BIMCO Urges Clarity as Hong Kong Convention Nears Implementation Amid Basel Convention Conflicts
April 23, 2025 – As the international maritime community prepares for a significant regulatory shift in ship recycling standards, BIMCO, one of the world’s largest shipping associations, has called on global stakeholders to resolve inconsistencies between two key international conventions. In a position paper prepared for the Conference of the Parties to the Basel Convention, BIMCO is urging immediate action to align international frameworks and remove legal and procedural barriers to sustainable ship recycling.
With just two months until the Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships (commonly referred to as the Hong Kong Convention) enters into force on June 26, 2025, BIMCO’s newly formed Ship Recycling Alliance is taking the lead in advocating for a harmonized global regulatory approach. The Alliance, which represents the interests of both the international shipping sector and major ship recycling industries in Bangladesh, India, Pakistan, and Türkiye, has authored a comprehensive document that outlines the current challenges posed by conflicting international regulations.
The Growing Urgency of Harmonized Standards
At the heart of BIMCO’s concern is the ongoing misalignment between the Hong Kong Convention and the Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and their Disposal. These two multilateral environmental agreements, although aimed at improving safety and environmental standards, offer conflicting protocols and definitions that complicate compliance for ship owners and recyclers alike.
David Loosley, BIMCO’s Secretary General and CEO, emphasized the importance of removing these regulatory conflicts without delay. “The Hong Kong Convention is only two months from entering into force,” said Loosley. “While it is crucial for the future of safe and sound ship recycling—for both people and the environment—if the inconsistencies and contradictions between the conventions are not resolved, they will slow the progress of improving the global ship recycling industry.”
The Hong Kong Convention represents a milestone in international maritime regulation. Developed under the auspices of the International Maritime Organization (IMO), the Convention establishes a comprehensive framework for the environmentally sound and safe recycling of ships. Unlike the Basel Convention, which addresses waste at the end of its lifecycle and relies on the Prior Informed Consent (PIC) procedure between exporting and importing states, the Hong Kong Convention considers the entire life of a ship, from design and construction through dismantling.
One of the key areas of divergence is the role of States in regulation. The Hong Kong Convention operates on a flag State and recycling State model, where the country where a ship is registered (flag State) and the country where it is dismantled (recycling State) have jurisdictional authority. In contrast, the Basel Convention focuses on the relationship between the exporting and importing countries of hazardous waste, often treating end-of-life ships as waste themselves. This difference in perspective has led to legal and procedural overlaps that can hinder recycling operations.
BIMCO’s Position Paper: A Call for Coherence
The Ship Recycling Alliance’s paper seeks to provide clarity by outlining the history, current status, and expected benefits of the Hong Kong Convention, while highlighting the legal obstacles posed by the Basel Convention’s structure. The paper urges parties to the Basel Convention to consider the emerging global consensus around the Hong Kong Convention and to seek practical solutions that support a smooth transition.
“The documents currently available, including provisional guidance from the International Maritime Organization, do not yet provide the level of clarity needed by the industry,” the Alliance noted. “Article 11 of the Basel Convention does allow for bilateral or regional agreements that ensure environmentally sound management of hazardous wastes. However, relying on such agreements is not a viable long-term solution for the global ship recycling industry.”
The position paper argues that a patchwork of bilateral agreements would create a fragmented system, potentially undermining the very harmonization the Hong Kong Convention seeks to establish. BIMCO and its Alliance partners are therefore advocating for a unified and coherent regulatory regime that clearly defines how the two conventions should coexist and interact.
Industry-Wide Implications
The stakes are high. Every year, hundreds of ships reach the end of their operational life and are sent to recycling yards, particularly in South Asia. While the ship recycling industry provides crucial raw materials and employment, it also raises significant environmental and occupational safety concerns.
The Hong Kong Convention aims to mitigate these risks by requiring ships to carry an Inventory of Hazardous Materials (IHM) and ensuring that recycling yards meet strict environmental and safety standards. For countries such as Bangladesh, India, and Pakistan—home to some of the world’s largest recycling facilities—compliance with the Hong Kong Convention also presents an opportunity to elevate their environmental and labor practices.
However, if legal uncertainties persist due to conflicting obligations under the Basel Convention, shipowners may face delays, legal disputes, and increased compliance costs. This could lead to reduced investment in cleaner, safer recycling infrastructure, ultimately undermining global sustainability goals.
BIMCO’s Next Steps and Global Outlook
BIMCO has called on all countries that are party to both the IMO and the Basel Convention to urgently address these conflicts and coordinate their implementation strategies. “The shipping and ship recycling industries need a harmonised approach that can ensure a coherent set of regulations,” said Loosley. “This is not just about compliance—it’s about creating a regulatory environment that actually works in practice.”
The organization is also pushing for better definition of the role of overlapping UN conventions and for clearer guidance on the interface between ship-based and shore-based responsibilities. The Alliance hopes its paper will prompt more meaningful discussions at the upcoming Conference of the Parties and encourage the development of a roadmap for reconciling the two conventions.
As the clock ticks toward the Hong Kong Convention’s implementation date, the global maritime community is watching closely. The ability of international bodies to reconcile their differences and deliver a clear, effective regulatory framework will determine whether the industry can finally move toward truly sustainable ship recycling.
For now, the message from BIMCO and its Ship Recycling Alliance is clear: the time to act is now. Without coordinated action, a golden opportunity to transform one of the maritime sector’s most problematic areas could slip away.
