BIMCO Calls for Clarity Between Basel and Hong Kong Conventions as New Ship Recycling Rules Loom
With just two months to go before the landmark Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships (HKC) enters into force, BIMCO, one of the world’s largest international shipping associations, is sounding the alarm over unresolved regulatory contradictions that could hinder global progress in ship recycling.
In a move aimed at promoting clarity and consistency, BIMCO has drafted a paper to be submitted to the 17th Conference of the Parties (COP-17) to the Basel Convention, urging member states to address the overlapping and, at times, conflicting requirements between the Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and their Disposal and the forthcoming HKC.
The paper was prepared by BIMCO’s newly established Ship Recycling Alliance, a collective initiative representing both the shipping industry and major ship recycling nations including Bangladesh, India, Pakistan, and Türkiye. According to BIMCO, the document is intended to provide a comprehensive overview of the evolution of ship recycling regulation and to warn of delays unless regulatory coherence is established.
“The Hong Kong Convention is only two months from entering into force. While it is crucial for the future of safe and sound ship recycling, for people and the environment, inconsistencies and contradictions between the conventions still exist. If these obstacles are not removed, we fear it will slow down the progress of improving the global ship recycling industry,”
— David Loosley, Secretary General & CEO, BIMCO
A Clash of Regulatory Frameworks
The HKC, which takes effect on June 26, 2025, introduces a unified framework for environmentally responsible ship recycling. It emphasizes reporting, safety, environmental standards, and accountability throughout a ship’s entire lifespan. Central to the HKC is the concept of coordination between a ship’s flag State and the recycling State — a departure from the Basel Convention’s focus on exporting and importing countries, which reflects a land-based waste disposal model.
This fundamental difference in structure has created operational confusion and legal uncertainty. Under the Basel Convention’s Prior Informed Consent (PIC) procedure, a ship earmarked for dismantling must await consent from the exporting and importing States — and sometimes transit States — before moving. For shipowners, this process is cumbersome and out of sync with how maritime operations function globally.
In many cases, the “exporting State” under Basel is not where the shipowner or manager is based, nor does the ship maintain a long-term presence in that jurisdiction. Yet under Basel’s PIC, the vessel may have to remain in port for weeks or months, as the exporting State seeks clearance from the receiving (and possibly transit) countries. During this waiting period, the ship may not be allowed to leave, causing logistical delays and increasing costs.
Implementation Challenges and Enforcement Gaps
Adding to the complexity is the question of who enforces what. Under the Basel Convention, enforcement typically falls under the Environmental Inspectorate, which often lacks expertise in maritime law and vessel operations. In contrast, the HKC will be monitored and enforced by Port State Control (PSC) officers — regulators already versed in other International Maritime Organization (IMO) conventions.
Recognizing this, the Paris Memorandum of Understanding (Paris MoU) has already committed to enforcing the HKC starting July 1, 2025, thereby integrating ship recycling into the standard international PSC inspection regime.
Yet as of today, the HKC’s core mechanism — the International Ready for Recycling Certificate (IRRC) — is not yet active. It cannot be issued until the Convention officially comes into force. This leaves shipowners, recycling facilities, and regulators in a regulatory gray area.
Still, progress has been made. Voluntarily, more than 110 of India’s 120 active recycling yards have already aligned with HKC requirements, including upgrades in waste handling and environmental protection systems. Bangladesh and Pakistan are also investing in similar infrastructure and regulatory improvements.
Limitations of Basel’s Flexibility
While Article 11 of the Basel Convention allows for regional or bilateral agreements between parties for hazardous waste management, BIMCO argues that this cannot serve as a long-term solution for the ship recycling industry. Instead, it calls for structural reform and explicit guidance on how the two conventions can coexist and interact.
“The interplay between the two conventions will result in significant challenges for ship recycling. We ask that all States which are both party to the IMO and to the Basel Convention urgently examine the conflicts and agree on solutions,”
— David Loosley, BIMCO
One of the key components of the HKC, Regulation 16, governs how ship recycling facilities receive authorization from their national authorities. This regulation specifies what type and size of ships can be processed and outlines restrictions on the types and volumes of hazardous materials that can be handled. This framework, BIMCO argues, offers greater precision and operational clarity than the broader, less targeted mechanisms under Basel.
The Path Forward
BIMCO’s submission to BC COP-17 is a call to action for international regulators. Without urgent coordination, the global community risks stifling the very progress that the HKC was designed to accelerate. BIMCO is urging a harmonised regulatory approach that eliminates duplication, accelerates compliance, and facilitates environmentally sound ship recycling — particularly in major ship-breaking nations.
As the June 26 deadline approaches, the industry will be watching closely to see whether the Basel Convention parties will take concrete steps to resolve these discrepancies or allow procedural inertia to undermine the effectiveness of the HKC.
For BIMCO and its Ship Recycling Alliance, the message is clear: the time to act is now. Without clarity and cooperation between the UN’s parallel frameworks, the promise of a safer, greener global ship recycling system could remain unfulfilled.
