We welcome the continued engagement by governments and stakeholders at the latest meeting of the Basel Convention Open-ended Working Group (OEWG), where discussions focused on the complex legal and environmental framework for ship recycling.
The meeting was an important step towards clarifying how international regimes should work together. Crucially, parties did not support applying both the Basel Convention and the Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships (HKC) to end-of-life ships.
This is a significant and positive outcome. Avoiding a double regulatory burden is important because overlapping regimes risk creating legal uncertainty, operational inefficiencies and disincentives to compliance.
However, although there is broad agreement that more clarity and legal certainty are needed, no final conclusions were reached on how overlapping obligations should be implemented in practice.
Global alignment is essential
We believe a globally consistent regulatory framework is essential for safe, environmentally sound and efficient ship recycling.
The entry into force of the HKC is a milestone for the industry. It establishes a comprehensive global regime designed specifically for ships. At the same time, the continued application of the Basel Convention, which was designed for general packaged hazardous waste, creates legal complexity when applied to ships operating internationally.
Ship recycling is a global activity that requires clear, harmonised rules. The discussions at OEWG highlight both the progress made and the work still needed to ensure that shipowners, recycling facilities and authorities operate under a predictable and coherent framework.
Practical challenges remain
Delegations at OEWG acknowledged several practical challenges, including:
- Diverging interpretations of when a ship becomes waste
- Uncertainty about transboundary movement procedures for ships
- Potential duplication or conflict between Basel Convention and HKC requirements.
These issues have direct implications for compliance, enforcement and the ability of shipowners to recycle ships in authorised facilities in HKC party states.
Industry progress must be supported
We have seen substantial progress in the ship recycling industry in recent years. Many recycling yards, particularly in South Asia, have upgraded facilities and standards in line with HKC requirements.
Transparency, third-party verification and improved safety and environmental practices are increasingly becoming the norm. It is essential that regulatory developments support this progress rather than undermine it.
The industry needs practical solutions
We encourage parties to continue working towards practical solutions that:
- Recognise the HKC as the primary global framework for ship recycling
- Avoid duplication and overlapping obligations
- Provide clear guidance on the interface between the Basel Convention and the HKC
- Support ongoing investment in compliant recycling facilities.
Regulatory clarity is not just a legal issue. It is fundamental to improving worker safety, protecting the environment and ensuring that ships are recycled responsibly worldwide.
Next steps
We will continue to engage with governments, international organisations and industry partners to support coherent policy development. Our aim is to help ensure that the transition to a robust global ship recycling regime is effective, enforceable and practicable.
The IMO experience-building phase will be an important opportunity to test the new framework in practice, identify areas where further guidance may be needed and make improvements based on real-world experience.
This phase should be used constructively to learn from implementation, address challenges as they arise and strengthen the regime where needed.
