About
Although the Convention was adopted in 2009, the threshold of ratifying states representing a sufficient percentage of the gross tonnage of the world's merchant shipping and the ship recycling volume was not met until 26 June 2023.
The Hong Kong Convention contains requirements that concern both ship-owners and ship recycling facilities. Relying on flag state jurisdiction, the Hong Kong Convention requires that a vessel flying the flag of a state that has ratified the Convention must only be recycled at a pre-approved facility fulfilling the standards of the Convention.
In addition, there is a requirement that each vessel must carry on board an Inventory of Hazardous Material ('IHM'), which, in short, is a document listing all inventory of possible hazardous materials contained on board the vessel.
Several guidelines have been developed to assist states in the Convention's implementation.
Norway is a contracting state to the Hong Kong Convention, and therefore its requirements apply to vessels flying a Norwegian flag. In Norway, the Convention is implemented through regulations where the Norwegian Maritime Authority is responsible for the certification and supervision of ships, the Norwegian Environment Agency is responsible for the approval and supervision of recycling yards, and the Labour Inspection Authority oversees the requirements for working environments.
Who does it impact?
Ship-owners, shipyards and other parties involved in recycling of ships.
Status: In force
The Hong Kong Convention came into force 24 months after the ratification by 15 States, representing not less than 40 per cent of the world fleet by gross tonnage, with a combined annual ship recycling volume not less than 3 per cent of their combined tonnage.
This threshold was reached on 26 June 2023, after Bangladesh and Liberia ratified the Convention. The Hong Kong Convention therefore entered into force on 26 June 2025.
Relation to other initiatives and regulations
The Hong Kong Convention is a multilateral convention adopted by the International Maritime Organization (IMO).
The Hong Kong Convention has been implemented into EU law by way of the EU Ship Recycling Regulation, which entered into force on 30 December 2013. The EU Ship Recycling Regulation has in turn been incorporated into Norwegian law by way of the Norwegian Ship Recycling Regulation (2018).
The entry into force of the Hong Kong Convention may affect the ongoing process of revising the EU Ship Recycling Regulation.
Shipowners that must comply with both the Basel Convention and the Hong Kong Convention may potentially face a legal conflict. Prior to the Hong Kong Convention entered into force on 26 June 2025, there were calls for the IMO to ensure consistency between the two conventions by e.g. BIMCO, the International Chamber of Shipping and a number of signatory states.
The problem is that once a vessel has received an International Ready for Recycling Certificate under the Hong Kong Convention and is intended to be recycled in line with the Hong Kong Convention, it may simultaneously be considered 'hazardous waste' under the Basel Convention, which means that it would be prohibited to export the vessel to a non-OECD country. The vessel could therefore risk being detained during the entire validity of the certificate, which may be up to three months, and the owners may face criminal sanctions.
The IMO has acknowledged this issue, and during the 82nd session of the Marine Environment Protection Committee, a draft guidance was agreed. This states that States that are parties to both the Basel Convention and the Hong Kong Convention may notify he Secretariat that the Hong Kong Convention's requirements will be applied in respect of the transboundary movements of ships intended to be recycled at a ship recycling facility that has been authorized in accordance with the Hong Kong Convention.
The aim is that provisions of the Basel Convention would not affect the transboundary movements which take place pursuant to the Hong Kong Convention, however the interplay between these two regulations is uncertain legal territory. Thommessen is monitoring developments in this respect. Shipping companies should also note that the EU's regulations may be given independent effects despite incorporating the Hong Kong Convention and the Basel Convention.
Participants
As per December 2025, there are 24 contracting states to the Hong Kong Convention.
States that have ratified the convention include Bangladesh, Belgium, Republic of the Congo, Croatia, Denmark, Estonia, France, Germany, Ghana, India, Japan, Liberia, Luxembourg, Malta, Marshall Islands, the Netherlands, Norway, Pakistan, Panama, Portugal, São Tomé and Príncipe, Serbia, Spain and Turkey.
They between them represent approximately 46% of the gross tonnage of the world's merchant fleet.
Thommessen's comments
The Hong Kong Convention entered into force on 26 June 2025. Its main purpose is contributing to raising the standards in the ship recycling industry.
The Hong Kong Convention has often been referred to within the shipping industry and used as a benchmark when considering the recycling policies of ship-owners, even before it entered into force.
The Hong Kong Convention applies to vessels flying the flag of a contracting state and require such vessels to only be recycled at a pre-approved yard as authorised by the competetent authorities of a contracting state.
As the Hong Kong Convention relies on flag state jurisdiction, it is prone to circumvention by flag-hopping to flags known for poor implementation of international maritime law.