Ready for HKC? Here's What You Need to Know

🌍 Navigating the Future of Ship Recycling:

The Hong Kong Convention Enters into Force in June 2025

🚢 Introduction: A Turning Point for the Maritime Industry

The international maritime industry is on the cusp of a regulatory milestone. Beginning 26 June 2025, the Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships (HKC)—a long-anticipated global agreement—will officially come into force, setting legally binding standards for ship recycling across the globe.

This development marks a significant shift toward accountability, sustainability, and safety in shipbreaking practices, especially for shipowners, technical managers, and recycling yards operating across diverse flag states.

The HKC introduces a comprehensive legal and operational framework designed to eliminate unsafe dismantling practices, reduce environmental contamination, and ensure workers' safety in ship recycling yards. With enforcement just weeks away, stakeholders must understand the Convention's requirements and prepare proactively.

In this blog, we'll break down:

Let's dive in.

⚖️ What Is the Hong Kong Convention (HKC)?

The Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships (HKC) was adopted by the International Maritime Organization (IMO) in 2009 to address the growing concerns surrounding unsafe and polluting ship recycling practices—particularly in countries lacking strong environmental and labour protections.

The Convention sets globally binding standards aimed at ensuring that ships, when being recycled after reaching the end of their operational lives, do not pose unnecessary risks to human health or the environment.

Who Does the HKC Apply To?

What Makes HKC Comprehensive?

Unlike earlier fragmented regulations, the HKC covers the entire lifecycle of a ship—from its design, construction, and operational use to its final dismantling and recycling. It requires:

By setting clear responsibilities for both shipowners and recycling states, the HKC represents a critical step toward more sustainable, transparent, and accountable ship recycling practices worldwide.

Why Was It Needed?

For decades, the global shipping industry faced growing criticism over the unsafe and environmentally damaging methods used to dismantle end-of-life vessels—especially in countries lacking strict labour or environmental regulations. A significant number of ships were being sent to beaching yards, primarily in South Asia (India, Bangladesh, Pakistan), where they were torn apart directly on tidal shores.

These practices posed grave dangers:

🚧 Unsafe Working Conditions

Workers—often unskilled, underpaid, and unprotected—were routinely exposed to deadly substances without proper equipment or training. Accidents, injuries, and fatalities were alarmingly common, with little to no medical or legal recourse for affected workers.

☠️ Hazardous Material Exposure

Ships contain numerous toxic substances, including:

  • Asbestos (used for insulation)
  • Polychlorinated Biphenyls (PCBs) (in electrical equipment)
  • Lead and mercury (in paints, batteries, instruments)
  • Ozone-depleting substances and heavy metals

Without adequate handling procedures, these substances leached into the soil, water, and air—causing long-term damage to marine ecosystems and nearby communities.

🌍 Environmental Degradation

Beaching yards often lacked proper waste management infrastructure. Oils, chemicals, and toxic residues from dismantled vessels were directly discharged into open environments, leading to contamination of groundwater and irreversible harm to coastal biodiversity.

To address this global issue, the Hong Kong Convention (HKC) was created to set enforceable standards and close the regulatory gap by requiring:

By doing so, the HKC not only protects workers and the environment, but also enhances regulatory consistency across the global maritime industry—ushering in an era of responsible, ethical, and sustainable ship recycling.

🧩 Core Components of the Hong Kong Convention (HKC)

The HKC outlines a robust compliance framework that covers the entire process of ship recycling—from documentation and planning to on-the-ground dismantling and monitoring. Below are the three core pillars of the Convention:

📦 1. Inventory of Hazardous Materials (IHM)

At the heart of HKC compliance is the Inventory of Hazardous Materials (IHM)—a mandatory, ship-specific document that identifies and records all potentially hazardous materials present onboard a vessel.

The IHM consists of three parts:

  • Part I: Inventory of Hazardous Materials (IHM) Part I is established for newbuilding's at the time of construction and must be certified before the ship enters service; for existing ships, IHM Part I is developed based on available documentation and assessment, then certified and maintained throughout the vessel's operational life, with updates required after any significant changes.
  • Parts II & III: Developed prior to recycling, these parts detail waste generated during the ship's operation (Part II) and residues or stores remaining onboard at the end of life (Part III), such as oils, fuels, and cleaning agents.

Key Compliance Requirements:

  • The IHM must be developed and maintained throughout the ship's lifecycle.
  • It must be certified by an authorized classification society or competent authority.
  • Ships without a verified IHM may face detention, refusal of entry into ports, or fines under port state control (PSC) inspections—especially in the EU and other HKC-aligned jurisdictions.

🏗️ 2. Ship Recycling Plan (SRP)

Before a vessel is sent for dismantling, the selected authorized ship recycling facility must prepare a Ship Recycling Plan (SRP), which is a vessel-specific document tailored to the ship's Inventory of Hazardous Materials (IHM).

The SRP must:

  • Clearly outline how each identified hazardous material will be safely removed, handled, stored, and disposed of, ensuring worker and environmental safety.
  • Include measures for fire safety, accident prevention, and pollution control.
  • Be approved by the competent national authority in the recycling state before any physical work begins.

