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Hong Kong Convention 2009: Ship Recycling

The Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships, 2009, commonly called the Hong Kong Convention or HKC, is an International Maritime Organization (IMO) treaty that establishes a global framework for the environmentally sound and safe demolition of end-of-life vessels. Adopted at a diplomatic conference in Hong Kong on 15 May 2009, it entered into force on 26 June 2025 after Bangladesh and Liberia provided the ratifications needed to cross the 40% world tonnage threshold. The Convention introduces an Inventory of Hazardous Materials (IHM) that must accompany every ship from construction to demolition, imposes facility authorisation requirements on ship recycling yards, and creates a chain of certification linking shipowners, flag states, and recycling-state competent authorities. Approximately 700 to 900 ships are demolished each year, and around 85% of that tonnage is broken on the beaches of South Asia - principally at Alang in India, Chittagong in Bangladesh, and Gadani in Pakistan. The Hong Kong Convention is a central reference point for understanding the legal, environmental, and safety dimensions of that industry. ShipCalculators.com provides tools covering vessel scrap pricing, EU-approved recycling facility checks, hot work permits, and hazardous material handling.

Contents

Background and history

The rise of South Asian beach breaking

Ship demolition is among the most hazardous industrial processes in the global maritime sector. When a large ocean-going vessel reaches the end of its commercial life, the steel hull, machinery, and fitting-out materials must be recovered and processed. The economic driver is simple: a ship’s lightweight displacement, measured in light displacement tonnes (LDT), represents a large quantity of steel scrap, non-ferrous metals, and recoverable equipment whose aggregate value determines the vessel scrap price per LDT.

Through the 1960s and early 1970s, ship breaking was performed principally in Europe, Japan, and the United States, using dry docks and floating pontoons. Cost pressures and environmental regulations in those jurisdictions shifted the industry progressively toward South Asia. The beach-breaking method, in which a vessel is run aground at high tide on a gently sloping intertidal flat and dismantled in situ by large cutting gangs, allowed facilities in India, Bangladesh, and Pakistan to undercut conventional yards on labour cost. By the mid-1980s Alang in the Gulf of Khambhat (Gujarat, India) had become the world’s largest ship recycling location, and by the early 2000s Chittagong in Bangladesh and Gadani in Balochistan, Pakistan, had grown to comparable scale. Together, these three clusters account for around 85% of global ship demolition tonnage by most years.

The beach-breaking method concentrates hazardous materials - asbestos insulation, polychlorinated biphenyls (PCBs) in electrical fittings, heavy metals in anti-fouling coatings, tributyltin (TBT), heavy fuel oil sludge, and hundreds of tonnes of residual cargo - on unlined tidal zones with minimal containment infrastructure. Workers in early South Asian yards typically operated without respiratory protection when cutting asbestos-lagged pipe runs, without gas-free certification before hot work inside enclosed tanks, and without downstream treatment for liquid effluents. Reported fatality rates at Chittagong yards in the late 1990s and early 2000s reached alarming levels, attracting sustained scrutiny from the International Labour Organization (ILO), the Basel Action Network, and the NGO Shipbreaking Platform.

Regulatory precursors and the Basel debate

Prior to the Hong Kong Convention, the dominant international instrument applied to ship recycling was the Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and Their Disposal, adopted in 1989 and entering into force in 1992. Basel defined ships at end-of-life as hazardous waste when they contained listed hazardous substances, thereby theoretically restricting their export from OECD to non-OECD nations. The Basel Ban Amendment, adopted by the parties in 1995 and entering into force on 5 December 2019 after the requisite number of ratifications, explicitly prohibits the export of hazardous waste from Annex VII countries (OECD members, EU, Liechtenstein) to all other parties.

The practical application of Basel to ships was always contested. Shipowners and flag states generally argued that a ship underway is not waste, and that its classification as waste occurs only at the recycling facility, which is located within the importing country. Several IMO member states and the shipping industry pressed for an IMO-led instrument that would address both the environmental and safety dimensions of ship recycling without the trade-restrictive framing of the Basel waste regime. The IMO Marine Environment Protection Committee (MEPC) began work on ship recycling guidelines in the early 2000s, and this process culminated in the Hong Kong Convention.

Diplomatic conference and adoption

The Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships was adopted on 15 May 2009 at a diplomatic conference hosted by the Hong Kong Special Administrative Region of China and convened by the IMO. The conference drew delegations from 63 states and observers from inter-governmental and non-governmental organizations. The Convention text comprises a Preamble, 21 Articles, and 25 Regulations arranged in five Annexes, together with a set of technical guidelines adopted by the MEPC to support implementation.

Entry-into-force conditions required ratification by 15 states representing 40% of world merchant shipping gross tonnage, and that the combined maximum annual ship recycling volume of ratifying states represented 3% of their gross tonnage. These conditions had frustrated entry into force for 16 years: the major South Asian recycling states and key flag states were slow to ratify. The turning point came in June 2024 when Bangladesh and Liberia submitted their instruments of ratification to the IMO. With those additions, the 40% tonnage threshold was crossed, triggering the 24-month countdown. The Convention entered into force on 26 June 2025.

Structure of the Convention

The Hong Kong Convention is organised around five Annexes that correspond to distinct regulatory tasks.

Annex 1 contains the main substantive Regulations (1-25), covering definitions, general obligations, survey and certification of ships, and the requirements for recycling facilities.

Annex 2 contains the form for the International Certificate on Inventory of Hazardous Materials (ICIHM).

Annex 3 contains the form for the International Ready for Recycling Certificate (IRRC).

