Global ship recycling rules go live with Hong Kong Convention

As of today, June 26, the Hong Kong International Convention for the safe and environmentally sound recycling of ships (HKC) officially enters into force. It marks a long-awaited turning point in how the world dismantles and recycles end-of-life vessels.

Over two decades in the making, the convention—for which full compliance is not obligatory before 2030—sets global standards for shipowners, flag states, and recycling yards, seeking to bring long-overdue accountability to an industry long plagued by safety and environmental abuses.

“We believe the convention has the potential to change the face of ship recycling, support the circular economy and provide safe jobs to the people that need them,” David Loosley, Secretary General and CEO of shipping association BIMCO, remarked.

The Hong Kong Convention was first adopted in May 2009 at a diplomatic conference in China. It was crafted with input from IMO Member States and non-governmental organizations, as well as in co-operation with the International Labour Organization (ILO) and the Parties to the Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and their Disposal (otherwise known as the Basel Convention).

HKC represents a cradle-to-grave framework for the lifecycle of ships, from design and construction to operation and preparation of ships so as to facilitate safe and environmentally sound recycling.

It mandates that vessels ≥ 500 GT maintain an inventory of hazardous materials (IHM), a documented list of the types, quantities and location of substances onboard, such as asbestos, PCBs, ozone-depleting chemicals, heavy metals, hydrocarbons and anti-fouling agents. This inventory must be verified, kept current—when toxic materials are added or removed—and certified via an International Certificate on IHM.

The treaty also imposes strict rules on recycling infrastructure: only authorized facilities may dismantle ships. These must prepare a Ship Recycling Facility Plan (SRFP), covering worker safety, environmental controls, emergency response, waste handling, and record-keeping.

Ratification of the HKC, however, moved at a snail’s pace. Regions like the European Union (EU) implemented the EU Ship Recycling Regulation (EU SRR) by 2013, with the goal of minimizing negative impacts associated with ship recycling, particularly concerning human health and the environment. Meanwhile, the IMO developed detailed technical guidelines by 2012, with a further update in 2023 when the IHM protocols were ‘refined.’

To enter into force, the HKC required ratification by at least 15 States, accounting for 40% of world merchant tonnage. Despite early momentum, these thresholds were not met until June 2023, when Bangladesh and Liberia deposited their instruments, unlocking a 24-month countdown.

As of right now, twenty-four countries in total have ratified the HKC. Four of the largest ship-recycling nations, namely, Pakistan, Bangladesh, India and Türkiye, are among them, having authorized a number of recycling yards under this framework. In India, for example, it is said that well over 100 ship recycling facilities have secured a Document of Authorization (DASR).

Nonetheless, although the Hong Kong Convention has attempted to install the guardrails needed for the maritime industry to sail toward net zero ‘more safely’, some critics have underscored that it stops short of addressing and, ultimately, banning some of the most hazardous recycling and dismantling methods typically done in a number of countries in South Asia: beaching.

Defined as the practice of deliberately grounding ships at tidal flats for dismantling, beaching has been a colossal issue in the shipbreaking/ship recycling sector(s), drawing considerable attention and criticism in countries such as India and Bangladesh in particular. The two nations are home to yards infamous for beaching, like Alang, where a string of tragic accidents has already claimed numerous workers’ lives.

Some of these yards have also claimed to be HKC-compliant, despite the reality being different. As the Belgian organization noted, many of these sites do not have hospitals nearby in case of accidents, no capacity to dispose of hazardous materials and no track record of monitoring the health of their workers.

Compounding the matter are shipping players that go around international ship recycling rules with the aim of ‘profiting’ from vessel dismantling operations. Belgium-based NGO Shipbreaking Platform has revealed that these companies tend to re-flag their units to sail under the flags of St Kitts and Nevis, Comoros, Tuvalu and Mongolia, which are currently the most popular choices for stakeholders sending off their vessels to be scrapped in South Asia.

These so-called flags of convenience have been quite a weak link in the HKC chain, as they can allow the circumvention of tougher oversight and, therefore, threaten the treaty’s foundations.

Numbers back this up, with a study done by the Belgian organization showing that, in 2024 alone, as much as 80% of the world’s aging fleet was scrapped under these conditions. A number of the units were previously re-flagged.

In light of the Hong Kong Convention’s entry into force, and particularly since, according to BIMCO, there are over 15,000 vessels that need to be recycled, the NGO Shipbreaking Platform has once again underlined the importance of tackling these issues.

“The HKC does not set a roadmap for sustainable ship recycling, but will instead serve the interests of shipping companies that want to avoid paying the true cost of safe and environmentally sound end-of-life management. Tragically, it also risks to undercut efforts to level the playing field for responsible ship recyclers to compete,” Ingvild Jenssen, Executive Director & Founder of the NGO Shipbreaking Platform, remarked.

“The shipping industry cannot settle with a Convention designed to accommodate the industry’s worst practice. Beaching should be phased out, not endorsed,” she added.

That said, certain nations, which have been plagued with irregularities, have made steps to align better with the HKC and with other global environmental stipulations. Bangladesh is one of them. In February this year, the IMO shared that draft amendments to Bangladesh’s ship recycling and hazardous waste management legislation have been developed to align the shipbreaking industry with international environmental standards and safety regulations.

The amendments were presented and reviewed during a workshop held in Dhaka. The workshop also examined how the sector could be aligned with the most important provisions of the Basel, Rotterdam and Stockholm conventions.