Background
Recycling is the most environmentally sound way to dispose of ships at the end of their commercial lives. Ship recycling contributes to the circular economy through the supply of scrap steel to the steel producing industries, thereby reducing both the need for raw materials such as iron ore and the overall CO2 emissions from the production of new steel.
BIMCO is committed to promoting safe and environmentally sound ship recycling and welcomes the entry into force of the Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships (HKC) in 2025. Having a global legally binding standard in place is a major breakthrough as it ensures overarching environmental and safety standards, as well as creating a global level playing field for ship recycling.
While the HKC enters into force 15 years after its adoption as the global standard to regulate ship recycling, it is vital that attention remains focused on continuous improvements. The EU Ship Recycling Regulation (EU SRR) and other best practices could be used as benchmarks for this exercise. Levelling up the playing field and ensuring high quality standards internationally are essential to uphold safety and environmental protection. In addition, the life cycle approach taken under the HKC will allow a better traceability of hazardous materials through the IHM and could help increase the ship’s recyclability. It also has the potential to be the stepping stone to better integrate ship recycling into a circular economy as a source of non-virgin steel and materials.
As of 26 June 2025, four main legal instruments could be applied to ship recycling related activities, depending on the flag of the ship and/or its location on the globe while going for recycling: the IMO HKC, the United Nations Environmental Programme’s Basel Convention (UNEP’s BC), the EU SRR and the EU Waste Shipment Regulation (EU WSR). The requirements on the transboundary movement of end-of-life ships are contradictory between the four instruments leading to an unacceptable situation. A ship which is fully certified to operate under IMO rules and regulations, should not be prohibited to do so by another UN body’s rules and regulations. For the BC and its associated ban (and so by extension the EU regulations) and the HKC to co-exist after 26 June 2025, there is an urgent need for the states that are parties to the BC (nearly all countries of the world) and the IMO member states to ensure that all legal uncertainties are clarified.
In addition, EU members states will be required to implement the European Crime Directive, which may bring significant changes such as potentially extending the jurisdiction to certain offences onboard while outside the EU territory.
Most recent BIMCO data predicts that over 15,000 ships globally will need to be recycled in the next decade, which is more than twice the amount recycled globally in the ten years up to 2025. Addressing this capacity issue is crucial not only for the EU fleet (which can only be recycled in EU approved facilities) but also for the global shipping industry to comply with environmental and safety regulations, as shown in the BIMCO report of December 2024. Deploying new HKC compliant capacity will demand extra time, money and effort as dedicated infrastructure will need to be in place to ensure a better protection of the environment and worker safety. Furthermore, expanding ship recycling capacity will necessitate hiring and training new workers, as well as modifying the current waste management capacity to accommodate the requirements of ship recycling facilities.
This increased demand for recycling capacity, coupled with legal uncertainties, poses significant challenges for ship owners to comply with international standards. Addressing these issues is crucial to enable the recycling of ships in adherence to global regulations.
To further help address the work around the key areas, BIMCO has established the Ship Recycling Alliance. This Alliance between stakeholders in the shipping industry and the ship recycling industry, will allow to evaluate and assess amendments and possible improvements to a global standard, where and when needed.
BIMCO’s Position Statement
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BIMCO supports continuous improvement of global ship recycling standards, in line with best practices such as under the EU SRR, both at the level of the IMO as well as the BC
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BIMCO supports the co-existence of the BC and the HKC, each within their own area of competence and merits
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BIMCO supports the call for an experience building phase at the IMO, while also emphasising the need for a robust implementation and alignment between BC guidelines and the IMO HKC guidelines
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BIMCO is of the view that the provisions of the BC shall not affect transboundary movements which take place pursuant to the HKC, in line with IMO HKSRC.2/Circ.1
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BIMCO will engage with competent intergovernmental organisations, such as the IMO, the UNEP and the EU Commission to highlight the importance of legal clarity and transparency
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BIMCO believes that the HKC should prevail in any international law conflict between the HKC and the BC, and the HKC should henceforth be recognised as the framework for sending ships for recycling, in line with the Vienna Convention on the law of treaties
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In the current transitional period prior to the entry into force of HKC, shipowners are urged
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to use HKC compliant facilities
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to develop and regularly update the inventory of hazardous materials (IHM), based on suppliers’ documentation in the form of Material Declarations, the content of which need to be improved to enable shipowners to properly maintain the IHM
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BIMCO is concerned about the lack of compliant recycling capacity due to the predicted increased demand for recycling and will raise awareness of this issue
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BIMCO will monitor the impact of the implementation of the ECD in the different EU member states
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BIMCO strongly recommends the use of BIMCO’s standard contract for the sale of ships for green recycling, RECYCLECON.