There are five specific problems related to the recycling of seagoing vessels.

1. Although it is good that ships can be recycled and that almost every part of a vessel can be reused, the way the process occurs in some countries leaves something to be desired. This concerns the safe working conditions of personnel and environment protection measures.
2. The IMO Hong Kong International Convention for the Safe and Environmentally Responsible Recycling of Ships (Hong Kong Convention), which was adopted in 2009, does set acceptable requirements for ship recycling practices. It is the intention that the Convention be applied globally to ship recycling companies and shipowners. However, the Convention has not been ratified by enough countries to enter force.
3. Legislation does exist at the European level, with the European Ship Recycling Regulation 1257/2013 taking effect in 2013. While this has many similarities with the Hong Kong Convention, is not as effective and also does not facilitate a global level playing field.
4. Furthermore, ships flagged under an EU Member State can only be recycled at ship recycling facilities that have been approved by the European Commission. In theory these facilities can be located both inside or outside the EU. In practice, though, none of the as yet 18 approved ship recycling facilities are located outside the EU.
5. The fifth problem involves the complicated application of the European Regulation 1013/2006, relating to shipments of waste (EVOA) and the actual definition of ‘waste’ which a shipowner intends to discard for recycling.

On January 30th, 2019, the NGO Shipbreaking Platform published its 2018 list of vessels recycled worldwide. None of the vessels beached in Southeast Asia sailed the Dutch flag and none of the vessels was registered or owned by a member of the Royal Association of Netherlands Shipowners. Moreover, no Dutch flagged vessel changed flag to a so-called 'flag of convenience' prior to recycling.

First of all, the ship recycling industry and the shipping sector would gain the most from internationally applicable regulations for the safe and environmentally friendly recycling of ships. For this reason, it is of the utmost importance that the Hong Kong Convention is ratified and comes into effect as soon as possible in order to achieve an international level playing field.

Also of great importance is that, in its approval procedures for ship recycling companies, the European Commission should not automatically exclude the ‘beaching’ method from correct recycling standards. The KVNR believes that it is not the location or method, but the actual operational procedures in which the ship recycling process is carried out that determines whether activities are carried out in a safe and environmentally friendly manner. To this end, the ‘beaching’ method does not necessarily have to be classed as a poor ship recycling method.

In accordance with EVOA Article 60, the European Commission must perform an evaluation of EVOA norms by 31 December 2020 and, if necessary, make proposals for legislative changes. It is important that the EVOA be amended so that it no longer applies to ships that are going to be recycled, and that this is explicitly defined in the EVOA itself.

This is of particular interest because, since 2013, there has been a specific European ship recycling regulation 1257/2013 in effect, which clearly states that the EVOA is no longer applicable on vessels subject to the European Ship Recycling Regulations.

The Netherlands has ratified the Hong Kong Convention on February 20th, 2019. In total fifteen countries have now ratified the convention. Entering into force of the convention now requires more countries to follow soon.