This ensures that recycling is pre-planned, auditable, and transparent, mitigating ad hoc practices that have historically led to injury and environmental harm.

👷‍♂️ 3. Authorized Ship Recycling Facilities

Only certified and approved recycling yards may carry out dismantling activities under the HKC. To receive and maintain authorization, facilities must meet comprehensive requirements, including:

  • Health and Safety Measures: Proper personal protective equipment (PPE), worker training, and monitoring of workplace hazards.
  • Environmental Controls: Wastewater treatment systems, impermeable floors, waste segregation, and pollution mitigation strategies.
  • Emergency Response Preparedness: Firefighting systems, medical care, evacuation plans, and incident reporting.
  • Documented Procedures: Full traceability and recordkeeping, regular audits, and third-party inspections.

This ensures ship recycling occurs in controlled environments rather than on open beaches, promoting safer and greener end-of-life vessel management.

🇪🇺 HKC vs. EU Ship Recycling Regulation (EU SRR)

While the HKC is a global treaty, the EU Ship Recycling Regulation (EU SRR) is a regional law that has already been in effect since 2013 and applies to EU-flagged ships.

Feature HKC EU SRR
Scope Global coverage Applies only to EU-flagged vessels
Status Enters into force on 26 June 2025 In force since 31 December 2013
Recycling Yards Must be HKC-compliant Must be included on the EU-approved list of recycling facilities
IHM Requirements As per IMO guidelines Includes stricter criteria and additional materials
Certification Inventory Certificate (ICIHM), Ready for Recycling Certificate Similar structure, with EU-compliant formats

🔍 Important Note: Ships that call at EU ports or operate under EU flags must comply with both HKC and EU SRR to avoid penalties or restrictions. Harmonizing compliance with both regimes is essential for global operations.

June 2025: A Regulatory Deadline You Can't Ignore

After over a decade of anticipation, the Hong Kong Convention (HKC) is finally becoming legally binding—and the clock is ticking.

Effective 26 June 2025, the Convention will introduce mandatory compliance requirements for all parties involved in ship recycling. Key obligations include:

⛔ The Risks of Non-Compliance

Shipowners and managers who fail to prepare for HKC implementation may face serious consequences:

✅ Why You Must Act Now

With only a short window remaining, proactive compliance is not just recommended—it's essential. Aligning your operations with HKC requirements before the deadline will ensure uninterrupted global mobility, smoother vessel recycling processes, and a demonstrable commitment to sustainability and legal integrity.

🤝 How Varuna Sentinels BV Supports HKC Compliance

At Varuna Sentinels BV, we provide end-to-end HKC compliance solutions, helping shipowners, managers, and yards navigate this transition confidently.

📝 1. IHM Preparation & Certification

We:

  • Conduct detailed onboard surveys
  • Identify and document hazardous materials
  • Compile IHM Part I aligned with MEPC 379(80)
  • Coordinate with classification societies for certificate issuance

💡No IHM = No Port Access. Don't wait for last-minute complications.

🔄 2. IHM Maintenance via VSIMS

Our proprietary software—VSIMS (Varuna Sentinels IHM Maintenance Server)—ensures digital, up-to-date IHM compliance:

  • Monitor onboard material changes
  • Log Supplier's Declaration of Conformity (SDoC) and Material Declarations (MD)
  • Get proactive reminders and updates

📚 Stay audit-ready 24/7, not just at inspection time.

📝 3. End-of-Life Support for Recycling

We assist in:

  • Compiling IHM Part II & III
  • Applying for the Ready for Recycling Certificate
  • Coordinating with authorized recycling yards
  • Preparing and reviewing your Ship Recycling Plan (SRP)

♻️ We guide your vessel through a safe and legally compliant final voyage.

📚 4. Training & Capacity Building

We empower your teams with the knowledge needed to meet HKC standards:

  • Crew & staff training programs
  • DPA and superintendent webinars
  • Tailored audit prep templates and SOPs

🎓 Well-trained teams ensure long-term, sustainable compliance.

🏭 5. Compliance Consulting for Recycling Yards

Planning to become an HKC-compliant yard? We help you:

The Ship Recycling Facility Plan (SRFP) is a comprehensive, facility-wide document required by the HKC. It describes the yard's overall infrastructure, procedures, safety measures, and environmental controls for all recycling operations. While the SRFP covers the yard's general compliance and capabilities, the SRP is prepared for each individual ship to outline its specific recycling process.

  • Conduct a compliance gap analysis
  • Develop and submit Ship Recycling Facility Plans (SRFPs)
  • Train workers and implement documentation systems
  • Meet audit and reporting requirements

📈 HKC authorization opens the door to global ship recycling contracts.

🌍 Let's Shape the Future—Together

The Hong Kong Convention isn't just about legislation—it's about responsible transformation. As the world transitions to more sustainable maritime practices, early adopters stand to gain the most—in safety, trust, and business opportunities.

📩 Contact Varuna Sentinels BV Today

Let us help your fleet and facilities transition smoothly to HKC compliance.

📧 Email: contact@varuna-sentinels.com

🌐 Website: www.varuna-sentinels.com

🚢 Be HKC-ready before 26 June 2025—with Varuna Sentinels BV as your expert partner.