The Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships, 2009 (the Ship Recycling Convention or the Hong Kong Convention) was adopted in May 2009. After the entry into force of the Convention, the development and maintenance of an Inventory of Hazardous Materials, which identifies the amount and location of hazardous materials onboard a ship, will be required for all ships over 500GT. Furthermore, ships shall only be recycled at ship recycling facilities authorized by the competent authority. The following conditions have been met and the Convention will therefore enter into force on 26 June 2025.

1. Ratification by 15 States,

2. Representation by 40 per cent of world merchant shipping by gross tonnage, and

3. A maximum annual ship recycling volume not less than 3 per cent of the combined tonnage of the ratifying States

As of June 2023, the following twenty-two (22) countries have ratified.

Bangladesh, Belgium, Congo, Croatia, Denmark, Estonia, France, Germany, Ghana, India, Japan, Liberia, Luxembourg, Malta, Netherlands, Norway, Panama, Portugal, Sao Tome and Principe, Serbia, Spain, and Türkiye have acceded to the Convention.

Regulation (EU) No. 1257/2013 on Ship Recycling (EU-SRR), which is aimed at facilitating early ratification of the Hong Kong Convention 2009 - both within the EU and in other countries outside the EU - by applying controls to ships and ship recycling facilities on the basis of the Hong Kong Convention, came into effect in December 2013 and requirements such as the development of the inventory of hazardous materials (IHM) are applied from December 31, 2018 to EU flagged new ships and from December 31 2020 to EU flagged existing ships and Non-EU flagged ships calling at a port or anchorage of an EU member state.

For the IHM, New and Existing EU flagged ships must comply with Article 5 of the EU SRR, and Non-EU flagged ships must comply with its Article 12.

For Non-EU flagged ships, a statement of compliance (SOC) shall be issued in accordance with Article 12.6 of the EU-SRR after verification of the IHM by the relevant authorities of a Non-EU country whose flag the ship is flying or an organization authorized by them, in accordance with the national requirements. These documents shall be issued by or on behalf of the Flag state.

Considering that several thousand ships are likely to be unable to comply with the IHM obligations and may not have the required certification by the deadline of 31 December 2020 due to the disruptions caused by COVID-19, European Commission has published: Commission Notice 2020/C 349/01, suggesting EU member States to apply a harmonized approach towards enforcement during ship inspections, for a limited period of 6 months that is from 31 December 2020 to 30 June 2021.