ABS REGULATORY

NEWS
No. 12/2023

KEY NOTES
HONG KONG CONVENTION FOR THE Entry into force date:
SAFE AND ENVIRONMENTALLY 26 June 2025

SOUND RECYCLING OF SHIPS – Application:

­ Ships of 500GT or more engaged in

RATIFIED, ENTERING INTO FORCE international trade

­ Ship recycling facilities operating under

IN 2025 the jurisdiction of a Party to HKC.

References:
Resolution MEPC.379(80)
This Regulatory News provides guidance about the 2023 Guidelines for developing the IHM
Hong Kong Convention for the Safe and Environmentally include anti-fouling systems containing
cybutryne as a biocide
Sound Recycling of Ships.
HKSRC.1/Circ.21
Hong Kong International Convention for
BACKGROUND The Safe & Environmentally Sound
Recycling of Ships, 2009. Accession by
In 2005, the International Maritime Organization (IMO) General Bangladesh and Liberia. Entry into force.
Assembly adopted Resolution A.981(24), which directed the
Marine Environment Protection Committee (MEPC) to develop a
new legally binding instrument for ship recycling. On May 15, 2009,
the Hong Kong Convention (HKC) for the Safe and Environmentally Sound Recycling of Ships was adopted in
Hong Kong, China.
At the time of adoption, it was agreed that the HKC would come into effect 24 months after the following
required criteria were met:
 Ratification by not less than 15 States;
 Ratifying states represent not less than 40% of the world's merchant shipping by gross tonnage; and
 Ratifying states represent a ship recycling capacity of not less than 3% of the gross tonnage of the
combined merchant shipping of those States mentioned above.
On Monday, June 26, 2023, the accession by Bangladesh and Liberia triggered the entry into force of the HKC,
as the above conditions have now been met, and will enter into force on June 26, 2025. Its goal is to prevent
significant risks to human health and the environment throughout a ship’s operating life and during ship
recycling. Upon the entry into force of the HKC, new ships, and existing ships with a gross tonnage (GT) of 500
or more should have a valid International Certificate on Inventory of Hazardous Materials (IHM) no later than 5
years after the Convention's entry into force date or before being sent for recycling, whichever occurs first.

APPLICATION
HKC applies to ships of 500GT or more engaged in international trade and flying the flag of a party to the
Convention or operating under the authority of a flag of a party to the Convention, and to ship recycling
facilities operating under the jurisdiction of a party to the Convention.

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A. ENHANCE SHIP SAFETY, PROTECTION OF HUMAN HEALTH AND THE
ENVIRONMENT THROUGHOUT A SHIP’S OPERATING LIFE
Ships will be required to develop and maintain an Inventory of Hazardous Materials that consists of three parts:

 Part I: Hazardous materials listed in Appendices 1 and 2 to the Convention, contained in the ship’s
structure and equipment including their location and approximate quantities. The Convention prohibits
or restricts new installation of hazardous materials listed in Appendix 1, and it requires the recording of
new installations that contain hazardous materials listed in Appendix 2.
 Part II: Operationally generated wastes that are potentially hazardous to the environment and human
health at ship recycling facilities.
 Part III: Stores like regular consumable goods, which may potentially contain hazardous materials that
are not integral to a ship.

Part I should be developed following the 5-step approach outlined in the IHM Guidelines, verified on board, and
maintained during the operational life of the ship, while Parts II and III are to be developed to detail hazardous
material that will be delivered with the ship to the recycling facility.
Ships will undergo the following surveys:
 An initial survey to verify Part I of the IHM, before the International Certificate on Inventory of
Hazardous Materials is issued.
 A renewal survey at intervals not exceeding 5 years.
 An additional survey (either general or partial) at the shipowner's request after a change, replacement,
or significant repair.
 A final survey before recycling.
While IHM renewal surveys need not be harmonized with other statutory surveys, it is recommended to do so.