Annex 4 contains the Document of Authorisation to Conduct Ship Recycling (DASR) format.

Annex 5 contains the minimum content requirements for the Ship Recycling Plan (SRP).

The principal obligations flow through three chains: the ship chain (survey, IHM, certification), the recycling facility chain (authorisation, planning, reporting), and the state chain (flag state, recycling state, port state control).

Inventory of Hazardous Materials

Purpose and scope

The Inventory of Hazardous Materials (IHM) is the cornerstone document of the Hong Kong Convention. It is a structured record of all hazardous materials present in a ship’s structure, equipment, and stores. The IHM travels with the ship throughout its operational life and is handed to the recycling facility when demolition begins.

The IHM is divided into three parts. Part I covers materials that are intentionally used in the ship’s structure and equipment - asbestos, PCBs, ozone-depleting substances, anti-fouling systems containing organotin compounds, cadmium and cadmium compounds, hexavalent chromium compounds, lead and lead compounds, mercury and mercury compounds, polybrominated biphenyls (PBBs) and polybrominated diphenyl ethers (PBDEs), radioactive substances, and certain perfluorooctane sulfonates (PFOS). Part II covers operationally generated wastes such as oily bilge water, oily residues, sewage sludge, exhaust gas cleaning system (EGCS) residues, and similar. Part III covers ship stores, including chemicals, paint stocks, and cleaning agents.

Preparation and maintenance

For new ships, the IHM must be prepared before delivery and must be maintained throughout the operational life of the vessel. Regulation 5 requires the IHM to be verified and certified by the flag-state administration or a recognized organization acting on its behalf. Any modification to the ship - a major conversion, a refit, a change in anti-fouling coating, installation of new electrical equipment - must be assessed against the IHM and the document updated accordingly.

For ships in existence at the date of entry into force, flag states were required to ensure that an IHM was developed and certified within a defined compliance period aligned with the first scheduled renewal survey after entry into force. This transition arrangement allows existing fleets to phase in compliance during their normal survey cycles rather than requiring a single simultaneous retrofit.

The practical challenge of IHM preparation on existing ships is considerable. Older vessels built before asbestos bans - which came progressively in IMO instruments, the EU Working Environment Directive, and national legislation during the 1980s and 1990s - may have thousands of metres of asbestos-lagged pipework. The physical survey requires sampling in accordance with MEPC.269(68) guidelines, laboratory analysis, and thorough documentation of location, material type, and estimated quantity. Specialist IHM surveyors must carry out or supervise the work, and the process on a large bulk carrier or oil tanker may take several weeks.

International Certificate on Inventory of Hazardous Materials

Once the IHM has been prepared, verified, and accepted by the administration, the flag state issues an International Certificate on Inventory of Hazardous Materials (ICIHM). The ICIHM is a statutory certificate in the same category as the International Oil Pollution Prevention Certificate under MARPOL or the Safety Construction Certificate under SOLAS. It is subject to renewal surveys and may be endorsed at annual verification surveys. Port state control officers can inspect the ICIHM during port visits; a flag state that has ratified the Convention can detain a ship that lacks a valid certificate.

Ready for Recycling Certificate

Before a ship makes its final voyage to a recycling facility, the flag state issues an International Ready for Recycling Certificate (IRRC). The IRRC certifies that the ship satisfies the requirements of the Convention for delivery to a recycling facility, including that:

  • the IHM has been finalised and reflects the ship’s actual condition;
  • the Ship Recycling Plan (SRP) developed by the recycling facility specifically for that ship has been approved by the recycling state’s competent authority;
  • the ship-specific SRP has been transmitted to the master and the flag state;
  • quantities of fuel oil, sludge, residual cargo, and waste on board are minimised in accordance with the pre-recycling plan.

The IRRC has a maximum validity of three months or until the ship arrives at the recycling facility, whichever is earlier. This tight validity window is designed to prevent situations where a ship is certified, sold to a different buyer, and diverted away from the approved facility.

The practical implication is that the shipowner and the recycling facility must agree on the SRP before the final voyage begins. Given that scrap steel prices fluctuate, that facilities may have variable capacity, and that voyage distances from active trading areas to Alang or Chittagong may be several weeks, there is commercial pressure to proceed quickly once prices are favourable. The IRRC regime inserts a mandatory compliance step into that commercial timeline.

Ship Recycling Facility requirements

Authorisation and the DASR

A ship recycling facility (SRF) wishing to accept ships from flag states that have ratified the Hong Kong Convention must be authorised by the competent authority of the recycling state. The authorisation takes the form of a Document of Authorisation to Conduct Ship Recycling (DASR). The DASR specifies the types and sizes of ships the facility is authorised to recycle, the maximum throughput, and any conditions attached to the authorisation.

To obtain a DASR, the facility must develop and have approved a Ship Recycling Facility Plan (SRFP). The SRFP is a master plan for the facility that sets out:

  • the facility’s working procedures for dismantling operations;
  • the management approach for hazardous materials identified in incoming ships’ IHMs;
  • arrangements for preventing and controlling fires and explosions;
  • procedures for gas-freeing, tank cleaning, and hot-work permitting;
  • worker training and personal protective equipment requirements;
  • procedures for the downstream management of hazardous waste streams;
  • emergency response procedures;
  • arrangements for reporting accidents, occupational diseases, and near-misses to the competent authority.

Regulation 15 requires that the SRFP be approved by the recycling state’s competent authority before the DASR is issued. This creates a formal regulatory relationship between the facility and the national government, displacing the largely informal or absent oversight that characterised South Asian yards before the Convention.

