Assessing Global Standards for Ship Recycling: Gaps Persist Between HKC and EU Rules
A new analysis comparing the Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships (HKC) with the European Union Ship Recycling Regulation (EU SRR) has identified significant structural gaps between the two frameworks, particularly in the authorization and monitoring of ship recycling facilities.
The study finds that while both regimes seek to improve environmental protection and worker safety in the ship recycling industry, the EU SRR establishes a more prescriptive and enforceable system. In contrast, the HKC relies heavily on broad principles and national interpretation, creating uneven standards across jurisdictions.
A central concern highlighted in the report is that many HKC requirements are drafted at a high level, with detailed implementation left to guidelines developed by the International Maritime Organization’s Marine Environment Protection Committee (MEPC) or individual national authorities. This flexibility allows countries to adapt rules to local conditions, but it also creates substantial variability in how ship recycling facilities are approved, inspected and supervised.
The analysis notes that the rigor of authorization procedures, inspection regimes and compliance verification can differ significantly between parties to the convention. Even where MEPC guidelines are fully adopted, the EU SRR remains more detailed in its procedural requirements and provides stronger transparency and enforcement mechanisms.
As a result, the EU system offers greater predictability and comparability among recycling facilities, while the HKC framework permits wider discretion but less consistency in practical application.
The report also identifies several additional weaknesses within the HKC regime. These include weaker controls on waste leakage during dismantling operations, less explicit protections for worker rights and occupational safety, and more limited public disclosure of facility-level information.
According to the study, these shortcomings are closely interconnected. Less detailed authorization standards may lead to fewer or less rigorous inspections, which in turn reduces oversight of operational risks such as pollution control, hazardous waste handling and worker exposure during dismantling activities.
The analysis further stresses that both the HKC and the EU SRR ultimately depend on national implementation and interpretation of provisions that are sometimes ambiguous. Consequently, actual environmental and safety outcomes may vary considerably even where legal texts appear broadly aligned.
“Enforcement capacity and regulatory interpretation at national level are critical determinants of real-world performance,” the report states.
The findings come amid growing debate within the global shipping industry over fragmented regulation in the ship recycling sector. The Sustainable Shipping Initiative (SSI) recently argued that the prolonged regulatory divide between the HKC and the Basel Convention has delayed investment in safe and sustainable recycling infrastructure since 2011.
According to SSI, uncertainty regarding downstream traceability requirements and overlapping oversight mechanisms has discouraged the scaling-up of compliant recycling capacity worldwide. At the same time, the organization pointed to emerging evidence from Alang in Gujarat — one of the world’s largest ship recycling hubs — indicating improvements in environmental performance and worker safety under HKC-aligned practices.
SSI has therefore called for a more coordinated technical role for the International Maritime Organization (IMO) and closer cooperation with the Basel Convention through a joint IMO-Basel workstream. The initiative believes such coordination could reduce regulatory uncertainty and encourage greater investment in compliant recycling infrastructure globally.
The report also recommends clearer definitions for several important legal concepts that currently remain open to interpretation under both regimes. Terms such as “as far as practicable” in relation to hazardous material inventories, “minimize” for onboard waste management prior to recycling, and “sufficient evidence” for triggering investigations lack operational clarity, the analysis says.
Experts argue that clearer criteria and illustrative guidance would improve legal certainty, reduce enforcement inconsistencies and strengthen compliance.
Another area requiring attention is the updating of outdated guidance documents referenced by both frameworks. The report notes that some occupational safety standards and exposure limits cited in existing guidelines no longer reflect current best practices or technological developments within the industry.
Transparency and information sharing also emerged as major concerns. While the HKC requires reporting to the IMO, public access to detailed facility-level information remains limited. Expanding published data on recycling capacity, hazardous material handling and dismantling methods could improve due diligence by shipowners and strengthen oversight by regulators and civil society.
Worker safety training remains another key challenge. Although the HKC mandates “appropriate training and familiarization,” it does not establish minimum standards or implementation models. The study suggests that adopting structured training systems similar to shipboard safety programmes under the International Safety Management (ISM) Code could help standardize safety practices and improve worker protection across recycling facilities worldwide.
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