In jurisdictions with limited ship recycling regulations, ship recycling practices can have negative consequences, resulting in environmental damage, occupational health and safety risks, as well as harm to the health of local communities. 

Gard’s position

Shipping is a global business and a uniform practice in terms of ship recycling is essential to level the playing field and reduce the financial incentives to undertake practices that endanger people and the environment.

Although Gard welcomes the EU Ship Recycling Regulation,[1] we believe that the best way to ensure a uniform approach to ship recycling is through international conventions. Gard therefore supports the Basel[2]  and Hong Kong Convention[3] and their underlying principles to manage the environmental and social impacts of ship recycling.

In the absence of an effective global regulation to ensure a consistent approach to sustainable ship recycling, we further support the Ship Recycling Transparency Initiative. Their mission is to accelerate a voluntary market driven approach to responsible ship recycling practices through transparency which will inform decision-making and create fair competition across the shipping industry.

Recommendations for our Members and clients

Gard recommends that our Members and clients take the following actions to reduce potential negative environmental and societal impact:

  • Comply with the Hong Kong Convention. If there is lack of enforcement by a host country, flag state or port state, shipowners are advised to ensure compliance with the convention’s requirements by: 
    • Selecting a yard that has a Statement of Compliance with the Hong Kong Convention or the EU Ship Recycling Regulation.
    • Preparing the ship for recycling in a sustainable way by mapping hazardous materials, arranging the necessary inspections, providing certificates and cleaning and ventilating the ship in accordance with the requirements of the Hong Kong Convention.
    • Avoiding recycling of ships in yards that do not have arrangements for the collection of hazardous and polluting substances.
    • Verifying through a ship specific recycling plan, that the recycling process is responsible, safe and non-polluting.
    • Ensuring that the yard can document that it handles hazardous wastes responsibly. 
  • Follow up the recycling process through inspections, measurements, reporting etc.
  • When selecting a yard, focus particularly on the workforce to ensure that no forced or child labour are engaged.  
  • Assume a high degree of vigilance to secure compliance with the Hong Kong Convention where sales are made to a third party as part of the recycling process.

Gard is committed to 

  • Using our best efforts to ensure compliance with the Hong Kong Convention or EU Ship Recycling Regulation when involved in a Constructive Total Loss (CTL) and/or wreck-removal. 
  • Actively promoting our recommendations through dialogue with Members, clients, the insurance sector and other relevant stakeholders.
  • Not providing separate[4] last-voyage insurance for ships sailing to a recycling facility that does not have a Statement of Compliance with the Hong Kong Convention or EU Ship Recycling Regulation.



[2] on the Control of the Transboundary Movements of Hazardous Wastes and their Disposal:

[3] the Hong Kong International Convention for the Safe and Environmentally sound Recycling of Ships

[4] Separate last-voyage insurance is defined as insurance taken out separate from the ordinary P&I/H&M insurance.