Bangladesh’s Quiet Decisive Role in Activating the Hong Kong Convention—and the Strategic Path Still Ahead
The entry into force of the Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships (HKC) on 26 June 2025 marks a historic shift in the governance of global ship recycling. After more than a decade of negotiations, delays, and recalibrations, the Convention has finally crossed the legal thresholds required to become binding international law. Governments, international organisations, and parts of the maritime industry have hailed this moment as a breakthrough for environmental protection and worker safety in one of the world’s most hazardous industrial sectors.
Yet behind the celebratory headlines lies a more complex and less visible reality. The HKC did not enter into force simply because a global consensus was achieved. It did so because a very specific mathematical and political equation was solved at a very specific moment in time, and Bangladesh was the decisive variable in that equation. Without Bangladesh’s ratification in June 2023, the Convention would almost certainly have failed to meet its final prerequisite and could have remained dormant for decades. More importantly, Bangladesh held significant diplomatic and commercial leverage at that critical juncture, leverage it did not fully deploy. Even so, the country still retains a viable second pathway to reclaim strategic advantage, rooted in the Basel Convention and its Ban Amendment.
To understand Bangladesh’s pivotal role, it is essential to revisit the HKC’s unusually stringent entry-into-force requirements. Unlike many international treaties, the HKC required three cumulative conditions to be met simultaneously. First, at least fifteen States had to ratify the Convention. Second, those States needed to represent no less than 40 per cent of the world’s merchant shipping by gross tonnage. Third—and most challenging—the combined ship-recycling capacity of those States, averaged over the preceding ten years, had to be equivalent to at least 3 per cent of the total gross tonnage of their combined fleets.
While the first two criteria were demanding, they were broadly achievable through the participation of major flag States. The third criterion, however, proved to be a formidable barrier. Only a handful of countries in the world possess meaningful ship-recycling capacity, and among them, Bangladesh is indispensable. When Bangladesh and Liberia deposited their instruments of accession in June 2023, the equation finally balanced. The number of contracting States exceeded 22, global fleet representation crossed 45 per cent, and—crucially—the 3 per cent recycling-capacity threshold was reached for the first time. The 24-month countdown to the Convention’s 2025 entry into force began.
Liberia’s role, despite its status as the world’s second-largest open registry, highlights why Bangladesh was so critical. Liberia has virtually no domestic ship-recycling capacity. Its accession added vast amounts of fleet tonnage to the denominator of the recycling-capacity ratio without contributing anything to the numerator. In fact, a premature Liberian ratification would have made the 3 per cent threshold harder to achieve, not easier. This is why Liberia was widely advised to ratify only after Bangladesh. Bangladesh, by contrast, had no substitute. Without its millions of light-displacement tonnes (LDT) of annual scrapping capacity, the Convention could not mathematically enter into force.
The broader global context amplified Bangladesh’s importance even further. China, once the world’s largest ship-recycling nation, effectively exited the international recycling market in 2019 by banning the import of foreign vessels as part of its environmental reforms. With China removed from consideration, one of the last high-capacity States capable of contributing to the HKC threshold disappeared. Pakistan, though active in shipbreaking, lacked the specialised legislation, institutional readiness, and compliance infrastructure required to ratify and implement the HKC within the mandatory two-year transition period. That left Bangladesh as the largest, most capable, and most indispensable recycling State in the world for the Convention.
Timing was equally decisive. The HKC’s third criterion relies on a rolling ten-year average of recycling capacity. Every year after 2023 introduced additional uncertainty. The global fleet continues to expand, increasing the denominator of the ratio, while Bangladesh’s recycling output fluctuates due to domestic regulatory and market conditions. Meanwhile, additional accessions by large flag States with no recycling capacity—such as Malta, Cyprus, or the Marshall Islands—risked further diluting the ratio. From a purely mathematical and policy perspective, 2023 was the last realistic window for HKC activation.
This reality gave Bangladesh substantial bargaining power. It could have leveraged its ratification to secure transition financing, international yard-upgrade packages, investment in hazardous-waste treatment and disposal facilities, or preferential recognition under the EU Ship Recycling Regulation. It could have negotiated staged implementation timelines, revenue-sharing mechanisms, or binding commitments for worker safety and environmental infrastructure. Yet these opportunities were largely unexercised. Domestic political constraints, bureaucratic fragmentation, limited consultation with national experts, and a lack of awareness of the leverage inherent in its position diluted what could have been a transformative diplomatic moment.
Despite this missed opportunity, Bangladesh is not without recourse. The Basel Convention offers a second—and potentially powerful—avenue for strategic repositioning. Under Basel’s legal framework, end-of-life ships can be classified as hazardous waste, particularly when exported from OECD to non-OECD countries. This classification triggers strict obligations for environmentally sound management, grounded in the principles of shared responsibility and the polluter-pays doctrine.
By positioning itself as a Basel-compliant receiving State, Bangladesh can legitimately require shipowners and exporting States to contribute financially to safe and environmentally sound recycling. In practical terms, this could take the form of a Basel-aligned compliance levy on incoming end-of-life vessels. Given that Bangladesh recycles roughly 2 million LDT annually, generating an estimated USD 770 million in economic output, even a modest 5 to 10 per cent levy could yield USD 38 to 77 million per year. Such revenue would be sufficient to fund hazardous-waste facilities, environmental monitoring systems, independent audits, emergency-response infrastructure, and yard upgrades aligned with HKC’s objectives.
To realise this potential, Bangladesh must adopt a coherent and strategic policy framework. This includes establishing a National Ship Recycling Environmental Compliance Fund, rapidly upgrading selected yards to full HKC compliance, integrating Basel and HKC obligations into domestic law, and engaging proactively with European regulators, classification societies, and international financiers. Regional coordination with India and Pakistan could further strengthen South Asia’s position as a predictable, compliant recycling hub.
Bangladesh was the indispensable State that ultimately enabled the Hong Kong Convention to enter into force. Although the initial moment of leverage was not fully utilised, the strategic window has not yet closed. By leveraging the Basel Convention and embedding compliance into its national framework, Bangladesh can still transform a missed diplomatic opportunity into a lasting competitive advantage—modernising its ship-recycling industry, delivering real environmental gains, and redefining its role from rule-taker to rule-setter in global maritime governance.
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