Ship Recycling Compliance: Hong Kong, Basel and EU Questions for Owners

A vessel disposal project can involve maritime rules, waste-movement controls and local facility permissions at the same time. Owners searching for Hong Kong Convention, Basel Convention or EU-compliant services need a vessel-specific assessment rather than a generic assurance. Wigmore Trading can help scope sourcing and procurement requirements, with legal opinions, surveys, certification and specialist compliance work assigned to appropriately qualified parties.

Map the vessel, movement and destination

Record the ship’s identity, flag, ownership, current location, intended destination, condition and disposal intention. Establish who is authorised to make decisions. Ask qualified advisers to determine which requirements apply and when approvals or notifications are needed. A general checklist is an organisational aid; it cannot determine a ship’s legal status or authorise its departure.

Hong Kong Convention: request the right evidence

The Hong Kong Convention entered into force on 26 June 2025. Its framework includes ship-specific hazardous-material inventories, surveys, certification and a ship-recycling plan. Confirm the applicable requirements with the flag administration and competent advisers. A supplier’s statement that it follows IMO principles is not itself the required evidence for your ship or receiving facility.

Basel Convention and the waste question

The Basel Convention’s ship-dismantling overview explains that ships destined for dismantling can represent a transboundary movement of hazardous waste. Ask advisers to assess origin, transit and destination controls before movement. A commercial sale contract, a seaworthy condition or a change of flag should not be treated as automatically resolving the waste-law question.

EU requirements and named facilities

The European Commission’s ship-recycling guidance explains the European List and relevant ship and facility requirements. Where that regime applies, verify the named facility’s current listing and conditions. “European compliant”, “green” and “OECD compliant yard” are not interchangeable approvals. A country’s OECD status does not certify every facility located there.

Do not collapse different regimes into one certificate

Ask the adviser to identify which rule is being satisfied by each document. The Commission’s waste-shipment information describes controls that depend on waste type, destination and timing. Applicability and transition questions need current professional review. Neither a facility certificate nor a recycling-plan document should be assumed to settle every export, transit or import requirement.

Use independent review before committing

Keep unresolved conditions visible in the tender and contract process. Ask who is responsible for each approval, what happens if it is refused and whether payment or mobilisation depends on it. Preserve the evidence used in selection. ISO certification can support a particular management-system claim, but its scope, issuer and validity need checking and it does not replace statutory permissions.

Build a compliance-support enquiry with Wigmore

Send a redacted vessel summary, location, flag, proposed destination and the work your advisers have already defined. Tell us whether you need provider research, a documented quotation comparison or logistics planning. We can clarify available support and specialist dependencies. This page offers procurement guidance, not a legal opinion, a compliance certificate or a promise that a route or facility is approved.