Hong Kong Convention: Inventory of Hazardous Materials and Green Passport
In force since 26 June 2025, the Hong Kong Convention turns the Inventory of Hazardous Materials into a living document to be maintained for the ship's entire life, not just a formality of the final voyage to recycling.
Operational Explanation
The Hong Kong International Convention for the safe and environmentally sound recycling of ships entered into force on 26 June 2025. Every ship subject to the Convention must carry on board a specific Inventory of Hazardous Materials (IHM), made up of three parts: Part I is developed and kept updated throughout the ship's operational life, while Parts II and III are developed only in preparation for final recycling.
All ships of 500 GT and above engaged in international voyages must carry an International Certificate on Inventory of Hazardous Materials (ICIHM) no later than 26 June 2030, obtained in practice at the first harmonized renewal survey after 26 June 2025 (for ships flying the Cyprus flag, for example, the specific trigger date is 26 February 2026). From 26 June 2025, ships destined for recycling must also hold an International Ready for Recycling Certificate (IRRC) — the so-called "green passport" — issued upon completion of the final survey verifying Parts I, II and III of the IHM, with a validity of no more than 3 months.
Implementation status (2026): the authorization framework under the Convention is concretely consolidating. Two new HKC-compliant facilities have been authorized in Pakistan (Prime Green Recycling Yard in January 2026 and Salam's International in March 2026), joining facilities already authorized in India, Bangladesh and Turkey. The 15th edition of the European List of Ship Recycling Facilities (February 2026) counts 41 authorized facilities, including the first German facility on the list. Demolition volume in Bangladesh has instead recorded a notable decline (57 ships in the first half of 2025 versus 89 in the same period of 2024), reflecting the time shipyards need to adapt to the new requirements.
Regulatory Reference
Hong Kong International Convention, in force since 26 June 2025: requirement for a three-part Inventory of Hazardous Materials (IHM); ICIHM Certificate required by 26 June 2030 for ships ≥500 GT on international voyages (specific trigger date for the Cyprus flag: 26 February 2026); International Ready for Recycling Certificate (IRRC/"green passport") required from 26 June 2025 for ships destined for recycling, valid no more than 3 months. Authorized facilities in steady growth: 24 ratifying States, new HKC facilities in Pakistan (January and March 2026), 41 facilities in the 15th edition of the European List of Ship Recycling Facilities (February 2026).
Scope of Application
Every ship of 500 GT and above engaged in international voyages, with an obligation to keep Part I of the IHM updated throughout its operational life; Parts II and III apply only in preparation for the ship's final recycling.
Procedure / How to Complete It
- Prepare and keep Part I of the IHM updated throughout the ship's operational life, documenting any structural or equipment modification introducing new hazardous materials.
- Verify the timeline for obtaining the ICIHM Certificate, required by 26 June 2030 for ships of 500 GT and above on international voyages.
- In preparation for final recycling, develop Parts II and III of the IHM in coordination with the authorized recycling facility.
- Request the final survey verifying the complete IHM (Parts I, II, III) to obtain the International Ready for Recycling Certificate (IRRC).
- Plan timing carefully, given that the IRRC has a validity of no more than 3 months: recycling must take place within this window from certificate issuance.
Practical Example
Example: a Company systematically updates a ship's Part I of the IHM every time an extraordinary maintenance job introduces new materials (for example during an insulation system refit), keeping the document living and ready, years before having to face the final recycling process.
Real Cases
Common Mistakes Mistake Library
| Mistake | Consequence | How to avoid it |
|---|---|---|
| Part I of the IHM treated as a document to be prepared only close to final recycling | Difficult and imprecise retroactive reconstruction of the ship's hazardous materials history | Keep Part I of the IHM continuously updated throughout the ship's operational life |
| Timeline for obtaining the ICIHM Certificate (2030 deadline) not planned with adequate lead time | Risk of non-compliance with the deadline for ships that delay adaptation | Plan the ICIHM Certificate acquisition well before the 2030 deadline |
| The International Ready for Recycling Certificate's (IRRC) 3-month validity not considered in recycling planning | Certificate expired before actual completion of the recycling process | Closely coordinate timing between IRRC issuance and the actual start of recycling operations |
PSC Observations
Operational Tips
- Don't wait until the end of the ship's operational life to deal with the IHM: Part I must be kept updated from the outset.
- Plan the ICIHM Certificate acquisition well ahead of the 26 June 2030 deadline.
- Remember that the International Ready for Recycling Certificate has a validity of only 3 months: carefully coordinate timing with the recycling facility.
Checklist
- Part I of the IHM prepared and kept updated throughout the ship's operational life
- Timeline for obtaining the ICIHM Certificate (2030 deadline) planned
- Parts II and III of the IHM developed in coordination with the recycling facility in preparation for final recycling
- Final survey verifying the complete IHM requested to obtain the IRRC
- Timing between IRRC issuance (3-month validity) and start of recycling carefully coordinated
- Authorization status of HKC recycling facilities of interest monitored (e.g. European List of Ship Recycling Facilities, updated periodically)