In February, the European Commission adopted the 15th edition of the European List of Ship Recycling Facilities. The list now contains 41 facilities of which 30 are in the European Union (EU), Norway and the UK, 10 are in Türkiye and one is in the United States.

Once again, the EU member states have voted to support the Commission’s recommendation to not add any recycling facilities in South Asia despite a significant transformation at many yards in the region.

Today, over 110 Indian recycling yards hold a Hong Kong Convention (HKC) Statement of Compliance, issued by International Association of Classification Societies (IACS) members. In addition, 23 yards in Bangladesh have been authorised to conduct ship recycling by their national authorities as per HKC requirements. And yet, for the 15th time, and despite several Commission-led inspections and audits, none of the yards appear on the EU list. In fact, not a single Indian yard has been approved by the EU.

From the point of view of BIMCO and our Ship Recycling Alliance – which includes representatives from ship recycling associations, facilities, cash buyers and shipowners – the omission of South Asian facilities on the list is no longer just an administrative detail. Some of these facilities achieve, or even exceed, the EU standards. The omission, we believe, is therefore a stark reminder of how limited the EU ship recycling regulation is when it comes to creating real, tangible benefits where it is needed the most.

The EU list aims to set higher safety and environmental standards globally. The truth, however, is that this intention stops at Europe’s borders because ships flying an EU member state flag must be recycled at a facility on the EU list. In 2024, around 80 percent of global ship recycling tonnage was processed in South Asia, regardless of EU policy. The reality is that the regulation is not preventing ships from heading to the region for recycling.

Rethinking the EU approach

We believe it is time for the Commission to rethink its approach.

With the HKC already in force, we have a multilateral framework on the table which has already demonstrated that its design is effective for addressing substandard ship recycling. The HKC functions partly because it is based on time-tested governance mechanisms of the maritime world. The HKC essentially draws upon, and enhances, the Basel Convention (BC) Prior Informed Consent (PIC) procedure but adds significant improvements tailored specifically to the international ship recycling and shipping industries.

Under the HKC, the procedural responsibility shifts from the environmental ministry of the state of export and import (as required by the BC) to the competent authority of the ship’s flag state and the recycling state. This approach places decision-making and oversight with bodies that are more familiar with shipping and ship recycling operations, technical requirements, and enforcement practices, ensuring a more coherent and effective regulatory process. Instead of requiring export and import states to exchange signed consent forms, the HKC framework ensures life-span compliance. It does so through a system of surveys and certification, making both the flag state and the recycling state directly accountable for granting permission for each ship, from building to recycling.

This system replaces the more static and often impractical end-of-life cross-border notification process of the BC PIC. It offers a more dynamic, lifespan survey and certificate-based approach that is better suited to the realities of global shipping and ship recycling.

It is time to close the gap between well-intentioned regulations and everyday realities. Instead of doubling down on EU-specific regulations with limited reach, the environmental protection and, critically, worker safety would be better served by the 27 EU member states actively supporting and adhering to the multilateral framework already in place at the IMO. Next year, deliberations will commence at the IMO regarding the potential need for further adjustments to the HKC to ensure that it remains up-to-date and effective.

By collaborating globally and leveraging the HKC, broader and more meaningful progress can be achieved. Every day the Hong Kong Convention is subject to the legal uncertainty created by competing global and regional regulation is another day of progress lost for environmental protection and worker safety.

According to our estimates, around 16,000 ships will require recycling over the next 10 years. We believe the yards in places such as Alang in India – which have invested heavily, rebuilt infrastructure, repeated audits and received certification from leading classification societies – belong on the EU list.

Continuing to ignore the progress of the ship recycling industry in South Asia is not prudent, it’s misunderstood.

Source: BIMCO