B. PREVENT AND TO THE EXTENT PRACTICABLE, ELIMINATE ACCIDENTS,

INJURIES AND OTHER ADVERSE EFFECTS ON HUMAN HEALTH AND THE
ENVIRONMENT CAUSED BY SHIP RECYCLING.
According to the HKC, each Party shall establish legislation, regulations, and standards that are necessary to
ensure that Ship Recycling Facilities are designed, constructed, and operated in a safe and environmentally
sound manner in accordance with the Convention. These facilities will need to develop a Ship Recycling
Facility Plan prior to being authorized by the Competent Authority(ies) of the Party. Prior to recycling a ship, an
authorized Ship Recycling Facility must prepare a ship-specific Ship Recycling Plan taking into account
information provided by the shipowner.

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 Figure 1: Ship Recycling Process from Preparation to Completion

2023 GUIDELINES FOR THE DEVELOPMENT OF THE INVENTORY OF

HAZARDOUS MATERIALS
In July 2023, the International Maritime Organization (IMO) adopted the 2023 Guidelines for developing the
Inventory of Hazardous Materials (IHM) (resolution MEPC.379(80)), specifically addressing the inclusion of
anti-fouling systems containing cybutryne as a hazardous material. These guidelines were introduced in
response to resolution MEPC.331(76), which implemented amendments to the Anti-Fouling Systems (AFS)
Convention regarding the regulation of cybutryne, a biocide commonly used in anti-fouling systems.

The 2023 Guidelines for developing the IHM include amendments to the Materials listed in appendix 1 of the
Annex to the Convention to include anti-fouling systems containing cybutryne as a biocide.

Threshold
Description
Value

Asbestos Materials containing asbestos 0.10%

“Polychlorinated biphenyls” means aromatic compounds

formed in such a manner that the hydrogen atoms on the
Polychlorinated biphenyls
biphenyl molecule (two benzene rings bonded together by 50 mg/kg
(PCBs)
a single carbon-carbon bond) may be replaced by up to
ten chlorine atoms
Controlled substances defined in paragraph 4 of article 1
of the Montreal Protocol on Substances that Deplete
the Ozone Layer, 1987, listed in Annexes A, B, C or E to
the said Protocol in force at the time of application or
interpretation of the Annex.
Ozone-depleting substances that may be found on
board ships include, but are not limited to:
• Halon 1211
Ozone depleting
• Bromochlorodifluoromethane no threshold value
substances
• Halon 1301 Bromotrifluoromethane
• Halon 2402 1,2-Dibromo-1,1,2,2- tetrafluoroethane
(also known as Halon 114B2)
• CFC-11 Trichlorofluoromethane
• CFC-12 Dichlorodifluoromethane
• CFC-113 1,1,2-Trichloro-1,2,2- trifluoroethane
• CFC-114 1,2-Dichloro-1,1,2,2- tetrafluoroethane
• CFC-115 Chloropentafluoroethane
Anti-fouling compounds and systems regulated under
Anti-fouling systems Annex I to the International Convention on the Control
2,500 mg total
containing organotin of Harmful Anti-fouling Systems on Ships, 2001 (AFS
tin/kg
compounds as a biocide Convention) in force at the time of application or
interpretation of the Annex
When samples are directly taken from the hull, average
values of cybutryne should not be present above 1,000 mg 1,000 mg/kg
Anti-fouling systems
of cybutryne per kilogram of dry paint.
containing cybutryne as a
When samples are taken from wet paint containers,
biocide
average values of cybutryne should not be present above 200 mg/kg
200 mg of cybutryne per kilogram of dry paint.
Figure 1: Hazardous Materials listed in Appendix 1

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ACTIONS FOR SHIPS TO COMPLY WITH HKC
New Ships
New ships of 500 GT and above contracted on or after June 26, 2025, must have an Inventory of
Hazardous Materials (IHM) in place upon delivery. The IHM Part I should be developed in accordance with
MEPC.379(80) during the design and construction phase based on the supplier's material declaration
forms and should be submitted to the Recognized Organization or flag Administration, along with
supporting information (Material Declarations (MD) and Supplier’s Declaration of Conformity (SDoC)).
Upon completion of the initial survey, the Recognized Organization or flag Administration will issue the
documentation detailing compliance with the IHM Part I.

