DNV issues guidance to help navigate sustainability regulations

(Posted on 13/02/25)

With the Hong Kong Convention (HKC) set to take effect this year, shipowners should ensure compliance with regulatory controls and inspections governing ship recycling for their vessels. DNV’s latest guidance paper “Safe and Green Recycling for Ship Owners” outlines how they can work in line with both existing EU Ship Recycling Regulations (EU SRR) and the HKC, coming into effect on 26 June, 2025.

The ship recycling process is a key contributor to a circular economy where materials and components may be reused or recycled. However it needs careful planning for safe execution. Ships often contain hazardous materials that can pose significant risks to workers' health, safety, and the environment if not managed properly. To mitigate these risks, shipowners must adopt a carefully planned strategy for responsibly handling the end of life of their vessels.

With thousands of ships expected to require recycling over the next decade, the International Maritime Organization’s (IMO) Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships (HKC) is an important step towards safer and more sustainable ship recycling.

Knut Ørbeck-Nilssen, CEO of DNV Maritime, stated: “As the maritime industry faces increasing pressure to adopt sustainable practices, it is essential for shipowners to fully understand the scope of regulations established by the EU and IMO. The primary focus of these regulations is to enhance the health and safety of workers while protecting the environment from pollution and the release of hazardous materials. The DNV guidance helps shipowners understand the regulatory landscape and make informed decisions on the recycling of vessels.”

In the EU, the Ship Recycling Regulation No. 1257/2013 (EU SRR) was implemented back in 2013, focusing mostly on safe waste management and sustainable ship recycling – it applies to all EU flagged ships. The HKC comes into effect in 2025, with compliance required by 2030, and applies to HKC ships* equal or above 500 gross tonnages (GT). It takes a global approach that brings social values into focus by implementing the UN’s human rights principles. DNV’s new guidance “Safe and green ship recycling for shipowners” details the regulatory landscape and the various recycling options to give shipowners a better basis for making decision on the recycling of their vessels.

Twenty-four countries and the four largest recycling nations by tonnage - India, Bangladesh, Pakistan, and Turkey - have ratified the HKC. Ships that need to comply must have an Inventory of Hazardous Materials (IHM) for Parts I along with an onboard survey before being issued an International IHM Certificate. Update to the IHM (part II and III) and a final survey are required before a Ready for Recycling Certificate (IRRC) can be issued. The ship should be sent for recycling at a facility that holds a Document of Authorization for Ship Recycling (DASR) from its authority.

Tone Knudsen Fiskeseth, Principal Consultant, said: “While undertaking inspections for the European Commission across several countries, we noted promising improvements in worker’s safety, environmental protection, IHM reporting, and hazardous materials handling.

With the HKC taking effect in 2025, shipowners need to understand how to comply and navigate a complex regulatory landscape that also includes the Basel Convention and the EU SRR. Adhering to the HKC regulations and Basel guidelines on waste management supports a sustainable, circular economy while EU’s waste directives mandates/push for further improvement to minimize environmental impact.

“It will be interesting to follow the technology innovations within ship dismantling and how they will impact on safety, capacity issues and sustainable recycling,” she added.

To assist shipowners in navigating the complex regulatory environment, DNV also offers a range of comprehensive services. These include approval and certification of Inventory of Hazardous Materials (IHM), class support to owners and advisory support to the European Commission on inspection of ship recycling facilities.