Welcoming the Hong Kong Convention to Indonesia’s Ship Recycling Scene: What You Need to Know and What to Prepare
Background: Why Does it Matter to Indonesia?
Indonesia is positioning itself as a competitive player in the global ship recycling industry. As of early 2025, the Ministry of Transportation’s Directorate of Vessels and Maritime Affairs emphasized the importance of the Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships 2009 (“HKC”), which will come into force on June 26, 2025. The Head of the Directorate highlighted Indonesia’s commitment to ensuring compliance with global standards to enhance human safety, protect the marine environment, and improve waste management in ship recycling activities.
The responsibility for enforcing international conventions typically lies with contracting states and national maritime authorities. While Indonesia has not yet ratified the HKC, the convention will still impact national shipping companies, charterers, and shipowners. Ports in HKC-compliant countries will have the authority to detain non-compliant Indonesian vessels, posing potential risks for the industry. In this regard, the Operational Director of BKI has cautioned stakeholders that failure to adhere to HKC standards may lead to commercial and operational setbacks.
Indonesia has already taken steps towards compliance, requiring vessels of 500GT and above to meet HKC safety standards under the Regulation of the Ministry of Transportation No. PM 24 Year 2022. To maintain competitiveness in the international ship recycling market, Indonesia must prepare for HKC implementation, aligning with other leading nations in ship recycling.
On a broader scale, adherence to HKC standards will help Indonesia maintain its standing in the Tokyo Memorandum of Understanding (Tokyo MoU) White List. Countries on this list benefit from enhanced diplomatic positioning when negotiating international maritime regulations, reinforcing Indonesia’s global credibility in the maritime sector.
What is the Aim of the Hong Kong Convention?
Clarifying Ship Recycling Regulations Beyond the Basel Convention
Before the HKC, ship recycling was primarily regulated under the Basel Convention, which governs the transboundary movement of hazardous waste. However, the Basel Convention focuses more on controlling hazardous waste exports than on the actual recycling process. The HKC seeks to close this regulatory gap by introducing comprehensive safety and environmental standards for ship dismantling and hazardous material handling.
Key Objectives and Provisions of the HKC
1. Inventory of Hazardous Materials (IHM)
Under the HKC, ships over 500GT flying the flag of contracting states must maintain an Inventory of Hazardous Materials (IHM) throughout their lifespan. The IHM consists of three parts:
- Part I: Hazardous materials in the ship’s structure and equipment
- Part II: Operationally generated waste
- Part III: Stores
Parts II and III must be prepared before recycling, ensuring that ships remain free from hazardous substances identified in HKC Appendix I.
2. Ship Recycling Facilities
The HKC mandates that ship recycling facilities develop a Ship Recycling Facility Plan (SRFP) covering safety measures, environmental management, and waste disposal. Only authorized facilities that meet HKC criteria will be permitted to recycle ships, ensuring compliance with safety and environmental standards.
3. Prevention of Environmental and Occupational Hazards
Ship dismantling is a high-risk occupation due to potential exposure to hazardous materials. The HKC requires ship recycling facilities to implement measures that prevent risks to human health and the environment. Compliance with these safety measures will help protect workers and minimize pollution risks.
4. Surveys and Certifications
Ships must undergo initial, renewal, and final surveys to verify compliance with HKC regulations. Upon successful completion, ships will receive an International Ready for Recycling Certificate. This certification process ensures that ships are properly assessed before dismantling.
Existing Ship Recycling Laws in Indonesia
Although Indonesia has not ratified the HKC, national regulations already incorporate aspects of the convention.
1. Law No. 17/2008 as Amended by Law No. 66/2024 (New Shipping Law)
The updated Shipping Law emphasizes marine environmental protection, including regulations on ship recycling. Failure to comply with environmentally sustainable recycling practices could result in penalties, including imprisonment and fines of up to IDR 300 million.
2. Ministry of Transportation Regulation No. PM 24 Year 2022
This regulation aligns with the HKC by requiring Indonesian-flagged vessels of 500GT and above to comply with the convention’s ship recycling standards. It mandates IHM documentation, reporting procedures, certification requirements, and Ship Recycling Facility Plans, mirroring the HKC framework.
Preparing for HKC Implementation in Indonesia
To successfully adapt to the HKC, Indonesia’s ship recycling industry must address several challenges:
- Enhancing Compliance Infrastructure: Indonesia must invest in modern ship recycling facilities to meet HKC standards. The cost of upgrading technology and infrastructure to ensure environmentally sound practices is significant, but necessary for international competitiveness.
- Increasing Industry Awareness: Shipowners, maritime authorities, and ship recycling companies must be well-versed in HKC requirements. Training programs and stakeholder engagement are crucial to facilitate smooth adoption of the new regulations.
- Expanding Recycling Capacity: To strengthen Indonesia’s position in the global ship recycling market, the government must support industry growth by promoting sustainable practices and attracting investment in shipbreaking facilities.
The HKC’s entry into force marks a transformative moment for Indonesia’s ship recycling industry. While compliance poses challenges, aligning with the HKC will bring long-term benefits, including improved safety, environmental protection, and enhanced global market competitiveness. By preparing early and implementing robust regulations, Indonesia can become a responsible and influential player in the international ship recycling sector.