Ship Recycling Plan

For each individual vessel, the facility must prepare a Ship Recycling Plan (SRP) based on the ship’s IHM and general arrangement. The SRP is ship-specific and must address at minimum: the sequence of dismantling operations; the identification and management of all hazardous materials listed in the IHM Parts I, II, and III; waste management routes including storage, transport, and disposal for each waste stream; fire and explosion prevention measures specific to that vessel’s configuration; and the procedures for Part II and Part III waste handling.

The SRP must be approved by the competent authority before the IRRC is issued to the shipowner. This double lock - facility plan and ship plan both approved before the vessel sails - is the Convention’s primary mechanism for closing the gap between the paper commitment to safe recycling and actual practice on the beach.

Hot work and gas-free requirements

Regulation 20 requires that facilities have implemented permit-to-work systems for hazardous operations including hot work and confined space entry. Hot work - cutting with flame or plasma, arc welding, grinding - on a ship that has carried hydrocarbons in its tanks or piping cannot be conducted safely unless the atmosphere in adjacent spaces has been tested and found to be gas-free. Gas accumulation in void spaces, cofferdams, and pump rooms on tankers and combination carriers represents a persistent explosion hazard. The tanker hot work permit and tank-freeing for hot work tools at ShipCalculators.com provide working calculations for the atmosphere monitoring requirements associated with this type of operation.

Asbestos management during hot work presents a distinct hazard. When asbestos-lagged pipe runs are cut, fibres are released and remain airborne for extended periods. Under the Convention, the IHM must identify all known or suspected asbestos locations before cutting begins, allowing workers to use appropriate respiratory protection and wet-suppression methods during removal. The IMSBC asbestos handling guide provides reference data on the physical properties and classification of asbestos as a cargo, which is relevant when removed asbestos must be packaged and transported off the facility as waste.

Hazardous materials regulated under the Convention

The Hong Kong Convention adopts a tiered approach to hazardous materials. Regulation 4 and its associated Appendix 1 list materials subject to prohibition or restriction when new ships are constructed or ships are converted. Appendix 2 lists materials subject to controlled management in the IHM.

Asbestos

Asbestos in all forms was prohibited in new ships from 1 January 2011 under the Convention schedule, consistent with the prohibition under SOLAS Regulation II-1/3-5 introduced by the MSC Resolution on 1 January 2011. Older ships built before the progressive national and IMO restrictions may contain chrysotile (white asbestos), amosite (brown asbestos), or crocidolite (blue asbestos) in pipe lagging, insulation boards, gaskets, rope packings, and fire-resistant panels. The quantities can be substantial: a post-Panamax container ship built in the early 1980s may contain several tonnes of asbestos material distributed across thousands of locations. The IHM regime requires all such material to be identified, quantified, and mapped before the ship reaches the recycling facility.

Polychlorinated biphenyls

PCBs were widely used in electrical transformers, capacitors, hydraulic equipment, and certain types of paint on ships constructed before 1980. Stockholm Convention obligations have progressively required the phase-out and disposal of PCB-containing equipment, but many older vessels still in service retain PCB-contaminated transformers in service rooms or refrigeration compressor systems. Under the Hong Kong Convention, PCB-containing items in excess of the Appendix 1 threshold must be listed in the IHM.

Tributyltin and other anti-fouling compounds

Tributyltin (TBT) was widely used as a biocide in anti-fouling paints until it was progressively banned under the MARPOL framework and the International Convention on the Control of Harmful Anti-Fouling Systems on Ships (AFS Convention, 2001, in force 2008). Ships built or repainted before the AFS ban may have TBT present in old paint layers beneath subsequent coatings. TBT is acutely toxic to marine organisms and can leach from scrap metal into the intertidal zone during beach breaking. The IHM must record TBT-bearing paint locations with estimated quantities.

Ozone-depleting substances

Refrigerant gases and fire-suppression agents containing chlorofluorocarbons (CFCs) or hydrochlorofluorocarbons (HCFCs) are subject to Montreal Protocol phase-out obligations. Ships operating refrigerated cargo systems or fixed fire-suppression systems charged with older refrigerants must list these substances in the IHM. Recovery of refrigerants before the torch reaches any refrigerant-bearing pipework is a mandatory pre-recycling task.

Heavy metals in coatings

Lead-based paint, chromate primers, and zinc-chromate coatings were standard on ships constructed before the 1990s. Lead and hexavalent chromium in paint are listed in Appendix 1 of the Convention. Removal and disposal of lead-containing paint debris from beach-breaking sites can contaminate intertidal sediments and marine food chains. The IHM mapping of paint systems allows the recycling facility to identify panels requiring abrasive blasting under controlled conditions with containment.

Flag state obligations and the last-voyage flag problem

Flag state survey and certification

Under the Hong Kong Convention, flag states are responsible for ensuring that ships flying their flag comply with the Convention’s survey and certification requirements. Flag state administrations may delegate survey functions to recognized organizations (classification societies) in the same manner as under SOLAS and MARPOL. The classification society must conduct an initial survey to verify the IHM, issue or endorse the ICIHM, and conduct renewal and annual surveys thereafter.

Flag states that are party to the Convention must also maintain registers of certified ships and report to the IMO on IHM compliance and recycling operations.

Last-voyage flag transfers

A well-documented pattern in the pre-Convention period involved shipowners transferring vessels to open registries immediately before the final voyage to a South Asian recycling beach. Registries in the Comoros, Tuvalu, and Saint Kitts and Nevis accumulated disproportionate shares of the world fleet in the final months before demolition, a phenomenon that NGOs characterized as deliberate evasion of Basel Convention obligations and flag state welfare requirements.

