addresses the environmental aspect of waste movement.  For example, a ship that is going to be recycled in a non-OECD country may meet the requirements of the Hong Kong Convention, but it could still violate the Basel Convention, as this constitutes a hazardous waste export. In such case, the shipowner must ensure that the ship's intended recycling destination complies with the Basel Convention's rules regarding hazardous waste exports to non-OECD countries. The owner must submit the required notifications to all relevant countries, demonstrating an understanding and compliance with both the HKC and the Basel Convention. The shipowner must ensure that the ship's intended recycling destination complies with the Basel Convention's rules regarding hazardous waste exports to non-OECD countries. The owner must submit the required notifications to all relevant countries, demonstrating an understanding and compliance with both the HKC and the Basel Convention.

European Union Ship Recycling Regulation (EU SRR)

For ships flying the flag of an EU member state, recycling must be conducted exclusively at facilities listed in the European List, which includes approved yards located in the EU, Turkey and the USA. The procedural requirements under the EU SRR closely mirror those of the HKC, with the following key similar obligations:

1. The Inventory of Hazardous Materials (IHM) must be updated to include Parts II and III.

2. The shipowner provides the SRF with ship-relevant information in order to develop the ship recycling plan (SRP).

3. Prior to entry into the SRF, the vessel must conduct operations to minimize cargo residues, remaining fuel oil, and ship-generated waste. In the case of tankers, shipowners shall ensure that cargo tanks and pump rooms are in a condition ready for certification as Safe-for-hot work.

4. Before it proceeds to a recycling facility, a final survey is conducted and upon successful completion, the ship shall be issued a Ready for Recycling Certificate (RfRC). This certificate is supplemented by the inventory of hazardous materials (IHM) and the approved SRP.

On 11 April 2024, the EU introduced Directive 2024/1203 on the protection of the environment through criminal law and replacing Directives 2008/99/EC and 2009/123/EC, which will be implemented by 21 May 2026. This Directive reinforces existing environmental protection laws, introducing criminal liability for violations regarding ship recycling practices.

EU Waste Shipment Regulation (EU WSR)

The European Union Waste Shipment Regulation (Regulation (EC) No 1013/2006) was established to implement the obligations of the Basel Convention (1989) on the control of transboundary movements of hazardous wastes and their disposal. The updated waste shipment regulation, Regulation (EU) 2024/1157, which entered into force on 20 May 2024, further strengthens this alignment, introducing stricter rules for the transboundary movement of waste within, into, and out of the European Union.

Exports of waste for disposal and export of hazardous waste for recovery to non-OECD countries are prohibited. End-of-life ships are deemed to be hazardous waste, which means that no ship (regardless of its flag) may leave an EU port destined for recycling in a non-OECD country.   

A ship subject to the EU WSR is not considered hazardous waste falling under the export prohibition if it does not contain any of the hazardous substances listed in Annex V to the Regulation.

Beginning 21 May 2027, the export of non-hazardous waste to non-OECD countries will be prohibited. However, non-OECD countries are eligible to submit a formal request to the European Commission for authorization to continue importing such waste from the EU. Several requests have been made, and the initial list of authorized countries is planned for adoption on 21 November 2026.

United Kingdom Ship Recycling Requirements

The EU SRR has been adopted into UK law by SI 2018/1122 and SI 2019/277 and with regards to Ship Recycling Facilities by SI 2015/430 and SI 2020/1429. UK flagged ships must be recycled at a UK approved Ship Recycling Facility as per the annex to MGN 656. Additionally, when preparing for recycling, the shipowner is obligated to notify the UK administration with the required documentation as per MGN 633 Amendment 1.

1.    What happens if a ship does not comply with the EU SRR?

If a ship subject to European Union’s (EU) Ship Recycling Regulation (SRR) does not submit Inventory Certificate/Statement of Compliance (SoC) supplemented by Part I of the Inventory of Hazardous Materials (IHM) it may be warned, detained, dismissed or excluded from the ports or offshore terminals in the EU.

Failure to update the IHM is not considered a detainable deficiency, but any inconsistencies shall be reported to the administration or the relevant authority concerned.

