During the 2024 GREEN4SEA Singapore Forum, Capt. Akshat Arora, Senior Risk Assessor, UK P&I Club, provided an overview of ship recycling regulations, emphasizing best practices for the Inventory of Hazardous Materials (IHM) and highlighting the risks associated with non-compliance.
In recent years, maritime decarbonisation has become a major focus, with a range of regulations and targets aimed at reducing greenhouse gas emissions. As these regulations become more stringent, it is anticipated that many aging and inefficient ships will be directed toward recycling yards.
In May 2023, BIMCO estimated that more than 15,000 ships with a deadweight capacity of over 600 million tonnes could be recycled between 2023 and 2032. However, current geopolitical conflicts and Red Sea diversions have increased ship demand, causing ship recycling volumes to hit a 20-year low. Nonetheless, ship recycling is expected to rebound in the coming years.
Now that all the major flag states and ship-recycling countries have ratified the Hong Kong Convention, it is set to enter into force on 26 June 2025. This is a significant milestone in ensuring safe and environmentally sound ship recycling. However, there is still one year to go before the Hong Kong Convention takes effect, and there are still some legal uncertainties regarding regulatory compliance that need to be addressed.
Overview of ship recycling regulations
Hong Kong Convention: Adopted in 2009 and set to come into force on 26 June 2025, this convention applies to ships over 500 GT engaged in international voyages, with exceptions like warships and domestic fleets. It also addresses the working and environmental conditions of ship recycling facilities.
Basel Convention: Entered into force in 1992, this convention regulates the transboundary movement of hazardous waste. While it does not specifically mention ship recycling, end-of-life ships often contain toxic components like asbestos, lead, and hydrocarbons, classifying them as hazardous waste. However, the successful application of Basel to end-of-life ships has historically been difficult, primarily due to the challenges in identifying when a ship becomes “waste”.
Basel’s Ban Amendment: Entered into force in December 2019, it prohibits the exporting of hazardous wastes (including end-of-life ships) from the OECD (Organisation for Economic Co-operation and Development) to non-OECD countries.
EU Waste Shipment Regulation (EU-WSR): Adopted in 2006, this regulation incorporates the provisions of the Basel Convention and its Ban amendment into EU law. It applies to all ships greater than 500GT in EU/EEA waters, regardless of flag. If a decision to recycle the ship is taken while the vessel was in EU/EEA waters, the ship can only be recycled in an OECD country.
EU Ship Recycling Regulation (EU-SRR): Adopted in 2013, this regulation aimed to facilitate early implementation of the Hong Kong Convention within the EU region. Under the EU-SRR, ships flying the flag of an EU member state can only be recycled in one of the yards on the EU’s list of ship recycling facilities.
Additionally, the UAE ship recycling regulation, which came into force at the end of March 2024, mirrors the EU ship recycling regulation. It applies to both UAE-flagged ships and foreign ships visiting UAE ports.
Compliance and sustainability
There have been instances in the past where shipowners were prosecuted for what was deemed irresponsible ship recycling. Having these complex regulations with various different requirements, some of which overlap, could potentially cause confusion and leave the operators at a risk of prosecution. With the Hong Kong Convention set to enter into force in June 2025, aligning the various requirements under a single regulatory framework would be a welcome development. This matter was raised by BIMCO and other industry stakeholders during the previous MEPC-81 meeting.
A primary requirement of the recycling regulations is that ships must have an Inventory of Hazardous Materials (IHM) onboard. For EU-flagged ships, this requirement has been in force since 31 December 2018, and for non-EU-flagged ships visiting the EU region since 31 December 2020. With the Hong Kong Convention’s ratification, this requirement will become globally enforced.
Essentially, an IHM consists of three parts:
- Part I: Hazardous materials contained in the ship’s structure and equipment
- Part II: Operationally generated wastes
- Part III: Stores
Part I applies to all ships, and shall be kept up-to-date throughout the operational life of the ship. However, Part II & III are only required to be prepared when the ship is decided to be sent for recycling. Additionally, ships destined for recycling are required to have a ship recycling plan (SRP) and an International Ready for Recycling Certificate.
To prepare a ship for recycling, the shipowner would need to complete IHM Part II (operationally generated wastes) and Part III (stores) and send these to the ship recycling facility, along with the up-to-date IHM Part I. The ship recycling facility would then prepare a ship-specific SRP. Once the SRP is ready, the shipowner shall request a final survey from the ship’s flag state or a recognised organisation to verify IHM Parts I, II and III, and the approved SRP.
The UK P&I Club recently published the second edition of its Risk Focus: Inventory of Hazardous Materials (IHM), which provides best practices around this topic and guidance to shipowners when compiling their IHM.
To conclude, it is important to consider sustainability not only during the building stages or operational life of a ship but throughout its entire lifecycle, including its end-of-life phase. Hong Kong Convention ideally puts the safety and environmentally sound practices at the gist of it.
Above article has been edited from Capt. Akshat Arora’s presentation during the 2024 GREEN4SEA Singapore Forum.
Explore more by watching his video presentation here below
The views presented are only those of the author and do not necessarily reflect those of SAFETY4SEA and are for information sharing and discussion purposes only.
