Bangladesh’s ship recycling industry at a crossroads

Bangladesh has missed the critical deadline to implement the Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships (HKC 2009), which it ratified in June 2023, but enforcement is still pending as of June 2025. A recent article in Maritime Executive suggested that Bangladesh and Pakistan might delay enforcing the Convention by citing their socio-economic challenges and referencing international agreements like the 1992 Rio Declaration. However, experts stress that once a country ratifies an international treaty such as the Hong Kong Convention, it is legally bound under the Vienna Convention on the Law of Treaties to honor its commitments in good faith. The often non-binding language of declarations such as the Rio Declaration cannot override the binding force of ratified conventions.

The ship recycling industry (SRI) in Bangladesh is currently regulated by the Ship Breaking and Recycling Rules 2011 and the Ship Recycling Act 2018, under which the Ship Recycling Board (SRB) holds official authority. Unfortunately, the Board faces a severe manpower shortage, preventing it from effectively managing key responsibilities such as issuing No Objection Certificates (NOCs) and permits for dismantling ships. In practice, these daily administrative tasks are handled by the Ship Recycling Wing of the Ministry of Industry. The country is in a transitional phase, transferring oversight from the Ministry's Wing to the SRB. This bureaucratic shift raises concerns about whether Bangladesh has enough administrative capacity to monitor and enforce regulations as the HKC 2009's implementation deadline approaches. Since shipbreaking yards make significant capital investments in acquiring ships for dismantling, delays in permits could result in substantial financial losses due to accruing bank interest, threatening the sector's economic viability.

For the compulsion of the HKC 2009, after June 2025, no ship can be legally permitted for dismantling in any yard in Bangladesh that has not attained "green yard" status in compliance with HKC standards. Currently, only seven yards—including PHP, SN Corporation, Kabir Recycling Yard, Arab Recycling Yard, and KR Recycling Yard—have received green certification, while fifteen others are in the process of upgrading. Most operational yards remain non-compliant but together employ thousands of workers directly and support millions more in related industries such as steel manufacturing and furniture production.

Restricting ship imports to compliant yards could jeopardise these workers' livelihoods and threaten the stability of related sectors. Moreover, without enough scrap metal from ship recycling, Bangladesh's steel industry would need to import raw materials, adding pressure on the country's foreign currency reserves. The global ship recycling industry's shift from Europe to Asia was driven by the region's more relaxed regulations and environmental standards. If Bangladesh unilaterally enforces strict rules to meet the Hong Kong Convention, competing countries like Pakistan, India, and the Philippines could seize the opportunity to attract business, reducing Bangladesh's market share. Another urgent issue is hazardous waste disposal. The Bangladeshi government, with support from Japan, is developing a Treatment, Storage, and Disposal Facility (TSDF) to safely manage hazardous materials from ship recycling. However, delays in land acquisition have hindered progress, making it unlikely the TSDF will be operational by the 2025 enforcement deadline. As a result, safe hazardous waste disposal remains uncertain.

Since its inception, the Hong Kong Convention has faced criticism for disproportionately placing the burden on ship recycling states rather than ship-owning nations. Recycling countries are required to establish safe recycling facilities, maintain TSDFs, prepare Ship Recycling Plans (SRPs), and implement strict occupational health and safety standards. Meanwhile, ship owners often shift responsibility to lesser-known flag states or cash buyers by changing a ship's flag before dismantling, avoiding accountability for the ship's end-of-life impacts despite profits during its operational life. This imbalance raises a key question: is Bangladesh truly prepared to enforce the Hong Kong Convention by the 2025 deadline? Failure by Bangladesh and other major recyclers to comply- whether due to unreadiness or socioeconomic reasons- would violate international law. Ratification shows Bangladesh's commitment to uphold treaty obligations in good faith, and it is essential to distinguish between legally binding conventions and soft international declarations. More importantly, this issue goes beyond legal obligations; it concerns protecting workers' health and safety, as well as safeguarding marine and terrestrial environments. Since the international community cannot reliably monitor occupational safety or environmental compliance at ship recycling yards, national enforcement is critical. Proper implementation of the Convention would improve working conditions for vulnerable laborers and reduce environmental pollution.

A coordinated and practical approach is needed to address these challenges. First, the International Maritime Organization (IMO) should work with recycling countries to develop tailored mandatory standards within the Hong Kong Convention framework, considering their socio-economic realities. Many yards cannot afford the costs imposed by classification societies like ClassNK, GMS, or Bureau Veritas, which certify facilities based on high MEPC guidelines. Adjusting these standards to be both feasible and effective is essential.

Second, the IMO should strengthen inspection and monitoring efforts in major recycling countries to accurately assess occupational safety and environmental compliance. Transparent, comprehensive evaluations would help the international community recognise progress and identify gaps, encouraging accountability. Third, technical support should be combined with financial aid. Bangladesh benefits from IMO projects like SENSEREC Phase 3, which offers safety training and legislative assistance. However, financial support is also needed to supply safety gear for workers and modern equipment for ship dismantling.

The IMO could establish a fund supported by stakeholders- including ship owners, cash buyers, and industry associations- to ensure the proper disposal of ships in line with international standards. Ultimately, the debate over enforcement delays is unproductive. Bangladesh's ratification signals a commitment to international law, but realising these commitments requires strong administrative capacity, financial investment, and international cooperation. Proper and timely implementation of the Hong Kong Convention will save lives, protect the environment, and help Bangladesh stay competitive in the global ship recycling industry. 

The writer is a PhD research Fellow on Ship Recycling, University of Malaya, Malaysia.