The regime, end to end
The convention regulates both halves of the transaction. Ships of 500 gross tonnage and above entitled to fly the flag of a party State, or operating under its authority, must develop and maintain an Inventory of Hazardous Materials. Part I covers hazardous materials in the ship's structure and equipment. It is maintained throughout operating life and verified by survey, and the ship carries an International Certificate on Inventory of Hazardous Materials. The scope has two carve outs worth knowing. The convention does not apply to ships that operate throughout their lives only in waters subject to the sovereignty or jurisdiction of the party whose flag they fly, and it does not apply to warships, naval auxiliaries or other ships owned or operated by a party and used only on government non commercial service. At end of life the inventory is completed with operationally generated wastes and stores, which are Parts II and III. The ship may only go to a ship recycling facility authorised by a party State. The facility prepares a ship specific Ship Recycling Plan keyed to the inventory. The ship is then surveyed and issued an International Ready for Recycling Certificate before work begins. Facilities in party States must themselves be authorised by their competent authority, holding a Ship Recycling Facility Plan and demonstrating worker safety and environmentally sound management of each hazardous stream.
What entry into force changed
The convention required ratification, acceptance, approval or accession by 15 States, representing 40 per cent of world merchant shipping by gross tonnage, with a combined maximum annual recycling volume of at least 3 per cent of their combined tonnage. Accessions by Bangladesh and Liberia on 26 June 2023 met all three conditions at once and started the two year clock. The parties now include the countries where most of the world's tonnage is actually dismantled. Since 26 June 2025, the inventory and certificate regime and the authorised facility requirement have been binding for ships flying party flags. Existing ships have a transitional period: Part I of the inventory must be in place no later than 26 June 2030, or before the ship goes for recycling, whichever comes first. Five years sounds generous. It is one special survey cycle. For yards on the beaches of South Asia the convention has driven a visible investment cycle in impermeable floors, cranage, hazardous material handling and worker protection, with class societies auditing facilities against the standard. Progress has been uneven, but it is measurable.
The EU layer on top
European regulation adds a stricter parallel track. Under the EU Ship Recycling Regulation, Regulation (EU) No 1257/2013, EU flagged ships of 500 gross tonnage and above may only be recycled at facilities on the approved European List, and must hold an EU Ready for Recycling Certificate before they go. Since 31 December 2020, ships of any flag of that size calling at EU ports must carry a compliant Inventory of Hazardous Materials, evidenced by the inventory certificate for EU flagged ships or, for ships flying the flag of a third country, by a statement of compliance issued under that Regulation. The statement of compliance is an EU instrument. There is no equivalent interim document in the Hong Kong Convention itself. The interplay matters commercially. An owner's flag, trading pattern and end of life plans determine which regime binds, and the two are not identical in scope or in the list of approved facilities. The Basel Convention's waste trade rules can still reach transactions structured to avoid scrutiny.
What owners should do in practice
The operational obligations are continuous, not terminal. Keep Part I of the inventory genuinely current, updating it when machinery, coatings or equipment change. Hold the certificate through its renewals. Buy with the inventory in mind, because purchasing decisions write the hazardous materials ledger that the recycler eventually inherits. At end of life the sale contract is the control point. Naming an authorised or EU listed facility, requiring the recycling plan, and resisting the cash buyer detour is what separates a compliant demolition from a headline.