Bangladesh Misses Deadline to Enforce Hong Kong Convention: Raising Concerns for Workers- Industry and Global Compliance
Bangladesh, one of the world’s largest ship recycling nations, has missed the critical deadline to implement the Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships (HKC 2009), which it ratified in June 2023. Despite the ratification, the country has yet to enforce the Convention as of June 2025, creating uncertainty for the ship recycling industry (SRI), global shipowners, and thousands of workers who depend on the sector for their livelihoods.
The delay has drawn international attention. A recent article in Maritime Executive suggested that both Bangladesh and Pakistan might postpone enforcement by invoking socio-economic challenges and referencing soft-law instruments such as the 1992 Rio Declaration on Environment and Development. However, legal experts stress that once a country ratifies a convention like HKC, it is legally bound under the Vienna Convention on the Law of Treaties to implement it in good faith. Declarations such as Rio carry non-binding language and cannot override the binding force of a ratified international treaty.
Currently, Bangladesh’s ship recycling sector is regulated by the Ship Breaking and Recycling Rules 2011 and the Ship Recycling Act 2018, under which the Ship Recycling Board (SRB) is the designated authority. However, the SRB is severely understaffed and unable to perform its core functions effectively, such as issuing No Objection Certificates (NOCs) and permits required to dismantle ships. These responsibilities are still being handled by the Ship Recycling Wing of the Ministry of Industry, creating bureaucratic overlap and confusion.
The government is in the process of transferring oversight from the Ministry’s Wing to the SRB, but the transition has been slow and disorganized. With the HKC deadline already passed, stakeholders fear Bangladesh may lack the administrative capacity to enforce compliance in an industry that relies on speed and efficiency. Shipbreaking yards often make massive upfront investments when purchasing ships for dismantling. Any delay in permits can lead to heavy bank interest costs, threatening the economic viability of businesses.
Under the HKC 2009 framework, from June 2025 onward, no ship can be legally dismantled in a yard that has not achieved “green yard” certification, meaning compliance with international environmental and worker-safety standards. As of now, only seven Bangladeshi yards—including PHP, SN Corporation, Kabir Recycling Yard, Arab Recycling Yard, and KR Recycling Yard—have been certified. About fifteen others are undergoing the expensive process of upgrading facilities to meet standards.
The majority of operational yards remain non-compliant, yet they employ thousands of workers directly and support millions more indirectly in related industries such as steel manufacturing, re-rolling mills, and furniture production. If ship imports are restricted only to green-certified yards, there will be severe economic repercussions.
The most immediate consequence would be the loss of income for thousands of laborers, many of whom already work in hazardous conditions with minimal protections. Beyond employment, the economic chain reaction would ripple through the steel industry, which relies heavily on scrap metal from ship recycling. Without sufficient local supply, Bangladesh would be forced to import raw materials, further straining its already fragile foreign currency reserves.
The global ship recycling business migrated from Europe to Asia decades ago, largely due to weaker environmental standards and lower labor costs. Today, South Asia dominates the sector, with Bangladesh, India, and Pakistan collectively handling the majority of the world’s end-of-life ships.
If Bangladesh moves too quickly to enforce HKC requirements, rival nations could exploit the transition period. India, Pakistan, and even emerging competitors like the Philippines may attract shipowners reluctant to comply with stricter conditions in Bangladesh. Given that shipowners often reflag vessels to avoid responsibility at end of life, the risk of Bangladesh losing business is substantial.
Another pressing challenge is the safe disposal of hazardous waste generated during ship dismantling. Bangladesh, with technical and financial support from Japan, has been working to establish a Treatment, Storage, and Disposal Facility (TSDF). This facility is crucial for managing asbestos, oils, heavy metals, and other dangerous materials extracted during recycling.
However, progress has been slow due to bureaucratic delays, particularly in acquiring suitable land. With enforcement already overdue, it is unlikely the TSDF will be ready in time. Until then, hazardous waste disposal will remain a weak point in Bangladesh’s compliance, with significant risks to both human health and the environment.
Critics of the Hong Kong Convention argue that it unfairly places the bulk of responsibility on recycling nations rather than on ship-owning states. Recycling countries must build green yards, prepare detailed Ship Recycling Plans (SRPs), and ensure occupational health and safety standards. In contrast, shipowners can evade responsibility by selling ships to cash buyers or reflagging them under jurisdictions with weak oversight.
This asymmetry leaves countries like Bangladesh bearing the environmental and human costs of dismantling ships, even though the profits from a vessel’s operational life accrue elsewhere. The imbalance raises the question: is Bangladesh truly prepared—or even able—to implement HKC obligations fairly by itself?
Failure to comply with HKC obligations after ratification would constitute a breach of international law. More importantly, the consequences extend beyond treaty obligations. The ship recycling yards of Bangladesh are infamous for poor working conditions, frequent accidents, and long-term health risks to workers. Implementing the Convention could reduce fatalities, prevent toxic exposures, and mitigate marine and coastal pollution.
Given that the international community cannot reliably monitor safety and environmental compliance at individual yards, national enforcement is critical. The missed deadline risks prolonging dangerous working conditions and environmental degradation, undermining the very purpose of ratifying the Convention.
Experts suggest that rather than treating HKC as a rigid framework, the International Maritime Organization (IMO) should collaborate with recycling nations to design tailored, enforceable, and financially realistic standards. At present, many yards struggle to afford certifications from classification societies such as ClassNK, Bureau Veritas, or GMS, which demand compliance with high-level guidelines. Adjusting these requirements without undermining safety is essential.
Additionally, the IMO should expand its inspection and monitoring role in major recycling countries. Transparent evaluations of occupational safety, waste management, and environmental standards would not only encourage accountability but also help the global community understand the progress and gaps in implementation.
Finally, technical support must be matched with financial aid. Bangladesh already participates in projects like SENSEREC Phase 3, which offers safety training and legislative assistance. But workers still lack proper safety equipment, and yards need modern machinery to handle dismantling safely. Without financial assistance, compliance will remain out of reach for many operators.
Bangladesh’s failure to enforce the Hong Kong Convention by the June 2025 deadline underscores a broader challenge facing the global ship recycling industry: how to reconcile international legal commitments with local socio-economic realities. While the country’s ratification signaled its willingness to reform, the absence of administrative readiness, infrastructural capacity, and financial support threatens both legal compliance and human welfare.
The future of Bangladesh’s ship recycling industry now hinges on whether it can bridge this gap quickly. Failure would not only risk violating international law but also jeopardize thousands of jobs, strain foreign reserves, and allow unsafe working conditions to persist. Success, on the other hand, would strengthen Bangladesh’s standing in the global maritime industry, improve labor safety, and protect the environment.
For now, the question remains unanswered: is Bangladesh ready to shoulder the weight of its commitments, or will it falter under the burden of competing economic and social realities?
Author: shipping inbox
shipping and maritime related web portal
