COP 28 BIMCO side event

Where do we go from here? A roadmap for HKC implementation

Published: 07 December 2023

Following Pakistan's recent accession to the Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships (HKC), all major ship recycling states, including Türkiye, India, Bangladesh, and Pakistan, have become parties to the IMO's HKC. 

As these countries recycle approximately 95% of the world's tonnage, the time has come for stakeholders to reflect and plan for the future. This urgency was emphasised at the recent BIMCO side event during COP 28, addressing the challenges and opportunities in achieving global safe and environmentally sound ship recycling. 

The roadmap outlined at the event stressed the need for a clear implementation direction. Challenges such as legal frameworks, transparency, and circularity principles in shipbuilding were discussed. The focus was on saving greenhouse gas emissions through careful consideration of ship and steel recycling processes, as well as the use of recycled steel in shipbuilding. 

Key challenges identified include certification of green steel, the need for a global playing field by amending HKC, coexistence of the UN Environment Programme and the HKC conventions for material traceability, and aligning terminology to prevent downcycling of scrap steel. Additionally, principles of circularity should be integrated into shipbuilding processes. 

Recognising the progress made by major recycling regions over the past decade, it is crucial for major flag states like the Marshall Islands, Singapore, Greece, Cyprus, and China to ratify the IMO HKC. With all major recycling states as parties to HKC, the enforcement of Inventory of Hazardous Materials (IHM) onboard ships will strengthen HKC compliance. 

Reflection by EU Member States is essential to address the legal complexity resulting from the Basel BAN amendment and recent changes to EU regulations. The roadmap emphasises the need for a unified legal framework to ensure legal certainty for ship recycling facilities and shipowners. 

In conclusion, stakeholders must act urgently over the coming year and a half to address challenges and set a roadmap for achieving global safe and environmentally sound ship recycling by 2025. Shipowners should use compliant facilities, flag and port states must ratify the HKC promptly and UN bodies need to agree on a legal framework. The HKC, with a proven track record, has brought significant progress, and collaboration is vital for further success.


Beverley Mackenzie


Dr. Bev Mackenzie

Head of Intergovernmental Engagement

London, United Kingdom