The Hong Kong Ship Recycling Convention and the EU Ship Recycling Regulation: the IHM, certificates and deadlines

Adopted at a diplomatic conference in Hong Kong, China, in May 2009, the Convention needed at least 15 States, 40% of world merchant tonnage and recycling capacity of at least 3% of those States’ combined tonnage. Those conditions were met in 2023 and it entered into force 24 months later, on 26 June 2025. On that day IMO counted 24 Parties covering 57.15% of world tonnage, among them the flag States Japan, Liberia, the Marshall Islands and Panama, and the recycling States Bangladesh, India, Pakistan and Türkiye.

Ships covered: every ship entitled to fly a Party’s flag, a definition that includes floating platforms, FSUs and FPSOs and a vessel stripped of equipment or being towed. Not covered: ships under 500 GT, ships operating all their life only in waters of their flag Party, and warships, naval auxiliaries and other government ships on non-commercial service.

Hazardous materials: the Convention prohibits or restricts materials such as asbestos, polychlorinated biphenyls (PCBs), ozone-depleting substances, and anti-fouling compounds and systems containing organotin compounds or cybutryne.

Sources: IMO, press briefing, 26 June 2025, Ship recycling and the Hong Kong Convention FAQ; read on 13 November 2026. The Party count is IMO’s figure at entry into force.

The shipowner prepares and keeps a ship-specific IHM listing the hazardous materials on board, with their location and quantity. It is verified by the Administration or its recognized organization, following IMO’s 2023 IHM guidelines (resolution MEPC.379(80)). It has three parts:

• Part I – hazardous materials in the ship’s structure and equipment, kept up to date throughout the ship’s life;
• Part II – operationally generated waste; and
• Part III – stores.

Parts II and III are prepared before the ship is recycled. Before recycling, the owner gives the authorized yard the completed IHM so that the yard can prepare a ship-specific Ship Recycling Plan.

Sources: IMO, Hong Kong Convention FAQ and Ship recycling; read on 13 November 2026.

• Initial survey before the ship enters service (for an existing ship, before its IHM certificate is issued).
• Renewal survey at intervals set by the Administration, not exceeding five years.
• Additional survey, at the owner’s request, after a change, replacement or significant repair of structure or equipment.
• Final survey before the ship is taken out of service for recycling. It checks that IHM Parts I–III comply, that the Ship Recycling Plan reflects the IHM (including safe-for-entry and safe-for-hot-work conditions) and has been explicitly or tacitly approved by the Competent Authority, and that the yard holds a valid DASR. The International Ready for Recycling Certificate that follows is valid for a period set by the Administration, not more than three months.

Port State control: a ship may be inspected in the port of another Party, starting with a check that it carries a valid IHM certificate or Ready for Recycling Certificate with the IHM. IMO’s FAQ says that failing to update the IHM should not on its own be a detainable deficiency; inconsistencies are reported to the flag and put right at the next survey. Failing to carry a valid certificate is among the deficiencies that may justify detention.

Source: IMO, Hong Kong Convention FAQ (PDF); read on 13 November 2026. Paraphrased; the Convention text and the 2012 survey and inspection guidelines (MEPC.222(64), MEPC.223(64)) are authoritative.

Regulation (EU) No 1257/2013 applies to ships flying the flag of an EU Member State, with the same 500 GT, government-ship and domestic-only exclusions. EU-flagged ships may be recycled only at yards on the European List of ship recycling facilities. Its Article 12 applies to non-EU ships calling at a port or anchorage of a Member State.

A non-EU ship that does not comply may be warned, detained, dismissed or excluded from EU ports and offshore terminals (Article 12(5)). A ship can fall under both regimes; check with your flag State and class which certificates it needs under each.

Sources: EU, Regulation (EU) No 1257/2013 (EUR-Lex); dates and certificate names from EMSA’s guidance on port State inspections under the Regulation (27 September 2019; an EU agency’s non-binding guidance); read on 13 November 2026.