The motivation for these flag transfers was twofold. First, the Basel Ban Amendment restricted exports of hazardous waste from OECD states to non-OECD states. A ship registered in a non-OECD, non-Basel-Ban-ratifying state fell outside the export restriction. Second, some registries offered minimal inspection presence, meaning the ICIHM and other certificates would not be scrutinised before departure on the final voyage.

The Hong Kong Convention partially addresses this through Regulation 9, which requires that for an IRRC to be valid, the IHM must have been maintained and verified during the ship’s operational life - not merely prepared for the last voyage. A ship transferred to a new flag immediately before recycling would need a fresh IHM verification, creating an administrative obstacle to last-minute flag shopping. Full effectiveness depends on the major flag states - Panama, Liberia, the Marshall Islands, the Bahamas, and Hong Kong SAR - all being parties to the Convention, since these registries account for the overwhelming majority of world gross tonnage.

Recycling state obligations

The recycling state - the state whose territory contains the recycling facility - must establish a competent authority with defined responsibilities, including approving SRFPs, issuing DASRs, approving ship-specific SRPs, authorising the start of recycling operations (by issuing a Statement of Completion after demolition), and reporting to the IMO.

For India, Bangladesh, and Pakistan, Convention ratification represented a commitment to domestic regulatory infrastructure that had previously been absent or unenforced. Bangladesh ratified in June 2024, becoming the first of the major beach-breaking states to do so, with its ratification being one of the two that triggered the entry-into-force countdown. India had ratified earlier. Pakistan remains in the ratification process as of mid-2025.

The competent authority in a recycling state must also maintain a list of authorised ship recycling facilities in a publicly accessible format, and communicate that list to the IMO for inclusion in the global GISIS database.

EU Ship Recycling Regulation

Regulation (EU) No 1257/2013

The European Union acted in parallel with the IMO process, enacting Regulation (EU) No 1257/2013 on ship recycling. The regulation entered into force on 31 December 2018 and applies to ships flying the flag of an EU member state and ships calling at EU ports. It requires EU-flagged ships to carry an IHM equivalent to the Hong Kong Convention standard, and restricts recycling to facilities on an EU list of approved yards.

The EU Ship Recycling Regulation approved facility check tool at ShipCalculators.com allows operators to verify whether a given recycling facility appears on the current European List of ship recycling facilities. The list is maintained by the European Commission and updated periodically. It includes both EU-located facilities (principally in Belgium, Denmark, the Netherlands, Turkey, and the United Kingdom) and non-EU facilities that have been assessed against the equivalent requirements and approved.

Scope differences from the Hong Kong Convention

The EU regulation differs from the Hong Kong Convention in several respects. The EU regulation covers ships of 500 gross tonnes (GT) and above calling at EU ports or flying EU flags, whereas the Hong Kong Convention’s application threshold is 500 GT engaged in international voyages. The EU list-based approach gives the European Commission direct oversight of which specific yards are permissible, rather than relying solely on the recycling state’s competent authority to authorise facilities. The EU regulation also explicitly prohibits recycling at non-listed facilities, with financial penalties enforceable through port state control.

A ship that complies with the EU Ship Recycling Regulation is substantially in compliance with the Hong Kong Convention, since the IHM format, survey requirements, and facility standards are substantively aligned. The EU regulation thus served as an interim framework during the 16 years between the Convention’s adoption and its entry into force, creating IHM practice and facility standards in the market before the global treaty became binding.

Relationship with the Basel Convention

Parallel and competing regimes

The relationship between the Hong Kong Convention and the Basel Convention has been one of the most contested aspects of the international law of ship recycling. Basel’s Annex IX lists “ships and other floating structures for breaking up, properly emptied of any cargo, including ballast water, which may have been classified as a hazardous substance or pollution, cleaned of residues.” Ships meeting those conditions were initially exempted from Basel’s export controls. However, the COP decisions and NGO litigation in several jurisdictions challenged this exemption, arguing that ships containing asbestos, PCBs, and TBT fell within the Annex VIII hazardous waste category regardless of whether tanks were cleaned.

The Hong Kong Convention was explicitly designed to provide a lex specialis for ship recycling that, once in force, would displace Basel’s application to ships. The preamble acknowledges the Basel Convention and the need to ensure an equivalent level of environmental control. Environmental NGOs, including the Basel Action Network and the Shipbreaking Platform, have consistently argued that the Hong Kong Convention’s equivalent-level-of-control claim is unsubstantiated because beach-breaking facilities in South Asia cannot in practice achieve the containment standards that Basel-compliant waste facilities would require.

The Basel ban amendment and flag reflagging

The Basel Ban Amendment, entering into force in December 2019, explicitly prohibits export of hazardous wastes from Annex VII parties to all other countries. This creates a direct conflict with the common practice of selling vessels from OECD-registered companies to South Asian recycling facilities. The reflagging strategy described above - transferring the ship to a non-Annex VII registry just before the final voyage - was the primary mechanism used to circumvent this prohibition. Under that approach, the ship departed from the OECD seller as a vessel flying a flag of convenience registered in a non-Annex VII state, and therefore the Basel Ban’s export restriction did not apply to the sending country.

The Basel waste export check calculator at ShipCalculators.com provides a reference tool for assessing whether a given waste export transaction falls within Basel’s notification and consent requirements - relevant to recycling facilities and shipowners navigating the overlap between the two regimes.

