Liberian Flag Updates Compliance Requirements for Ship Recycling Under Hong Kong Convention and EU-SRR
Monrovia, Liberia — April 30, 2025 — The Liberian Registry, one of the largest ship registries in the world, has issued updated compliance guidance for ship recycling in line with the Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships (HKC) and the EU Ship Recycling Regulation (EU-SRR), formally known as Regulation (EU) No. 1257/2013. The revisions are detailed in Marine Notice POL-016 Rev.03/25, released by the Liberian Maritime Authority in March 2025.
This development follows increasing global emphasis on environmental protection and sustainable ship dismantling practices, particularly as the maritime industry gears up for the entry into force of the Hong Kong Convention on June 26, 2025.
The Liberian Administration’s updated notice outlines the procedural and documentation requirements for vessels flying the Liberian flag to ensure compliance with international and EU ship recycling standards. Marine Notice POL-016 Rev.03/25 replaces earlier guidance and reflects the Administration’s commitment to environmental stewardship and legal compliance under both the International Maritime Organisation (IMO) and European Union frameworks.
Dual Compliance Approach: HKC and EU-SRR
The updated Marine Notice is significant for its dual focus: aligning Liberian-flagged vessels with the IMO’s Hong Kong Convention requirements and the EU-SRR. While both regulations share similar goals of ensuring environmentally responsible ship recycling, there are key procedural differences between them.
The Hong Kong Convention, adopted in 2009 under the auspices of the IMO, mandates that ships must carry an Inventory of Hazardous Materials (IHM) throughout their lifecycle and be recycled only in authorized facilities. The EU-SRR, which came into force in 2013, imposes similar requirements on ships calling at EU ports, regardless of flag, and mandates recycling in EU-approved facilities.
By aligning with both, the Liberian Registry is ensuring its vessels can operate globally without legal or operational disruption, particularly in European waters.
ClassNK Issues Updated Technical Advisory
In response to the Liberian Administration’s new directive, ClassNK—one of the world’s leading ship classification societies—has released a new Technical Information bulletin providing detailed instructions for shipowners and managers. The notice supersedes ClassNK Technical Information No. TEC-1320 and offers practical guidance for compliance with POL-016 Rev.03/25.
The updated ClassNK bulletin outlines the necessary steps to maintain a compliant Inventory of Hazardous Materials (IHM) and the process for obtaining a Statement of Compliance or an International Certificate on Ship Recycling, depending on the ship’s status and intended recycling destination.
Key Actions for Shipowners and Operators
Owners and operators of Liberian-flagged vessels must take the following key actions:
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Ensure that all ships have a certified Inventory of Hazardous Materials (IHM) on board, updated throughout the ship’s life.
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Conduct IHM surveys through recognised organisations such as ClassNK.
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For ships scheduled for recycling, obtain a Ship Recycling Plan (SRP) approved by the Administration and a valid International Ready for Recycling Certificate.
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Confirm that recycling facilities are authorised under the HKC and/or appear on the EU list of approved facilities, if the vessel intends to call at EU ports.
Non-compliance with these obligations could result in port state control (PSC) detentions or fines, especially in the European Union, where enforcement of the EU-SRR is rigorous.
Liberia’s Commitment to Responsible Ship Recycling
With the updated Marine Notice POL-016 Rev.03/25, the Liberian Registry underscores its commitment to environmental protection and responsible maritime operations. As the Hong Kong Convention enters into force, Liberia’s proactive stance provides clarity and compliance support for shipowners navigating complex international regulations.
For shipowners, charterers, and managers, understanding and implementing these updated requirements will be crucial to ensure seamless global operations and adherence to environmental standards in ship recycling.
