AS the global maritime industry moves toward safer and environmentally responsible practices, the Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships, 2009 (Hong Kong Convention or HKC) marks a pivotal shift.
With enforcement scheduled for 26 June 2025, it offers both a challenge and a transformative opportunity—especially for countries like Pakistan, which already house significant ship recycling facilities.
Adopted by the International Maritime Organization (IMO) in 2009, acceded to by Pakistan in 2023, the Convention aims to address the long-standing concerns surrounding unsafe and environmentally hazardous ship recycling practices, particularly concentrated in South Asia. It sets out legally binding standards for the design, operation and dismantling of ships, ensuring that recycling is conducted without endangering workers or damaging the environment.
Ship recycling has long been dominated by a few Asian nations: Bangladesh, India, China and Pakistan. However, lax regulations and weak enforcement have led to unacceptable levels of pollution, workplace casualties and the mishandling of hazardous materials such as asbestos, PCBs, heavy metals and oil residues. The HKC seeks to standardize and enforce global best practices, ensuring ships are responsibly managed from construction to dismantling.
Key requirements under the Convention include: Maintenance of Inventory of Hazardous Materials (IHM) for ships over 500 GT; Authorization of recycling yards by competent national authorities; Development of a Ship Recycling Plan for each vessel; Worker protections, including training, PPE and emergency protocols; Ongoing monitoring of facilities for environmental and safety compliance.
A major shift in the global ship recycling industry occurred when China banned the import of solid waste, including end-of-life ships. Formerly handling nearly 25% of global ship recycling, China’s departure has opened a large gap in the market. This presents a strategic opportunity for Pakistan to position itself as a safe and compliant alternative, particularly through its Gadani Shipbreaking Yard, historically one of the world’s largest. However, Gadani has been plagued in recent years by industrial accidents, fires and environmental violations. Aligning with the HKC is thus not only necessary but also a chance for reform and revival—one that could significantly contribute to Pakistan’s Blue Economy.
The clock is ticking. With the HKC entering into force today, Pakistan, being a party to the Convention, must act urgently to align its national legislation. Failure to do so will render its shipbreaking yards non-compliant, driving away international clients, foreign investment and access to global finance and insurance. A robust national framework should include: A comprehensive Act of Parliament, followed by clear rules and regulations; Empowering the Ministry of Maritime Affairs and Environmental Protection Agencies to oversee implementation; Infrastructure upgrades at shipbreaking yards; Worker training and certification programs for safety and environmental compliance; Transparent licensing, inspection and monitoring mechanisms.
Pakistan doesn’t need to reinvent the wheel. Bangladesh and India are already far ahead. Bangladesh implemented the Safe and Environmentally Sound Ship Recycling (SENSREC) Project in collaboration with the IMO and EU. This multi-phase initiative led to economic and environmental studies, training material development and infrastructure planning for hazardous waste management. India, with support from the Japan International Cooperation Agency (JICA), has modernized many yards at Alang to meet HKC standards and is rapidly upgrading the rest. Pakistan must not lag behind. If others can lead—why not us?
This is not only a defining moment for Pakistan rather this is a make-or-break moment for Pakistan’s ship recycling sector. With China out and others racing ahead, Pakistan has a unique window to capture a significant share of the global market—but only if it acts fast. The HKC is more than just another treaty, it’s a blueprint for sustainable industry. It enables economic growth while safeguarding human lives and the marine environment. For Pakistan, it’s not merely about compliance; it’s about leadership, vision and responsible maritime governance. If Pakistan responds with urgency by legislating, upgrading and training, it can emerge not just as a survivor in the changing maritime economy, but as a global leader in green and responsible ship recycling. Let us not miss this historic tide and a window of opportunity.
—The writer is a practicing advocate in International, maritime and admiralty laws under the name and style ‘LEX-FORA International, Advocates & Solicitors’.