2.    Can EU-flagged ships be recycled outside the EU?

European Union (EU)-flagged ships are only recycled at ship recycling facilities that are included in the European List. The European List now contains 43 facilities: 31 yards located in Europe (EU, Norway and the United Kingdom), 11 in Türkiye, and one in the United States.

3.    On New Ships, is it necessary to collect MDs and SDoCs for every item?

Material Declarations (MDs) should be prepared for each product regardless of the existence of hazmat materials.

A single Supplier’s Declarations of Conformity (SDoC) may refer to several items of conformity declarations as long as each item and its related product information and supplementary information can be clearly identified. The same SDoC ID number and product must be provided in both the MD and SDoC.

4.    Who are the ABS approved service suppliers for IHM?

The list of approved service suppliers for Inventory of Hazardous Materials (IHM) is available on ABS website (Recognized Service Supplier Database Search)

5.    What is the timeline to comply with HKC?

The Hong Kong Convention (HKC) entered into force on 26 June 2025. All new ships contracted for construction on or after this date must have an Inventory of Hazardous Materials (IHM) and the International Certificate on Inventory of Hazardous Materials (ICIHM) or Statement of Compliance (SoC) in place upon delivery.

Existing ships are to have a valid Certificate within five years of the Convention's entry into force on 26 June 2025, or before going for recycling if that occurs earlier.

6.    For ships registered under a flag which hasn’t ratified HKC is it required to comply with HKC?

Yes. Even if a ship is registered under a flag State that has not ratified the Hong Kong Convention (HKC), it must comply with the Convention’s requirements when entering the ports or waters of a country that has ratified the HKC. This means such ships must have on board a Statement of Compliance (SoC).

7.    Should the validity of IHM Certificate be harmonized with all other Statutory Certificates?

Hong Kong Convention (HKC) certificates should be harmonized with the surveys required by other applicable statutory instruments.

8. Is IHM included in the annual survey?

Vessels with the Inventory of Hazardous Materials (IHM) notation will be subjected to an annual survey in accordance with the ABS Rules in the course of completing other annual and periodical surveys.

9.    My ship has already a valid Hong Kong SoC on IHM. How do I replace it with an ICIHM?

The ship is required to have on board the International Certificate on Inventory of Hazardous Materials (ICIHM) by 26 June 2030. To comply, shipowners should request the issuance of the Certificate at the time of the next renewal survey. However, for ships flying the flag of party to the Hong Kong Convention (HKC), if there is a valid Statement of Compliance (SoC) on Inventory of Hazardous Materials (IHM) and IHM Part I has been reviewed by ABS in accordance with resolution (MEPC).269(68), MEPC.379(80) and/or European Union’s (EU) Ship Recycling Regulation (SRR) (EU No.1257/2013), the existing SoC may be reissued as an ICIHM with the same validity as the existing SoC, without an additional shipboard inspection/survey, provided the IHM has been maintained and updated as required.

10.    What is the required documentation for the IHM Renewal Survey?

The following documents will be required for the Renewal Survey:

        1.     Inventory of Hazardous Materials (IHM)

        2.     Material Declaration (MD)

        3.     Supplier’s Declaration of Conformity (SDoC)

        4.     Location Diagram of Hazmat

        5.     Quality management system — procedures to safeguard the proper updating of the IHM

11.    What types of deficiencies under the HKC could lead to a ship being detained?

The Port State Control Officer are expected to use professional judgment to determine whether to detain a ship until any noted deficiencies are corrected or to allow it to sail with certain deficiencies that do not pose an unreasonable threat to the safe and environmentally sound recycling of ships. The following deficiencies are of such nature that may warrant the detention:

1.    Failure to carry on board a valid International Certificate on Inventory of Hazardous Materials (ICIHM), or, if appropriate, a valid International

Ready for Recycling Certificate .

2.    Noncompliance with the control measures for hazardous materials listed in Appendix 1 of the Convention

12.    What are the requirements for ship recycling of UK-flagged vessels under the current regulations?

The U.K. has retained Regulation (EU) 1257/2013 on Ship Recycling in U.K. domestic law under the EU Withdrawal Act 2018. When preparing for recycling, the shipowner is obligated to notify the U.K. Administration with the required documentation as per MGN 633. United Kingdom flagged ships must be recycled at a U.K. approved ship recycling facility as per the Annex to MGN 656.

