Hong Kong Convention: Inventory of Hazardous Materials and Green Passport
The Inventory of Hazardous Materials (IHM) must follow the individual ship and its modifications. For existing ships within HKC scope, the general deadline is 26 June 2030 or before recycling if earlier; check EU obligations separately.
Operational Explanation
The Hong Kong Convention entered into force on 26 June 2025. Docking is an opportunity to update the IHM after removals and new installations and arrange survey and certification with the Administration or authorised organisation. An old Green Passport is supporting information to verify, not automatic evidence of IHM compliance.
Regulatory Reference
Hong Kong Convention; MEPC.379(80) as amended by MEPC.405(83); EU 1257/2013, Articles 5, 8–12. The 2025 amendment clarifies cybutryne thresholds by sample type: do not apply one threshold indiscriminately to wet paint and hull coating samples.
HKC regulation 10.1.1 requires an initial survey before entry into service or issue of the International Certificate on Inventory of Hazardous Materials. The final survey, before withdrawal from service and commencement of recycling, verifies the completed IHM, the Ship Recycling Plan’s consistency with that inventory and its Safe-for-entry/Safe-for-hot work arrangements, and the recycling facility’s valid authorization (regulation 10.1.4). Hong Kong Convention, regulation 10.
Scope of Application
Check Party flag or authority and HKC exclusions: ships below 500 GT, warships and government non-commercial service, and ships operating throughout their life solely in waters under their flag State’s jurisdiction. For the EU regime, separately check flag, port calls and its exclusions.
Procedure / How to Complete It
- Identify the applicable regime, individual deadline and any flag implementation requirements.
- Reconcile IHM Part I against completed work, removed components and installed materials.
- Collect relevant Material Declarations and Supplier’s Declarations of Conformity; document gaps and verification.
- Arrange survey and certification without assuming automatic issue at HSSC renewal.
- Before recycling, also complete Parts II and III and the final survey/certification process.
Practical Example
Equipment is replaced during docking: check the IHM location and supplier documents. Section 4.3.2 of the guidelines does not require updating for identical parts or coatings; establish identity before applying this exception.
What Typically Goes Wrong
Confusing a Green Passport with a verified IHM, leaving the inventory unchanged since first issue, or applying the HKC 2030 deadline to EU documents already due.
Common Mistakes Mistake Library
| Mistake | How to avoid it |
|---|---|
| Confusing a Green Passport with a verified IHM, leaving the inventory unchanged since first issue, or applying the HKC 2030 deadline to EU documents already due. | Check the individual ship’s requirements and documents before closing the work. |
What the PSCO Checks
Operational Tips
- Assign responsibility for IHM updates.
- Link each change to its location and documentation.
- Distinguish survey planning from compliance already required.
Preparation checklist
- Scope and deadlines checked
- Removals and installations reconciled
- Supplier documents available
- IHM and certification consistent
- EU requirements checked separately
FAQ
Related Topics
Last substantive revision of this page: 16 September 2026 · page fingerprint b2bf433be176