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The HNS Convention

The transport of hazardous and noxious substances (HNS) by sea is a crucial component of global trade. Chemicals and other hazardous products underpin many manufacturing processes, and transport of chemicals such as ammonia, hydrogen and LPG/LNG are set to dramatically increase as the world seeks to decarbonise. There are International Maritime Organization (IMO) regulations to ensure the safe transport of the wide range of HNS cargo that is carried by sea. However, by nature of the material’s make-up, it also has the potential to cause serious damage to the environment and endanger life if, despite best efforts, an accident occurs. The HNS Convention offers an efficient solution to deal with any incidents that may arise.
What is the HNS Convention?
Modelled on the highly successful international oil pollution liability and compensation regime, the convention will establish a two-tier international regime for HNS damage. It applies the concept that the ‘polluter pays’ in situations involving hazardous and noxious substances. The cost of damage and loss will be shared between shipowners and HNS cargo receivers, ensuring comprehensive, global liability and compensation for those who suffer damage or loss from an HNS incident. The Convention establishes a similar governing structure to the 1992 IOPC Fund, namely an HNS Fund, that will be established through financial contributions from HNS Cargo receivers. While most damage from any HNS incidents will be covered by the shipowner in the first tier of compensation, the existence of the Fund – the second tier – will ensure that further compensation is available in the rare event that the first tier is exhausted.
Hazardous and noxious substances covered by the convention include oils, liquid substances defined as noxious or dangerous, liquefied gases, liquid substances with a flashpoint not exceeding 60˚C, dangerous, hazardous and harmful materials, substances carried in packaged form or in containers, and solid bulk materials defined as possessing chemical hazards.
When will the HNS Convention be implemented?
The Convention has a long history with the first iteration agreed in 1996. 2010 saw the adoption of a Protocol to tackle some of the perceived obstacles to ratification by IMO Member States. Although the protocol was a significant step forward, the work needed to implement the cargo reporting elements of the convention has meant that governments have remained slow to act. However, momentum is now building towards entry into force.
Yesterday (Tuesday 14 April 2026), we were delighted that Germany, the Netherlands, Belgium and Sweden all deposited their instruments of ratification. This fulfils the second of three ratification criteria needed for the entry into force provisions to be triggered – 12 States Parties to the Convention. The tonnage threshold has already been met, and we hope to see the contributing cargo threshold to be confirmed as met in the imminent future.
ICS and the HNS Convention
ICS has been a staunch supporter of the HNS Convention since it was first agreed in 1996 and was a key participant in the negotiations for a Protocol to the Convention in 2010. We are therefore delighted that, once it is hopefully confirmed that the contributing cargo threshold has also been reached by the recent ratifications, the official countdown will begin to the entry into force of the Convention at the end of 2027. There is still work to be done to facilitate a smooth entry into force, and the International Chamber of Shipping remains committed to assisting States with the implementation of the HNS convention. An important focus in the run up to entry into force will be the process for issuing States certificates of insurance to the more than 65,000 ships that will need them on the entry into force date. At the IMO Legal Committee this week, the International Chamber of Shipping joined with the International Group of P&I Clubs to call for a coordinated approach among States to this task.