13.    Is there a classification notation for IHM compliance?

Yes, ships that have had their Inventory reviewed and verified to the requirements of the IHM Guide and to the satisfaction of ABS survey, will receive the ABS notation Inventory of Hazardous Materials (IHM) upon owner’s request.

14.    How to maintain the GP notation?

Ships that currently hold Green Passport (GP) notation will continue to be eligible to maintain the GP notation, provided the requirements contained within the ABS Guide for the Class Notation Green Passport (GP) continue to be satisfied.

15.    How to convert the GP notation to IHM notation?

Existing vessels that have a Green Passport (GP) Notation may receive an IHM notation provided:

• The vessels have Inventories that have been prepared using the procedure for “new vessels” in compliance with 3/4.1 of the Inventory of Hazardous Materials (IHM) Guide, or
• The existing vessels which currently maintain an Inventory prepared by using the procedure for “existing vessels” in compliance with 3/4.2 of the IHM Guide, along with their Inventory’s being reviewed and revised where necessary by an ABS approved service supplier.

16.    What certification is required for a ship registered under the Panamanian flag when calling EU Ports?

For ships flying the Panamanian flag, only one document is required on board. ABS is authorized to issue an interim International Hong Kong Convention (HKC) Certificate, which includes a remark for compliance with European Union’s (EU) Ship Recycling Regulations. Following this, the shipowner must apply for the full-term HKC certificate through the Panamanian flag Administration.

17.    What certification is required for a ship registered under Liberia/Marshall Islands flag when calling EU Ports?

For ships registered under Liberia, or Marshall Islands flag Administrations, two documents are required on board: a Hong Kong Convention (HKC) certificate and a Statement of Compliance (SoC) for the European Union’s (EU) Ship Recycling Regulation (SRR).

For the Marshall Islands, ABS is authorized to issue the full-term HKC and SoC for EU SRR

For Liberia, ABS is authorized to issue a five-month interim HKC certificate and an interim SoC for EU SRR. The Liberian flag Administration will then issue the full-term certificates, valid for five years.

18.      How will compliance with the HKC provisions be checked? 

Ships may be subject to Port State Control inspections in any port or offshore terminal of another party to the HKC. This inspection may include verifying that there is a valid International Certificate on Inventory of Hazardous Materials onboard or, if the ship is scheduled to be recycled, an International Ready for Recycling Certificate

19.      Can ships which fly the flag of a party to the HKC be recycled in a Ship Recycling Facility under the jurisdiction of a government which is not a party to the Convention?

No, as per Regulation 8 of the Convention, such ships can only be recycled at SRFs which are authorized in accordance with HKC (holding a DASR).

20.      What is the definition of a Ship Recycling Facility under the HKC?

Ship Recycling Facility means a defined area that is a site, yard or facility used for the recycling of ships. 

21.      Can Ship Recycling Facilities acting under the jurisdiction of a party to the Hong Kong Convention recycle non-party ships? 

As per regulation 17 of the HKC, Ship Recycling Facilities may take non-party ships if they meet the requirements of the Convention (i.e. they must have had equivalent surveys and documentation).

22.     How to deal with the issue of the interplay between the Hong Kong and the Basel Conventions with respect to the transboundary movement of ships intended for recycling?

MEPC 82 approved HKSRC.2/Circ.1 on Provisional Guidance on the implementation of the Hong Kong and Basel Conventions, which recommends:

1.      States that are parties to the Hong Kong Convention but are not parties to the Basel Convention

should apply the requirements of the HKC.

2.      States that are parties to the Basel Convention but are not parties to the Hong Kong Convention

should apply the requirements of the Basel Convention, including its Ban Amendment, if they have expressed their consent to be bound by it.

3.      States that are parties to both the HKC and the Basel Convention, should notify the Basel Convention Secretariat that the HKC's requirements

will be applied, and confirm that appropriate measures are in place to ensure environmentally sound management of hazardous wastes, as

required by the Basel Convention.