Industry structure and economics

Light displacement tonnes and scrap value

The commercial value of a ship sent for recycling is determined primarily by the vessel’s LDT and the prevailing scrap steel price in the relevant recycling market. LDT is the displacement of the ship without cargo, fuel, fresh water, ballast, crew, provisions, or stores - essentially the weight of the steel hull and fixed machinery. A large crude oil tanker of the very large crude carrier (VLCC) class may have an LDT of 40,000 to 50,000 tonnes. At the South Asian scrap prices that prevailed in 2024 of approximately US$500 to US$600 per LDT, such a vessel might yield US$20 million to US$30 million in scrap value. The vessel scrap price per LDT calculator provides current and historical price references for the Alang, Chittagong, and Gadani markets.

Beach-breaking facilities in South Asia consistently offer higher prices than yards in Turkey, China, or Northern Europe because their labour costs are lower, their environmental compliance costs have historically been minimal, and their land costs are negligible compared with hard-stand yards. The differential is typically US$50 to US$150 per LDT. That premium is sufficient to make the South Asian beach the economically dominant destination for end-of-life tonnage despite the reputational and, increasingly, regulatory risks.

Annual volumes and industry concentration

Approximately 700 to 900 large vessels are demolished each year globally by weight of steel recovered. The precise figure varies with the shipping cycle: high freight rates and rising asset values encourage owners to keep older ships in service, while a freight market downturn triggers accelerated demolition of marginal tonnage. Tankers and bulk carriers dominate the scrapping market by LDT because their large steel hulls contain relatively little complex machinery or electronics per tonne of hull steel compared with container ships.

Alang, located on the Gulf of Khambhat coastline of Gujarat, India, processes the largest single share of global scrapping by most years. At peak, Alang had over 170 working plots, each capable of accommodating one large vessel. Chittagong, Bangladesh, and Gadani, Pakistan, each process substantial volumes, with Gadani being the older facility that has seen variable activity depending on domestic economic conditions and safety enforcement.

Worker health and safety record

The fatality rate in South Asian ship breaking has historically been significantly higher than in comparable heavy industries in the same countries. Deaths from falls from heights, from explosion during hot work without gas-free certification, from asbestos-related disease (mesothelioma, asbestosis), and from structural collapse of weakened hull sections have all been documented. The NGO Shipbreaking Platform has maintained a fatality register since the mid-2000s, reporting between 20 and 40 recorded deaths per year across South Asian facilities, with the true figure likely higher due to underreporting.

The Convention’s requirement for SRFP approval and DASR issuance was designed to institutionalise a government-approved minimum safety standard at each facility, including fire and explosion prevention, gas-free certification before hot work, and personal protective equipment requirements. The practical impact depends on the rigour with which recycling state competent authorities conduct facility inspections and enforce permit conditions.

IMO guidelines and technical support

MEPC guidelines

The IMO MEPC adopted a set of guidelines to support Convention implementation. The 2012 guidelines (MEPC.196(62)) addressed the development of the IHM. MEPC.269(68) provided further guidance on surveys and certification. Guidelines on the development of the Ship Recycling Facility Plan and the Ship Recycling Plan were adopted in parallel. These guidelines are not mandatory instruments but are referred to by administrations and recognized organizations as the interpretive framework for applying the Regulations.

Recognised organizations and classification societies

Classification societies - Lloyd’s Register, Bureau Veritas, DNV, American Bureau of Shipping, ClassNK, Korean Register, and others - serve as recognized organizations for IHM verification and ICIHM issuance on behalf of flag states. The International Association of Classification Societies (IACS) developed Unified Requirements and guidance circulars establishing a common approach to IHM surveys, sampling protocols, and document formats across member societies. This harmonisation is important because a ship may change classification society or flag during its operational life, and the IHM must remain coherent across those transitions.

Notable incidents and their legacy

Probo Koala (2006)

The Probo Koala incident preceded the adoption of the Hong Kong Convention but directly influenced its content. In August 2006, the tanker Probo Koala discharged approximately 500 tonnes of coker naphtha washings and caustic soda waste in Abidjan, Côte d’Ivoire, after being refused reception at the port of Amsterdam where the waste would have required expensive treatment. The waste was collected by a local contractor who dumped it at multiple sites around Abidjan, causing the deaths of at least 15 people and injury to thousands. The incident, while not a ship recycling case in the strict sense, dramatised the consequences of inadequate downstream waste management and the ability of commercial actors to evade expensive disposal requirements in developed countries by discharging in jurisdictions with less capacity to handle hazardous maritime waste. The downstream waste management requirements in Regulation 20 of the Hong Kong Convention - requiring that recycling facilities document and manage all hazardous waste streams from demolition - were shaped partly by this type of regulatory failure.

Seawise Giant / Jahre Viking

The Seawise Giant (later Jahre Viking, then Knock Nevis, and finally Mont), the world’s largest ship by displacement, was broken at Alang in 2010 after a career spanning several decades. As one of the highest-profile demolition cases in the history of the beach-breaking industry, its arrival at Alang attracted international media attention and illustrated the gap between the recycling practices required under the pre-Convention guidelines and what actually occurred on the beach at that time.

Downstream waste management

Waste streams from ship demolition

A large ocean-going vessel arriving at a recycling facility carries a complex mixture of solid and liquid waste streams that must be managed separately from the recoverable steel and equipment. The Convention’s Regulation 20 requires that the SRFP and SRP both address the full downstream management chain for each material type.

Liquid waste streams include residual fuel oil and lubricating oil from tanks and sumps that were not fully drained before departure on the final voyage, residual cargo in the case of tankers, oily bilge water accumulated in engine room bilges during the delivery voyage, hydraulic oils from deck machinery and steering gear, and refrigerant gases from air conditioning and refrigeration systems. Each of these must be collected in designated containers, transferred to appropriately licensed treatment or disposal facilities, and the chain of custody documented.

