Ship recycling: end of life for a ship, but no end to regulations

When it comes to ship recycling, shipowners face a complex, costly and daunting regulatory regime. The Hong Kong Convention (HKC), Basel Convention, EU Ship Recycling Regulation, Basel Ban and EU Waste shipment all address, one way or another, the handling of a ship’s end of life.

Wirana Shipping vice president, Middle East and Green Recycling co-ordinator, Hiitesh Vvyaas, cautioned shipowners that “more than one regulation may become applicable to the end of life of a ship going to a ship recycling destination. So, a shipowner needs to be careful and mindful about compliance with all these regulations.”

HKC, a dedicated regulation aimed at promoting responsible ship recycling, came into force in June 2025. “Moreover, HKC also covers the ship during its entire life, which is an additional advantage,” he said.

Mr Vvyaas made his comments during Riviera’s webinar, Navigating the new era of shipping recycling compliance. The webinar was sponsored by Wirana Shipping Corp.

Mr Vvyaas was joined by a panel of experts representing a broad spectrum of maritime stakeholders. They included Norton Rose Fulbright partner, Philip Roche, UN Secretariat of the Basel, Rotterdam and Stockholm Conventions, Programme Officer, Legal and Policy Unit, Susan Wingfield, and AP Møller–Mærsk senior advisor, public and regulatory affairs, energy transition and international legal affairs, Jesper Fanø.

The panellists discussed the complexities, overlaps and gaps created by the regulatory landscape, noting the potential time consuming and costly nature of the ship recycling process.

Ms Wingfield provided background on the Basel Convention, which is aimed at preventing and minimising both the generation and transboundary movement of hazardous and chemical waste.

One provision in the convention is the prior informed consent procedure, which essentially means that any shipment of hazardous and other waste needs to be consented by the exporter, the transit state and importing authority,” she explained.

She also said another pillar of the convention is environmentally sound management. “This means that any country that is party to the Basel is required to manage hazardous materials in an environmentally responsible manner.

“For governments who are party to both the Basel Convention and Hong Kong Convention: it is up to them to decide which convention to apply,” said Ms Whitfield.

But Mr Fanø said, “We need clarification on the legal aspects of ship recycling because there is an expected uptake in ship recycling volumes coming. The green transition is a big part of that.”

He said AP Møller–Mærsk has its own ship recycling process that goes beyond the current regulations.

A long-time shipping lawyer, Mr Roche offered some sound advice to shipowners when assessing the various regulatory regimes. “When it comes to compliance and regulation, you need to comply with the regulation that is in the statute book of the place where you intend to or make a decision to scrap your vessels,” he said.

Mr Vvyaas also highlighted a problem on the horizon: responsible ship recycling yard capacity. He questioned whether EU-listed yards could also be extended to non-OECD countries to provide the “additional capacity that may be required at a later stage when a huge flow of ships” must be recycled.

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