Ship recycling is a highly regulated sector, governed by a complex and evolving set of international and regional frameworks. These regulations aim to ensure that the disposal of ships is conducted in a manner that is safe, environmentally responsible, and socially sustainable. Key among these are the Basel Convention, the European Union Ship Recycling Regulation (SRR), and the recently enforced Hong Kong Convention (HKC).
The Basel Convention (1989)
- Objective and Scope: Adopted by 187 countries, the Basel Convention regulates the transboundary movement of hazardous waste. It establishes a “notice and consent” system and generally prohibits the movement of waste between member countries and non-member countries.
- Basel Ban Amendment: The 1995 Basel Ban Amendment, which entered into force in December 2019, further prohibits the export of hazardous waste from member countries to non-member countries, specifically those classified as developing nations.
The European Ship Recycling Regulation (SRR)
- Implementation and Applicability: The SRR, which superseded the EU Waste Shipment Regulations, came into force on December 31, 2020. It applies to all EU-flagged ships and also to non-EU-flagged ships when they call at EU ports. Norway, Switzerland, and the UK have similar national legislation.
- Key Requirements: The SRR mandates several requirements for EU-flagged vessels, many of which align with the Hong Kong Convention:
- Ships must carry an Inventory of Hazardous Materials (IHM).
- Surveys must be conducted approximately every five years to ensure the IHM is up to date.
- A ship recycling plan must be developed before a vessel is sent for recycling.
- Most notably, EU-flagged ships can only be recycled at yards on the approved European List. This list includes facilities in EU countries, the UK, Turkey, and the USA, but currently excludes yards in the Indian Subcontinent.
- Enforcement and Penalties: The SRR places the responsibility on ships and shipowners. EU Member States are required to legislate for penalties for infringements, which must be “effective, proportionate and dissuasive” and can be civil or administrative. Enforcement is carried out through port state control inspections.
The Hong Kong Convention (HKC)
- Entry into Force: The HKC, adopted in 2009, finally received sufficient ratification and entered into force on June 26, 2025.
- Core Requirements: The convention’s requirements largely mirror those of the SRR, obligating ships destined for recycling to:
- Carry a vessel-specific Inventory of Hazardous Materials (IHM).
- Implement a system of notifications as the ship is prepared for recycling.
- Require recycling yards to provide a ship recycling plan tailored to each individual vessel.
- Key Distinction from SRR: A crucial difference between the HKC and the SRR is that the HKC does not have any country-based limitations on where a ship may be recycled. This means a ship and its owners can comply with the HKC without necessarily meeting the stricter location-based requirements of the Basel Convention or the SRR.
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Source: Shipowners Club
