European Shipowners|ECSA and the International Chamber of Shipping (ICS) have released an independent study on the key areas of divergence between the EU Ship Recycling Regulation (EU SRR) and the International Maritime Organization (IMO) Hong Kong Convention (HKC). The study also examines the significant change that the new global standards have brought after the HKC entered into force.
Aiming to contribute to the IMO experience-building process on the HKC, ES|ECSA and ICS commissioned the study to highlight the main areas of divergence between the EU SRR and the IMO HKC and inform the discussions ahead. The study also looks at the remarkable progress made worldwide after HKC entered into force and the number of ship recycling facilities that have been certified as complying with the new global standard.
Also read: Hong Kong Convention for ship recycling enters into force
Towards one ambitious international standard
‘The entry into force of the HKC on 26 June 2025, was a major milestone for the safe and environmentally sound recycling of ships worldwide,’ says Sotiris Raptis, Secretary General of ES|ECSA. ‘It has brought on significant and measurable change internationally and has already delivered more compliant facilities. Our study identifies concrete areas where we can build on the experience gained from the EU SRR to strengthen the Convention and raise global standards.’
He adds: ‘The experience-building phase starting in 2027 is the right opportunity to discuss areas of improvement and ensure one ambitious international standard. In the meantime, we need to address current capacity challenges while promoting safe, environmentally sound ship recycling on a global scale. Facilitating the inclusion of non-OECD yards on the EU SRR list must be a priority for the EU.’
Also read: ‘IMO has to solve disparities in ship recycling conventions’
Three critical gaps
John Stawpert, Principal Director (Marine) at the ICS: ‘This detailed independent study demonstrates the significant overlaps between the EU Ship Recycling Regulation and the Hong Kong Convention. The report highlights where there is divergence within the two instruments and by identifying three critical gaps gives a clear steer for areas to work on during the IMO experience building phase next year.’
The study underlines that HKC’s far wider global scope is a major strength. Addressing the gaps identified would strengthen the Convention, raise global standards and ensure consistent implementation worldwide. To this end, the study highlights three key areas that could be addressed:
- Authorisation of ship recycling facilities: HKC Parties should communicate their mechanisms for authorising facilities, including the mandatory criteria applied and the form and frequency of inspections, with clearer rules on the organisations to which authorisation may be delegated.
- Downstream waste management: the international standards applicable to downstream waste management under the HKC should be specified, and parties should communicate which standards they consider mandatory when authorising facilities.
- Inventory of Hazardous Materials: the scope of the inventory under the HKC should be updated to cover the larger number of materials included under the EU SRR.
The full study is available here.
Picture: Bangladesh is ready for next phase to make ship recycling green and sustainable (photo by IMO, Flickr, CC BY 2.0).
Also read: BIMCO paper: ‘Remove obstacles to safer ship recycling’
