European and international shipowners are calling for a single global ship recycling rulebook, arguing that the entry into force of the Hong Kong Convention (HKC) has transformed standards worldwide and should become the foundation for a unified framework, according to a report by Splash247.
The call follows a joint independent study by the European Community Shipowners’ Associations (ECSA) and the International Chamber of Shipping (ICS), which examined differences between the EU Ship Recycling Regulation (EU SRR) and the International Maritime Organization’s (IMO) Hong Kong Convention. The HKC entered into force on June 26, 2025, and the IMO’s experience-building phase is due to begin in 2027.
What the Study Found
According to the report, the two regimes are “broadly aligned” but important gaps remain. The study identifies three key areas where the convention could be strengthened:
- Authorisation procedures for recycling facilities
- Standards governing downstream waste management
- Scope of the Inventory of Hazardous Materials required onboard ships
“Our study identifies concrete areas where we can strengthen the convention and raise global standards,” said Sotiris Raptis, secretary general of ECSA. He described the HKC’s entry into force as “a major milestone” for safe and environmentally sound ship recycling.
John Stawpert, principal director of marine affairs at ICS, said the study demonstrated “significant overlaps” between the two regulatory systems while highlighting “three critical gaps” that should be addressed during the IMO review process.
The Push for One Rulebook
The HKC has already driven significant change in the global recycling sector. The report states that more than 100 ship recycling facilities are now certified as compliant with the convention, including numerous yards in India, Bangladesh, Pakistan, Türkiye and China. Together, compliant facilities now account for annual recycling capacity of around 30 million gross tonnes, far exceeding current global recycling demand.
ECSA and ICS argue that greater convergence between the EU and global regimes would reduce regulatory fragmentation and support consistent implementation of ship recycling standards worldwide. Raptis also urged Brussels to address capacity constraints within the EU regime by making it easier for qualified non-OECD recycling yards to join the EU-approved recycling list.
Compliance Implications for Trade Professionals
| Issue | Current Status | Proposed Action |
|---|---|---|
| Authorisation procedures | Differences between EU SRR and HKC | Strengthen HKC procedures during IMO review |
| Downstream waste management | EU SRR has stricter requirements | Align HKC standards upward |
| Inventory of Hazardous Materials | Scope varies | Harmonise requirements |
For trade compliance officers and customs brokers, the push for a single rulebook signals potential changes to the EU’s approved recycling facility list and possible amendments to the EU SRR. Companies with shipping operations should monitor the IMO’s experience-building phase from 2027 and prepare for possible updates to certification requirements for recycling facilities. The study’s findings may also influence how customs and environmental authorities verify compliance with ship recycling rules.
Raptis emphasised that the EU should consider recognising more non-OECD yards under the EU SRR to address capacity constraints, which could expand the pool of compliant facilities. Stawpert noted that the three critical gaps should be addressed during the IMO review process, indicating that the regulatory landscape may shift in the coming years.
As the maritime industry works toward a single rulebook, companies should engage with industry associations such as ECSA and ICS to stay informed of developments and ensure their recycling practices meet both current and future requirements.
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