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The Hong Kong Convention is about to come into effect, and the shipping industry needs to pay close attention to key issues

Author.

LCS

Source:

Post time:

2025-02-11

The 2009 Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships (referred to as the "Hong Kong Convention") will come into effect on June 26, 2025. The Convention applies to ships of 500 gross tons or more sailing internationally under the flag of a contracting state, as well as shipbreaking yards operating within the jurisdiction of a contracting state.

Background of Convention Implementation

In March 2000, the 44th MEPC conference first proposed the role of IMO in ship recycling, a term used to refer to the scrapping of ships. Subsequently, a communication group was established to study this issue and provide information on current ship recycling practices and recommendations on the role of IMO.

In November December 2005, the International Maritime Organization (IMO) Assembly subsequently agreed that the IMO should develop a new legally binding instrument for ship recycling. Subsequently, over a period of three and a half years, member states of the International Maritime Organization (IMO) and relevant non-governmental organizations, in collaboration with the International Labour Organization and contracting parties to the Basel Convention, formulated the text of the Hong Kong Convention. Finally, the Hong Kong Convention was adopted at a diplomatic conference held in Hong Kong, China in May 2009.

Since the adoption of the Hong Kong Convention, the Marine Environment Protection Committee (MEPC) of the International Maritime Organization has developed and adopted the following guidelines to assist countries in implementing and enforcing the technical standards of the Convention:

Guidelines for the Development of Ship Dismantling Plans in 2011, Resolution passed by MEPC. 196 (62);  

The 2012 Safe and Harmless Ship Recycling Guidelines MEPC.210 (63) adopted by the resolution;  

MEPC.211 (63) of the 2012 Resolution on Authorization Guidelines for Ship Dismantling Facilities;

MEPC.222 (64) of the Hong Kong Convention Ship Inspection and Certification Guidelines, adopted in 2012; and

The Hong Kong Convention Ship Inspection Guidelines MEPC.223 (64) passed in 2012;

Guidelines for the Development of Hazardous Materials List in 2023, approved by Resolution MEPC.379 (80).

General requirements of the convention

All vessels suspended in EU member states shall be subject to this inspection system and shall be accompanied by a "Certificate of International Hazardous Substance List" or a "Certificate of Compliance with Hazardous Substance List" issued by the competent authority or its authorized registration agency, supplemented by Part I of the Hazardous Substance List (IHM). All third country vessels docking at ports or anchorages of EU member states shall carry a compliance certificate issued by the competent authority of that third country or an agency authorized by the competent authority, supplemented by Part I of the Hazardous Substances List (IHM).

Meaning of the Convention

The purpose of the Hong Kong Convention is to ensure that ships, after reaching their useful life, do not pose any unnecessary risks to human health, safety, and the environment during safe recovery. It adheres to the concept of "cradle to grave" and addresses all environmental and safety issues related to ship recycling, including responsible management and disposal of waste streams in a safe and environmentally sound manner. The Convention places responsibility and obligations on all relevant parties - shipowners, shipyards, ship recycling facilities, flag states, port states, and recycling states. After the Hong Kong Convention comes into effect, ships sent for recycling will be required to carry a list of dangerous goods. Ship recycling facilities authorized by the competent authorities will be required to provide a ship recycling plan, specifically for each vessel to be recycled. In addition, governments of various countries will be responsible for ensuring that recycling facilities within their jurisdiction comply with the provisions of the Convention.

Key issues that all parties involved in the ship need to pay close attention to

(1) Hazardous substance control should prohibit and/or restrict the installation or use of hazardous substances listed in Appendix 1 of the Convention (including asbestos, polychlorinated biphenyls, ozone depleting substances, and harmful anti fouling systems) on ships.   

⑵ Hazardous Substance List (IHM).

① The list of hazardous substances should be verified by the competent authority or any individual or organization authorized by it. The list of hazardous substances includes three parts: hazardous substances contained in ship structures and equipment (Part I), waste generated from operations (Part II), and materials (Part III).

② Starting from June 26, 2025, a list of hazardous substances should be stored on each new ship. The list should include the hazardous substances, their locations, and approximate quantities contained in the ship structures and equipment described in Appendix 1 and 2 of this Convention as Part I of the list.  

③ Existing ships should develop a list of hazardous substances as soon as possible, no later than June 25, 2030, or before preparing for dismantling (whichever is earlier).  

④ Before dismantling the ship, the list of hazardous substances should include not only the appropriately maintained and updated Part I, but also Part II - Waste generated from operations and Part III - Materials, and should be verified by the competent authority or any authorized individual or organization in accordance with the guidelines developed by this organization.

Ships subject to this Convention shall undergo the following inspections for inspection and certification:

① Initial inspection: conducted before the vessel is put into operation or before the issuance of the International Hazardous Substances List Certificate. This inspection shall verify that Part I of the list of hazardous substances complies with the requirements of this Convention.

② Renewal inspection: conducted within the time limit specified by the competent authority but not exceeding 5 years. This inspection shall verify that Part I of the list of hazardous substances complies with the requirements of this Convention.

③ Additional Inspection: Upon request from the shipowner, overall or partial additional inspections may be conducted based on the situation after changes, replacements, or major repairs have been made to the structure, equipment, systems, accessories, layout, and materials. The inspection shall verify that the vessel still complies with the requirements of this Convention after any such changes, replacements or major repairs, and that Part I of the list has been amended as necessary.

④ Final inspection: conducted before the retirement of the vessel and the commencement of dismantling, to verify that the hazardous substance list, dismantling plan, and dismantling yard comply with the requirements of this Convention. After passing the inspection, the International Certificate of Suitability for Ship Dismantling will be issued.

Other precautions:

The development of the Ship Hazardous Substance List (IHM) can refer to the International Maritime Organization's (IMO) Guidelines for the Compilation of Hazardous Substance Lists in 2023 (MEPC. 379 (80) Resolution). The MEPC.379 (80) resolution includes guidance on anti fouling bottom systems containing sibutrinib, replacing the MEPC.269 (68) resolution passed by IMO in 2015.

The development of Ship Dismantling Plans (SRP) can refer to the IMO's "Guidelines for the Development of Ship Dismantling Plans in 2011" (MEPC. 196 (62) Resolution).

The development of Ship Recycling Plant Plan (SRFP) can refer to the IMO's "2012 Guidelines for Safe and Environmentally Sound Ship Recycling" (MEPC. 210 (63) Resolution).

Lixun Testing can provide IHM testing, ACMS removal and disposal, IHM maintenance and other services for major shipyards, ship equipment manufacturers, ship owners and ship management companies across the country, providing customers with accurate testing reports.

As a third-party IHM sampling, testing, and certification organization for hazardous substances recognized by various classification societies, Lixun Testing's team can provide you with a comprehensive solution for "green ships", ensuring that your ship meets the green and environmental protection requirements of international conventions.

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