The Hong Kong Convention promises to reshape ship recycling practices worldwide by imposing stringent environmental, health, and safety standards—particularly targeting regions like South Asia where the majority of ship recycling takes place, argues Rohith Agarwal, Managing Partner at GUIDESHIP CONSULTING SERVICES LLP.
As the maritime industry counts down to June 26, 2025, the date marks a pivotal shift in the way ships will be recycled globally. On this day, the Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships (HKC) will finally enter into force, over a decade after its adoption by the International Maritime Organization (IMO) in 2009.
One of the most significant implications of the Convention’s implementation is the mandatory requirement of key statutory documents. These include the Document of Authorization to conduct Ship Recycling (DASR) for facilities and the Inventory of Hazardous Materials Ready for Recycling Certificate (IRRC) for ships. These documents will become compulsory without any grace period outlined in the Convention itself.
This marks a clear exit from the voluntary “Statements of Compliance” (SoCs) that have thus far been issued by classification societies. While some flag states and recycling authorities may choose to temporarily acknowledge these SoCs during the early stages of implementation, the industry is expected to transition entirely to the statutory regime.
This shift will have significant implications for ship recycling yards—especially in South Asia. According to a strict reading of the Convention, non-compliant facilities in Party States will be prohibited from conducting ship recycling operations post-June 2025.
However, practical realities on the ground suggest that some level of transitional accommodation may be permitted. This could include the issuance of provisional DASRs for yards undergoing upgrades, subject to follow-up inspections and time-bound compliance plans.
The enforcement of HKC will likely result in a temporary contraction of global ship recycling capacity, less-resourced facilities—may struggle to meet the new requirements in time. As a consequence, compliant yards will be better positioned to handle the influx of tonnage from responsible shipowners and flag states.
Meanwhile, non-compliant facilities will be relegated to handling vessels from non-HKC Parties or less environmentally conscious owners, pushing them to the fringes of the global recycling market.
Classification societies, which have traditionally issued voluntary SoCs, will now take on a more formal role under the Convention. Acting as Recognized Organizations (ROs), they will be authorized by flag and recycling states to conduct inspections and issue DASRs and IRRCs. In some cases, yards that previously held SoCs may be subject to confirmatory audits or full re-assessments before being granted statutory certification.
Interestingly, the Convention itself does not prescribe any global transitional period. However, individual Party States may adopt temporary measures—such as conditionally accepting SoCs or granting limited-time DASRs—as they work to align their national legislation with the Convention.
This is particularly relevant for few South Asian nations, where legislative, administrative, and infrastructural challenges may delay full enforcement.
Variations in implementation and enforcement are expected across jurisdictions, especially in countries where domestic regulation and institutional frameworks for the HKC are still evolving. While some states may adopt a strict and immediate approach, others may take a more gradual path, balancing regulatory compliance with economic and employment considerations.
In the long term, however, the trajectory is clear. The HKC sets a new global benchmark for safe and environmentally sound ship recycling, and market forces are expected to favour those who comply. As awareness of environmental, social, and governance (ESG) responsibilities grows within the maritime sector, shipowners will increasingly choose compliant facilities, aligning their recycling practices with sustainability goals and international law.
The success of the HKC will ultimately depend not only on the letter of the Convention but also on the spirit of enforcement by Party States, the integrity of inspections by ROs, and the commitment of the ship recycling industry to transition toward cleaner, safer, and more responsible practices.
June 26, 2025, will be a litmus test for the global maritime community—one that will define the future of ship recycling for decades to come.
The views presented hereabove are only those of the author and do not necessarily reflect those of SAFETY4SEA and are for information sharing and discussion purposes only.
