Countdown to compliance: Are shipowners ready for the Hong Kong Convention?

February 13, 2025, by Sara Kosmajac

With the Hong Kong Convention (HKC) coming into effect on June 26, 2025, the clock is ticking for shipowners who need to ensure compliance with regulatory controls and inspections concerning the recycling of their end-of-life vessels, Norway-based classification society DNV has stressed.

In its new guidance paper “Safe and Green Recycling for Ship Owners”, DNV highlighted that the International Maritime Organization’s (IMO) Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships (HKC) is a ‘big’ step toward safer and more sustainable shipping practices, particularly with the fact that thousands of vessels are scheduled to be recycled by 2032.

Though it enters force in June this year, the Hong Kong Convention requires full compliance by 2030. It is understood that twenty-four countries and the four largest recycling nations by tonnage—India, Bangladesh, Pakistan and Türkiye—have ratified the HKC.

As explained, vessels that need to comply must have an inventory of hazardous materials (IHM) for Parts I together with an onboard survey before being granted an international IHM certificate. Per DNV, the end-of-life unit has to be sent for recycling at a facility that holds a document of authorization for ship recycling (DASR) from its authority.

“While undertaking inspections for the European Commission across several countries, we noted promising improvements in worker’s safety, environmental protection, IHM reporting, and hazardous materials handling,” Tone Knudsen Fiskeseth, Principal Consultant, commented.

“With the HKC taking effect in 2025, shipowners need to understand how to comply and navigate a complex regulatory landscape that also includes the Basel Convention and the EU SRR. It will be interesting to follow the technology innovations within ship dismantling and how they will impact safety, capacity issues and sustainable recycling,” she added.

Giving more insight into the matter, Knut Ørbeck-Nilssen, CEO of DNV Maritime, remarked: “As the maritime industry faces increasing pressure to adopt sustainable practices, it is essential for shipowners to fully understand the scope of regulations established by the EU and IMO. The primary focus of these regulations is to enhance the health and safety of workers while protecting the environment from pollution and the release of hazardous materials.“

The flipside: (Ir)responsible recycling

The ship recycling process has been seen as an ‘essential’ contributor to the circular economy but this landscape has seen its fair share of stumbling blocks. One of the most burning issues is centered around workplace safety.

Vessels often carry dangerous materials that can pose tremendous risks to workers’ health and safety as well as to the environment if not managed properly. In addition to this, certain shipowners and managers have failed to follow the guidelines for responsible handling of end-of-life ships which has led to a number of tragic accidents over the years.

As understood, though they have certified the HKC, India and Bangladesh, as well as Pakistan, have seen the largest number of commercial and offshore units being scrapped—often in unsafe conditions—at their beaches.

In fact, according to the Belgian organization NGO Shipbreaking Platform, in 2023, 85% of the global end-of-life fleet, equaling 325 vessels in total, was dismantled on a beach in either of the abovementioned three countries.

The statistics have not altered much since. Bangladesh has held the number one position as the go-to country for scrapping for consecutive years now. What is more, the Belgian NGO revealed in early February 2025 that as much as 80% of scrapped units—i.e. 255 out of 409 ships—in 2024 were dismantled under sub-par conditions.

NGO Shipbreaking Platform: 80% of scrapped ships in 2024 dismantled under sub-par and high-risk conditions

Regulation & Policy

Some of the accidents that occurred due to irresponsible scrapping practices occurred on yards that were reportedly HKC-certified, like the explosion at the MT Suvarna Swarajya which claimed the lives of six people, and injuring many more.

Incidents like these have prompted certain organizations to rethink the Hong Kong Convention and explore whether or not this was the most viable solution for the maritime industry.

Following the MT Suvarna Swarajya accident, the NGO Shipbreaking Platform and the Human Rights Watch warned that the convention “provided for weak environmental and safety standards” and that it could undermine existing laws and efforts to reform dangerous and polluting practices.

In 2023, the UN Special Rapporteur on Toxics and Human Rights, the Centre for International Environmental Law and the European Parliament also endeavored to point out the gaps in the HKC, citing that the convention did not offer an equivalent level of control to the Basel Convention as it does not prevent the dumping of toxic ships in developing countries.