REQUIREMENTS

A ship registered with a flag state that is party to the HKC, or a ship being recycled in a country that is party to HKC, can only be recycled at a HKC-certified ship recycling facility — a facility holding a Document of Authorisation to conduct Ship Recycling (DASR).

The process requires notification to the flag state, followed by final survey which requires the owner to submit an IHM (Inventory of Hazardous Materials), SRP (Ship Recycling Plan) and a DASR.

After successful final survey, an International Ready for Recycling Certificate (IRRC) will be issued by the flag state or its registered organisation, which is valid for three months and can be extended thereafter for a single final voyage.

The ship recycling facility must, in writing, notify its competent authority of the SRF’s intent to receive a vessel for recycling. The SRF will submit the vessel’s details, together with the IHM, SRP and IRRC.

Upon completion of recycling, the SRF must notify its competent authority of such, and issue a certificate of completion in a form specified by the HKC in Appendix 7 of the convention.

PRESENT STATUS

India — has more than 100 HKC-certified SRFs. Circulars on the documentation required for vessels post-26 June 2025, as well as DASR issuance, are awaited from DG Shipping, the regulatory authority. DG Shipping has issued a circular on IHM Part I requirements for new and existing ships and that all ships covered under the HKC must recycle only at facilities holding a valid DASR.

Bangladesh — the Ship Recycling Board is the peak agency to monitor ship recycling activities. There are 10 SRFs that have received HKC certification with a Statement of Compliance from Class NK/IRS/Bureau Veritas. There is not yet a circular on procedural requirements after HKC enters into force, but only HKC-certified facilities will be allowed to import vessels for recycling. It is not yet clear how non-HKC facilities could receive a vessel to obtain HKC certification after the HKC enters into force.

Pakistan — the Karachi Port Trust (KPT) has issued a circular on IHM Parts I, II and III to be required for ships heading for recycling. Of seven SRFs working to obtain HKC certification, four are at an advanced stage. As directed by the Balochistan Development Authority (the relevant regulatory agency), once HKC enters into force, only those facilities that can demonstrate they have developed their recycling facility systems and infrastructure to HKC standards and want to recycle a vessel to proceed to HKC certification, will be permitted to import the vessel.

Türkiye — based on a circular dated 20 May 2025, local authorities have advised all SRFs to prepare a Ship Recycling Facility Plan (SRFP) and ensure that the SRP meets the specified requirement. A related circular on IRRC requirements and procedures is pending.

Not all flag states have yet come out with their processes for issuance of IRRC certification, but Liberia, Marshall Islands and Palau, among others, have laid out a specified procedure for obtaining such certification.

At the April-May Basel Convention COP17, there was insufficient consensus on accepting the HKC to replace the Basel Convention for ship recycling, so both conventions will thus be applicable to ships heading for recycling.

Constraints on the capacity for ship recycling could emerge if the flow of vessels for recycling drastically increases in early 2H25 from its present low levels. If such a rapid flow should transpire, HKC-certified SRFs will reap the benefits.

Specific workings at a party state level (countries that have ratified the HKC) should become clearer throughout June/July. Wirana is emphasising to all parties the importance of processes and requirements under HKC to be clear and well defined and understood.

All efforts have been taken to ensure that the information provided is accurate but more information circulated by party states may be available by the time of publication of this article — Wirana