Solid hazardous waste streams include asbestos-containing materials removed before cutting begins, PCB-containing transformers and capacitors, batteries including both lead-acid starting batteries and nickel-cadmium alkaline batteries from emergency systems, mercury-containing lighting including fluorescent tubes and high-pressure discharge lamps, pyrotechnic distress signals containing explosive and flare compounds, and fire extinguisher charges containing halon or dry powder. The IHM’s Part I and Part III listings allow the facility to compile an expected waste inventory before the ship arrives, enabling advance arrangement of specialist disposal contractors.

Electronic waste - navigation equipment, communication systems, computers, radar systems, gyrocompasses - constitutes a growing fraction of demolition waste, particularly on newer vessels. Many of these items contain rare earth elements, beryllium compounds in ceramic capacitors, and brominated flame retardants in circuit boards. The Convention does not specify downstream disposal routes for e-waste beyond the requirement that the SRFP address it, leaving domestic waste regulations in the recycling state to determine the actual disposal pathway.

Downstream contractor authorisation

Regulation 15 requires that the SRFP identify the downstream waste management contractors and verify that they are authorised under domestic law to accept each category of hazardous waste. This contractor-chain verification is one of the more operationally demanding aspects of Convention compliance for South Asian yards, because the waste management infrastructure in India, Bangladesh, and Pakistan has historically been fragmented, with authorisation status varying by state and by waste category.

In India, the Hazardous Waste (Management, Handling and Transboundary Movement) Rules, revised in 2016, govern the licensing of hazardous waste treatment, storage, and disposal facilities (TSDFs). An Alang yard seeking DASR authorisation must demonstrate that its contracted TSDFs are validly licensed by the Gujarat Pollution Control Board for each waste category generated during demolition. For asbestos, this means transfer to one of the few asbestos-designated landfill sites in India, which may be located hundreds of kilometres from Alang, with corresponding transport documentation requirements.

Bangladesh ratified the Convention partly on the basis of commitments made by its Ministry of Industries and the Department of Environment to upgrade TSDF capacity to handle the hazardous waste volumes that would be documented under Convention-compliant SRPs. The practical development of that infrastructure continues alongside the Convention’s implementation.

Pre-recycling preparation and the final voyage

Cargo and tank cleaning obligations

Before a ship can lawfully proceed to a recycling facility under the Hong Kong Convention, it must complete a set of preparatory steps that minimise the volume of hazardous or polluting materials on board. For a tanker, this typically requires cargo stripping to the maximum extent practicable, tank washing to reduce oil residues below the IRRC threshold, discharge of slops and oily water residues to shore reception facilities at a last port of call, and removal or discharge of chemical cleaning agents used in tank washing. The heavy fuel oil remaining in fuel service tanks and settling tanks at the last bunkering port must be reduced to the minimum required for the delivery voyage.

For a container ship, the pre-recycling preparation involves the removal of any refrigerant charges from reefer units that will not travel to the recycling facility with the ship, discharge of remaining lashing equipment to a facility that can sort and recycle it, and the removal of any residual cargo. For a bulk carrier, residual bulk cargo in holds presents a containment issue at the recycling facility, particularly if the cargo is classified under the IMSBC Code as a material harmful to the marine environment (MHB).

Stability and structural integrity on the final voyage

Ships proceeding to recycling are frequently in a deteriorated condition relative to the safety standards required for conventional commercial operation. Hull plating may be thinned by corrosion, structural members may have wastage beyond class limits, and machinery may be operating in a degraded state. Despite this, the vessel remains subject to SOLAS stability requirements for the delivery voyage, and the flag state must be satisfied that the vessel is seaworthy.

Some flag states and classification societies issue special voyage permits for vessels that are technically out of class but assessed as fit to proceed under restricted conditions - for example, with a limited weather window, specific routing, and tug escort - to the recycling facility. These voyage-only certificates are analogous to the provisional certificates issued for other irregular voyages. The IRRC cannot be issued to a vessel that does not have a valid seaworthiness certificate for the delivery voyage, creating a procedural link between the Convention’s recycling certification system and the conventional safety certification framework.

Environmental contamination at recycling sites

Intertidal and coastal contamination

Beach-breaking operations at Alang, Chittagong, and Gadani have been the subject of multiple environmental assessments documenting contamination of intertidal sediments and nearshore waters. Studies published in peer-reviewed journals since the late 1990s have recorded elevated concentrations of polycyclic aromatic hydrocarbons (PAHs), tributyltin, lead, cadmium, chromium, zinc, and copper in sediment samples from active and former breaking plots, at levels significantly above background concentrations for comparable coastlines.

The contamination pathways are multiple. Oil spills during tank opening, paint scale containing lead and TBT released into the intertidal zone, asbestos fibres deposited on the beach surface and redistributed by tidal action, and battery acid released during battery cutting all contribute. The concentration of breaking activity over several kilometres of coastline at Alang means that even diffuse releases from individual plots aggregate into a chronic contamination gradient that affects benthic invertebrate communities and fish populations in the nearshore zone.

The Convention’s requirement for containment infrastructure - lined drainage collection systems, impermeable working surfaces, covered areas for asbestos removal - addresses these pathways in principle. Whether implemented facilities in practice achieve the containment levels needed to prevent intertidal contamination depends on the rigor of competent authority inspections and the enforcement of permit conditions during actual operations.

