Assessing global standards for ship recycling: Gap analysis of the Hong Kong Convention and EU Ship Recycling Regulation
When ships reach the end of their operational life, they are normally dismantled for scrap in a practice that is referred to as “ship recycling”. The majority of global ship recycling takes place in South Asia (India, Bangladesh and Pakistan) as well as in Türkiye.
Ships are structurally complex and their dismantling can generate various environmental, safety and health hazards. As a result, there are international regulations in place which aim to ensure that the hazards of ship recycling are managed. In 2013 the EU adopted the EU Ship Recycling Regulation (EU SSR) which has been applicable to ships in scope since 31 December 2018. Meanwhile, the IMO Hong Kong Convention (HKC) entered into force on 26 June 2025 following its adoption in 2009, also regulating the issue of ship recycling.
The objective of this report is to identify and analyse key areas where the HKC and the EU SSR diverge. To do this, the report examines the legal texts of both frameworks, together with the corresponding IMO and EU guidelines and secondary legislation. Several recommendations to narrow the gaps between the frameworks are also given.
The national implementations of the EU SRR and HKC as well as guidelines from other bodies such as the ILO are out of scope of this report.
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