Existing Ships
Some existing ships with IHM Part I may be able to undergo a simple verification by an attending surveyor,
while others may need to submit an updated IHM Part I for review.

 Existing ships that do not require IHM Part I technical submission

Existing ships with an IHM Part I technically reviewed by ABS for compliance in accordance with
resolution MEPC.269(68) or / and EU SRR (EU No.1257/2013) do not require IHM Part I technical
submission. These ships should ensure that they:
1. Have the ABS review letter of the IHM Part I in accordance with resolution MEPC.269(68)
or / and EU SRR;
2. Revise the IHM Part I in accordance with resolution MEPC.379(80) if necessary, or
present documentation that the vessel’s hull coating is cybutryne-free.

On completion of a satisfactory IHM Part I review and survey, the surveyor will issue a survey
report for compliance and issue the IHM certificates as appropriate.

 Existing ships that require IHM Part I technical submission

Existing ships with a reviewed IHM Part I according to the resolutions MEPC.197(62) or / and
MEPC.179(59) and existing ships without an IHM Part I should:

1. Develop their IHM Part I plan according to resolution MEPC.379(80),

2. Submit to ABS the updated IHM Part I for review,

Once reviewed, surveyor attendance will be required to verify that the reviewed IHM Part I is
onboard. The surveyor will also confirm the location of materials listed in the IHM Part I. On
completion of a satisfactory IHM review and survey, the surveyor will issue the IHM certificates
as appropriate.
Existing ships must meet the HKC requirements within five (5) years of the Convention's entry into
force on June 26, 2025, or before going for recycling if that occurs earlier. Ships proceeding to a
recycling facility may have the initial and final surveys held concurrently.

Existing ships with IHM Part I in accordance with

MEPC.269(68) MEPC.197(62) MEPC.179(59) (EU) No 1257/2013
2015 Guidelines 2011 Guidelines Guidelines EU SRR
Updated IHM Part I Updated IHM Part I
IHM Part I technical Do not require revised according to according to Do not require revised
submission IHM Part I technical MEPC.379(80) to be MEPC.379(80) to be IHM Part I technical
to ABS submission submitted for technical submitted for technical submission
review review

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 It is advisable to start preparing the IHM as soon as possible to ensure proper compliance. An initial
survey shall be conducted before the International Certificate on IHM is issued in order to prevent
potential future Port State Control interventions.

MAINTENANCE OF THE IHM

As new machinery, equipment, or other material are installed onboard the vessel, the item is to be provided
with the necessary MDs and SDoCs. Equipment that is detailed to have hazardous material in quantities above
the threshold values is to be included in the IHM Part I. When items listed in the IHM Part I are removed or
replaced, it is also necessary to update Part I of the IHM. However, if identical parts or coatings are installed or
applied, updating it is not required.

Moreover, Part I of the IHM should be considered an integral part of the ship, and it is crucial to ensure the
continuity and conformity of the information contained within it, especially in cases where there are changes in
the flag, owner, or operator of the ship.

OTHER SHIP RECYCLING REGULATIONS

REFERENCES
Document Title
Hong Kong International Convention for The Safe and Environmentally Sound Recycling of
HKSRC.1/Circ.21
Ships, 2009 - The Hong Kong Convention. Accession by Bangladesh and Liberia.
Resolution MEPC.379(80) 2023 Guidelines for the development of the Inventory of Hazardous Materials
Resolution MEPC.269(68) 2015 Guidelines for The Development of The Inventory of Hazardous Materials
Resolution MEPC.210(63) 2012 Guidelines for Safe and Environmentally Sound Ship Recycling
Resolution MEPC.197(62) 2011 Guidelines for The Development of The Inventory of Hazardous Materials
Resolution MEPC.179(59) Guidelines for The Development of The Inventory of Hazardous Materials
Regulation (EU) No 1257/2013 Ship recycling and amending Regulation (EC) No 1013/2006 and Directive 2009/16/EC
ABS IHM Guide ABS Guide for the Inventory of Hazardous Materials
EMSA IHM Guide EMSA Guidance on the Inventory of Hazardous Materials

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