The Hong Kong Convention is in force — what it means for your vessel

For sixteen years, the Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships sat in limbo — ratified by too few flag states to take effect. That changed on 26 June 2025, when the Convention entered into force globally. The Inventory of Hazardous Materials is now a mandatory international requirement, not just a European one.

If your vessel is 500 GT or above, here is what that shift means in practice.

What actually changed on 26 June 2025

The HKC requires that all ships of 500 GT and above carry a certified Inventory of Hazardous Materials (IHM), maintained and verified throughout the vessel’s operational life. This was already a requirement for EU-flagged vessels under the EU Ship Recycling Regulation (EU SRR, Regulation 1257/2013), in force since 2013 and fully implemented from 2018. The HKC extends the same obligation globally — covering Cayman-flagged, Marshall Islands-flagged, Bahamian-flagged, and every other flag flying on a vessel above the GT threshold.

The practical document is the IHM Implementation Certificate (ICIHM), issued by your flag state administration or an authorised Recognised Organisation (typically your class society). This is the document a Port State Control officer will request.

Two additional documents apply specifically at the end of a vessel’s life — the Statement of Compliance for recycling, and a Ship Recycling Plan. For operational superyachts, neither is relevant yet. The ICIHM is what matters.

What a compliant IHM looks like

An IHM under the HKC has three parts, each with distinct obligations:

Part I — Hazardous materials in the vessel structure and equipment. This is the core of the IHM — a material-by-material inventory of hazardous substances installed in your vessel. The controlled substances are defined in Annex I of the Convention and include asbestos, polychlorinated biphenyls (PCBs), ozone-depleting substances, and anti-fouling compounds containing organotin (TBT). Part I must be verified against physical surveys and visual inspection of the vessel.

Crucially, Part I is not a one-time survey. It must be updated every time a material listed in Annex I of the Convention is added, removed, or changed. A replacement engine room fan with no hazardous materials requires no entry. A refrigerant recharge, or a refit that strips and replaces insulation, does.

Part II — Operationally generated waste. Waste streams that are hazardous and generated during vessel operations. Entries are cross-referenced to the relevant MARPOL Annex and supported by disposal receipts.

Part III — Operationally generated stores. Hazardous materials held on board for maintenance or operational use. Each entry requires a current Safety Data Sheet. When a product is superseded or reformulated, the SDS must be updated.

The survey cycle you need to track

The ICIHM follows a survey cycle defined in the Convention:

• Initial survey — before the ICIHM is issued, confirming the IHM is complete, accurate, and properly documented
• Renewal survey — at intervals not exceeding five years; the ICIHM is re-issued

Write down the dates now. ICIHM expiry and any open change records from the last refit are the two things most likely to cause problems at an inspection.

Your class society or flag state administration can advise on whether additional survey requirements apply under your specific registration.

PSC enforcement — what you need to be ready for

Port State Control authorities in HKC signatory states can inspect your ICIHM. For superyachts operating across the Mediterranean, the Caribbean, and the Pacific, this means most major ports are within scope.

An inspector may request:

1. The current ICIHM and its validity dates
2. The IHM itself — particularly that Part I is populated, not blank
3. Change records for the period since the last survey
4. Material Declarations and Statements of Compliance from contractors who supplied or installed equipment
5. Part III SDS documents for materials currently held on board

Areas that commonly generate PSC findings:

• ICIHM expired — missed renewal survey
• No change records for a known refit — equipment was replaced but the IHM was not updated
• Missing MD/SDoC documentation — a material change was made but contractor documentation was not collected
• Part III SDS gap — products on board with outdated or missing safety data sheets

For the applicable consequences and enforcement procedures, refer to your flag state administration or the relevant MOU (Paris, Tokyo, Indian Ocean, etc.) guidelines.

Flag state considerations

For superyachts:

• EU-flagged vessels (Cyprus, Malta, France, Germany, Netherlands, etc.): The EU SRR applies. Your vessel should carry an EU Inventory Certificate. The requirements are substantively similar to the HKC — if you are EU SRR compliant, you are close to HKC compliant.
• Non-EU flags: Check with your flag state administration whether the HKC has been ratified and what the certification pathway is. Most class societies (Lloyd’s Register, Bureau Veritas, DNV, RINA, ClassNK) are authorised to issue the ICIHM on behalf of multiple flag states.

If you are unsure which certification pathway applies to your flag, your class society is the correct first call.

A checklist for your next port call

Four things worth verifying before your vessel arrives at a HKC-signatory port:

1. ICIHM validity — is the certificate current, and is the next renewal date in your calendar?
2. Change records — is there any equipment replacement or refit work in the past five years without a corresponding IHM change entry?
3. MD/SDoC file — do you have Material Declarations and Statements of Compliance from the contractors who carried out that work?
4. Part III currency — are the Safety Data Sheets for your current stores up to date?

None of these require a survey. They require documentation discipline — knowing where the records are, that they exist, and that they cover what the inspector will ask about.

The practical reality

The HKC is not a new burden for vessels that have been maintaining their IHM properly. The change is enforcement reach: the obligations that EU-flagged vessels have operated under for nearly a decade now have global standing. For vessels that have treated the IHM as a one-time survey box-tick — typically drafted by a consultant at delivery and never touched since — that approach no longer holds.

The IHM is a living document. It moves when the vessel does. A refit that replaces refrigeration equipment updates Part I. A new cleaning product in the stores locker updates Part III. A contractor who supplies a piece of equipment owes you an MD. That chain of documentation, kept current, is what the ICIHM certifies.

For the full picture of what an IHM requires and how to keep it current, see our complete IHM for superyachts guide. For how the HKC certificate relates to the EU regime, see HKC ICIHM vs EU SRR Statement of Compliance.

MANTIS is IHM compliance management software for superyachts. It manages Part I/II/III records, tracks certificate expiry and survey intervals, stores MD/SDoC documentation, and generates survey-pack PDFs for class society review. Start free beta →