Groundwater and soil contamination

Recycling facilities above the intertidal zone, including the cutting of ship sections that have been moved ashore, generate liquid wastes that can percolate into soil and groundwater. Hydraulic oils, battery electrolyte, and PCB-containing transformer oils have been detected in groundwater monitoring wells at or adjacent to some South Asian yards. The SRFP requirement to address liquid containment applies to the entire facility footprint, not only the intertidal zone, and must include provisions for groundwater monitoring where facilities are sited above permeable formations.

The remediation of contaminated land and sediments at legacy beach-breaking sites represents a long-term environmental liability that predates the Convention and is not directly addressed by its provisions. Several plots at Alang that ceased operations in the early 2000s remain contaminated, and the question of remediation responsibility is unresolved under Indian domestic law.

Survey and certification timeline

Survey categories

The Hong Kong Convention establishes four survey categories for the ICIHM, following the pattern of SOLAS and MARPOL certificates.

The initial survey is conducted before the ICIHM is issued for the first time, verifying that the IHM has been prepared in accordance with the Convention’s requirements and that the ship complies with the relevant regulations.

The renewal survey is conducted at intervals not exceeding five years, verifying that the IHM remains complete and accurate and that the ship continues to comply.

The additional survey is conducted when a change to the ship - a major conversion, a change in anti-fouling system, the installation of new equipment potentially containing regulated materials - requires updating the IHM. The additional survey verifies the updated entries.

The final survey is conducted before the IRRC is issued, confirming that the IHM reflects the final pre-recycling condition of the ship and that the ship is ready for delivery to the authorised recycling facility.

Recognized organizations and survey delegation

Flag states may delegate the conduct of IHM surveys and the issuance of ICIHMs to recognised organizations (ROs), which in practice means the major classification societies. The RO acting on behalf of a flag state has the same authority to issue, endorse, and withdraw certificates as the administration itself. This delegation creates a commercial relationship between the shipowner (who typically pays the classification society’s survey fees) and the certifying body, which has attracted criticism from environmental NGOs who argue that commercial incentives may influence survey thoroughness.

The IACS Unified Requirement Z17, adopted in response to the Hong Kong Convention requirements, establishes minimum standards for how classification societies must conduct IHM surveys, including sampling protocols for suspect materials, laboratory analysis methods, and the handling of IHM data across flag or class transfers. A ship that changes class society must ensure that the IHM is transmitted in full to the new society, and the new society must verify it against the ship’s current condition before endorsing the certificate.

Enforcement and port state control

The Hong Kong Convention provides for port state control (PSC) inspection under Regulation 14, following the same framework as SOLAS and MARPOL. A PSC officer in a port state that has ratified the Convention may inspect any ship in port to verify that a valid ICIHM is carried and that the IHM is maintained. If deficiencies are found - an expired certificate, an IHM that does not reflect the ship’s actual condition, missing verification endorsements - the PSC officer may issue deficiency notices requiring correction. Significant deficiencies may result in detention until corrective action is demonstrated.

Port state control memoranda of understanding, including the Paris MOU (covering European and North Atlantic waters), the Tokyo MOU (Asia-Pacific), and others, coordinate inspection campaigns and share deficiency data. The Paris MOU began incorporating Hong Kong Convention inspection items into its electronic information system following entry into force. Port state control inspections covering the ICIHM are thus integrated into the same operational framework as inspections for SOLAS safety certificates, MARPOL pollution prevention, and MLC 2006 labour standards.

Interaction with other maritime conventions

The Hong Kong Convention sits within a framework of related international instruments. Ships proceeding to recycling must also comply with the pre-cleaning and de-gassing requirements consistent with MARPOL Annexes I through VI before departure on the final voyage, to minimise the volume of oil residues, sewage, and garbage on board. MARPOL Annex I requirements for tankers - oil residue disposal, tank cleaning records - are directly relevant to the pre-recycling preparation phase.

SOLAS remains in force for ships on the final voyage to the recycling facility, including stability, fire protection, and life-saving appliance requirements. The Convention does not exempt ships from SOLAS obligations merely because they are proceeding to demolition.

The Ballast Water Management Convention requires that ballast water exchange or treatment be carried out in accordance with the Convention’s requirements even on a final voyage, and the pre-recycling discharge of ballast tanks must comply with the convention’s D-2 biological treatment standard in waters where that standard applies.

Labour standards at the ship recycling facility engage the ILO’s Occupational Safety and Health Conventions as well as domestic labour legislation in the recycling state. The Maritime Labour Convention 2006 applies to seafarers on the delivery voyage, not to the shore workers at the recycling facility, but the ILO’s instruments on occupational safety in shipbuilding and ship-repairing extend to ship recycling contexts in states that have ratified them.

Ongoing issues and current developments

IHM compliance transition

The 12-month period following entry into force on 26 June 2025 represents the primary transition window for flag states to ensure existing vessels carry valid ICIHMs. In practice, because IHM preparation and survey verification require physical access to the vessel, the bottleneck is the availability of qualified IHM surveyors and the capacity of flag state administrations and recognized organizations to process the volume of certificates required. Classification society notices issued in 2024 and 2025 indicated that IHM survey backlogs were developing, particularly for older vessels with complex hazardous material profiles.

Flag states with large older fleets - including those of several Pacific island open registries that have ratified the Convention - face the practical challenge of ensuring that their registered tonnage is surveyed before the compliance deadline. Vessels that miss the compliance window become subject to detention risk at PSC inspections and, more critically, cannot receive a valid IRRC when sent for recycling.

