Ship Recycling Rules: Hong Kong Convention vs. EU SRR – What Owners Must Know

My name is Davide Ramponi, I’m 20 years old and currently training as a shipping agent in Hamburg. On this blog, I take you with me on my journey into the exciting world of shipping. I share my knowledge, my experiences, and my progress toward becoming an expert in the field of Sale and Purchase – the trade with ships.

Today, we’re tackling a topic that combines environmental responsibility with legal obligation: ship recycling. Every ship has an end-of-life moment. But how that moment is handled—whether responsibly or recklessly—can make all the difference for the planet, for safety, and for your legal standing.

The choice between compliant, sustainable recycling and risky shortcuts is no longer just ethical—it’s legally defined and enforceable. Two main frameworks shape this field: the Hong Kong Convention (HKC) and the EU Ship Recycling Regulation (EU SRR). But what are their differences? How do they affect shipowners? And what happens if you don’t comply?

Let’s navigate the cutting edge of sustainable ship recycling. 🌱⚙️

🌍 The Global Framework: What Is the Hong Kong Convention?

The Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships, adopted by the IMO in 2009, is the first major attempt to standardize ship recycling worldwide.

📜 Key Objectives of the HKC:

• Minimize risks to human health and the environment

• Control hazardous materials used in ship construction

• Ensure ships are dismantled in approved recycling facilities

• Require Inventory of Hazardous Materials (IHM) to be maintained throughout a ship’s life

🚢 Who does it apply to?

• Ships over 500 GT engaged in international trade

• Ship recycling facilities under the jurisdiction of a party to the convention

📅 Status update:

The HKC will enter into force on June 26, 2025, after Bangladesh—the world’s top shipbreaking location—ratified it in 2023.

🇪🇺 The Regional Approach: What Is the EU SRR?

The EU Ship Recycling Regulation (EU SRR) was adopted in 2013 and came into full force in 2019. It goes further than the HKC, applying immediately and specifically to ships under an EU flag.

🧾 What does the EU SRR require?

• All EU-flagged ships must be recycled at facilities listed in the EU-approved ship recycling yards

• Ships must carry and update a certified Inventory of Hazardous Materials (IHM)

• Recycling facilities must comply with strict environmental and labor safety standards

🗺️ Current EU List includes shipyards in:

• Europe (e.g. Denmark, Netherlands, Turkey)

• Some in Asia (only if meeting EU criteria)

🚨 Key difference: 

EU SRR prohibits recycling in yards not on the EU list, even if they comply with the Hong Kong Convention.

⚖️ HKC vs. EU SRR: Key Differences at a Glance

Feature	Hong Kong Convention (HKC)	EU Ship Recycling Regulation (EU SRR)
Legal status	Global treaty (IMO)	Binding EU law
Entry into force	June 2025	Already in force since 2019
Applies to	All ships over 500 GT (global)	EU-flagged ships
Facility approval	National-level	Must be EU-listed
Hazardous material rules	IHM required for new and existing ships	IHM mandatory + EU-approved documentation
Enforcement	Through flag states	Direct enforcement by EU states

💡 Bottom line:

HKC sets a global minimum, EU SRR sets a regional maximum.

🧭 What Shipowners Must Do to Comply

Whether your ship is EU-flagged or not, you can’t ignore the growing legal and ESG (Environmental, Social, Governance) pressure surrounding end-of-life management.

✅ IHM Compliance Is Non-Negotiable

Both HKC and EU SRR require an Inventory of Hazardous Materials (IHM) onboard:

• Includes asbestos, PCBs, lead, mercury, and ozone-depleting substances

• Must be compiled by a certified expert

• Requires maintenance throughout the vessel’s lifetime

• Verified during Port State Control inspections

📌 Failure to provide IHM can result in detention.

🚢 Choosing the Right Yard: HKC-Compliant vs. EU-Approved

Before recycling, shipowners must select a certified facility:

• HKC-compliant facilities meet basic international standards

• EU-approved facilities must undergo extra inspections and meet higher labor safety and environmental benchmarks

🛑 Warning: 

Using a non-listed yard for an EU-flagged ship = automatic non-compliance.

🌱 Real-World Examples of Sustainable Recycling

Let’s look at two recent examples of how ship recycling can be done responsibly:

1. Maersk and the Alang Transformation

Maersk partnered with several yards in Alang, India, to upgrade conditions to HKC standards.

📌 Outcome:

• Investments in worker safety, PPE, environmental controls

• Over 30 vessels recycled under monitored conditions

• Maersk published its Ship Recycling Transparency Report

💬 Lesson: 

With the right partnerships, even traditionally unsafe yards can improve.

2. Wallenius Wilhelmsen’s Green Approach in Turkey

This Norwegian shipping company recycled vessels at EU-listed Turkish facilities, fully aligned with EU SRR.

📌 Best practices:

• Pre-recycling planning and hazard removal

• Transparent documentation

• Third-party auditing

💬 Lesson: 

EU compliance is not just possible—it’s commercially valuable.

⚠️ The Risks of Non-Compliant Ship Recycling

Choosing the wrong facility or failing to document your recycling process can lead to serious consequences.

🚫 Legal Risks:

• Detention of vessels by Port State Control

• Fines and litigation from environmental groups

• Flag state penalties or even flag removal

💥 Reputational Risks:

• Media scrutiny of unsafe practices (e.g., toxic beaches in South Asia)

• Pressure from cargo owners and financiers to demonstrate ESG performance

• Loss of charter business due to negative publicity

🌍 Today’s market favors transparency and responsibility.

🔮 What the Future Holds: From Regulation to Opportunity

The ship recycling landscape is changing fast. With HKC entering force in 2025 and ESG reporting expanding, owners who act now will be ahead of the curve.

What we might see soon:

• 🌐 Global IHM databases to streamline inspections

• 📈 Integration of recycling compliance into vessel valuations

• 🏭 Rise of automated, enclosed recycling yards

• 💼 Carbon credits or tax incentives for sustainable end-of-life processes

🎯 Smart recycling will soon be a strategic advantage, not just a legal box to check.

🧰 Ship Recycling Compliance Checklist

Here’s your quick guide to staying compliant and responsible:

✅ Before Recycling:

• Determine if your vessel falls under EU SRR or HKC

• Commission a certified Inventory of Hazardous Materials (IHM)

• Review the yard’s compliance status (HKC or EU-listed)

⚙️ During Planning:

• Appoint a Ship Recycling Plan

• Notify relevant flag state and classification society

• Ensure proper removal of hazardous materials

📑 After Recycling:

• Collect and store all compliance documentation

• Request recycling yard certificates and audit reports

• Include outcome in ESG reports and stakeholder updates

🧭 Final Thoughts: Responsible Recycling is Good Shipping

Every ship has a final voyage—but how that voyage ends matters more than ever.

🔎 Key Takeaways:

• The Hong Kong Convention sets global standards—but the EU SRR goes further

• Shipowners must plan ahead, especially regarding IHM and yard selection

• Sustainable recycling is now a legal requirement, market expectation, and ethical obligation

Are your vessels recycling-ready? Have you navigated the EU SRR or HKC in your fleet operations?

💬 Share your thoughts in the comments — I look forward to the exchange!

---

---