When ships reach the end of their operational life, they are normally dismantled for scrap in a practice that is referred to as “ship recycling”. However ships are structurally complex and their dismantling can generate various environmental, safety and health hazards. As a result, there are international regulations in place which aim to ensure that the hazards of ship recycling are managed. In 2013 the EU adopted the EU Ship Recycling Regulation (EU SSR) which has been applicable to ships in scope since 31 December 2018. Meanwhile, the IMO Hong Kong Convention (HKC) entered into force in 2025 following its adoption in 2009, regulating ship recycling at a global level.
This report identifies key areas where the HKC and EU SRR diverge, based on an analysis of the legal texts and guidelines established by each framework. Key divergences identified and discussed in the report concern the mechanisms for authorising ship recycling facilities under both frameworks, which are more prescriptive and extensive under the EU SRR for facilities located outside the EU. Gaps between the HKC and the EU SRR also exist due to the legal text of the EU SRR setting more specific requirements, for instance on the control of waste leakage during the ship recycling process as well as the downstream management of that waste. The gaps between the EU SRR and HKC with respect to requirements for ships are more limited, although a significant gap in the HKC is the narrower scope of the hazardous materials which are required to be inventorised during a ship’s operational life and ahead of recycling.
Compared to the EU SRR, the HKC has the advantage of applying across a far wider scope, covering more ships and ship recycling facilities. This broader reach is a major strength, as it increases the potential impact of stronger social, human and environmental protection. However, the HKC’s presently more flexible and less specific requirements offer less protection against uneven implementation. The report therefore also presents recommendations to strengthen the HKC in the event of a potential revision of the Convention in the years ahead.
The HKC entered into force on 26 June 2025. The methodology of the report did not include whether or not progress has been made internationally in ship recycling since that date.
The report was conducted at the request of European Shipowners | ECSA and the International Chamber of Shipping (ICS).