South Asian facility upgrading

Investment in hard-stand recycling infrastructure in Alang and Chittagong has accelerated since 2019, driven partly by the EU Ship Recycling Regulation’s requirement that EU-flagged vessels recycle only at listed facilities. Several Alang plots have been upgraded from beach-based operations to yards with concrete aprons, covered dismantling halls, lined effluent collection sumps, and certified atmospheric monitoring systems. As of 2025, a growing number of Alang and Chittagong facilities appear on or have applied for the European List.

The economics of facility upgrading are significant. A full hard-stand conversion of a large Alang plot may cost US$10 million to US$20 million, and the continuing operating cost of environmental compliance - effluent treatment, atmospheric monitoring, hazardous waste logistics to licensed downstream processors - is substantially higher than beach-based operations. This cost must be recovered from the LDT price differential over competing facilities, which creates a continuing competitive tension between compliant and non-compliant yards within the same location.

NGO monitoring and transparency

The Shipbreaking Platform, a Brussels-based NGO coalition, publishes an annual report on global ship recycling statistics including fatality counts, facility-by-facility volume data derived from ship registration databases, and assessments of the relationship between reported practices and the Convention’s requirements. The Platform has been a consistent critic of the Hong Kong Convention on the grounds that the beach-breaking method is inherently incompatible with the containment requirements necessary for truly equivalent-level environmental control, and that the Convention’s enforcement architecture depends too heavily on recycling state competent authorities whose capacity and independence vary significantly.

The Platform’s position is that the Basel Ban Amendment provides a stronger legal tool for restricting the export of end-of-life ships to South Asian beaches from OECD states, and that the Hong Kong Convention should be interpreted as a floor rather than a ceiling on protection. This tension between the IMO’s jurisdiction-based approach and the Basel Convention’s trade-restriction approach continues to be litigated in academic and policy forums.

MARPOL

MARPOL addresses pollution from ships in operation - oil discharges, noxious liquid substances, packaged goods, sewage, garbage, and air emissions. It does not regulate what happens to the ship at end of life. The Hong Kong Convention fills this gap by addressing the ship as a product containing hazardous materials that must be managed on decommissioning. The two instruments overlap in the pre-recycling cleaning phase: MARPOL Annex I requires that oil residues be discharged to reception facilities before the ship is delivered to the recycler, and the IHM must account for any residuals that remain.

SOLAS

SOLAS establishes the safety standards for ships in service, including structural fire protection, life-saving appliances, and stability. The Hong Kong Convention builds on SOLAS in the sense that the IHM’s Appendix 1 list of prohibited and restricted materials overlaps with SOLAS Regulation II-1/3-5 (prohibition of asbestos in new ships). The safety requirements for the recycling facility itself - hot work permits, confined space entry, gas-free certification - parallel the SOLAS tanker safety regime but are applied in the context of an industrial shore facility.

ISM Code

The ISM Code requires that shipowners maintain a Safety Management System covering all safety-critical operations. For ships approaching end-of-life, the SMS should include procedures for pre-recycling preparation, IHM maintenance, and liaison with the recycling facility. Some flag states and recognised organizations have issued circulars clarifying how the ISM Code’s documented procedures requirement interacts with the Hong Kong Convention’s IRRC prerequisites.

EU ETS for shipping

Since 2024, large ships calling at EU ports have been subject to the EU Emissions Trading System, which applies to CO2 emissions. Vessels approaching end-of-life may have elevated carbon intensities and face increasing surrender obligations under the ETS. The economic calculus for owners of older, less efficient vessels - balance the cost of ETS surrenders in the final trading years against the scrap premium from the South Asian market - is increasingly shaped by these overlapping regulatory costs. The EU ship recycling list check tool allows operators to assess whether a facility is available that satisfies both the ETS territorial scope and the Ship Recycling Regulation compliance requirement.

See also

References

  1. International Maritime Organization. Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships, 2009. IMO, London, 2009.
  2. IMO MEPC Resolution MEPC.196(62). 2012 Guidelines for the Development of the Inventory of Hazardous Materials. MEPC, 2012.
  3. IMO MEPC Resolution MEPC.269(68). 2015 Guidelines for the Surveys and Certification of Ships under the Hong Kong Convention. MEPC, 2015.
  4. Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and Their Disposal, 1989. United Nations Environment Programme.
  5. Basel Ban Amendment (Decision III/1), adopted 1995, entered into force 5 December 2019. Basel Convention COP.
  6. Regulation (EU) No 1257/2013 of the European Parliament and of the Council on ship recycling. Official Journal of the European Union, L 330, 10 December 2013.
  7. International Convention on the Control of Harmful Anti-Fouling Systems on Ships, 2001, entered into force 17 September 2008. IMO.
  8. NGO Shipbreaking Platform. Annual Reports on Global Ship Breaking Statistics. Brussels, various years.
  9. Rousmaniere, P. and Raj, N. “Shipbreaking in the developing world: problems and prospects.” International Journal of Occupational and Environmental Health, 13(4), 2007.
  10. International Labour Organization. Safety and Health in Shipbreaking: Guidelines for Asian Countries and Turkey. ILO, Geneva, 2004.
  11. European Commission. European List of Ship Recycling Facilities. Published under Regulation (EU) 2015/757, updated periodically.

Further reading

  • Mikelis, N. “A statistical overview of ship recycling.” International Symposium on Maritime Safety, Science and Its Sustainability (IMAM), 2007.
  • Hiremath, A.M., Tilwankar, A.K., and Asolekar, S.R. “Significant steps in ship recycling vis-a-vis wastes generated in a cluster of yards in Alang.” Journal of Cleaner Production, 87, 2015.
  • Sarraf, M. et al. Ship Breaking and Ship Recycling: Closing the regulatory gap. World Bank, Washington D.C., 2010.