For Marex Media, Ms Delphine Estibeiro engaged in an insightful dialogue with Mr Rohith Agarwal, CEO of Guideship Consulting Services, on the Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships. Their conversation examined India’s long-standing leadership in ship recycling, the paradox of its absence from key IMO registers, and the pressing need for administrative clarity to ensure that India’s global commitments are reflected in practice. With the industry already investing heavily in compliance, the discussion underscored both the achievements made and the urgent steps required to translate intent into effective execution.
Progress and Challenges Under Global Standards…
For several decades, ship recycling has stood as one of India’s most significant industrial achievements, though it has often remained underappreciated in mainstream policy discussions. The yards at Alang have transformed thousands of end-of-life vessels into reusable steel and valuable materials, supporting a vast industrial ecosystem and providing livelihoods to thousands of workers. Over time, the sector has also demonstrated its ability to adapt to increasingly stringent regulatory expectations.
Well before the international community adopted the Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships, many Indian ship recyclers had already begun aligning their operational practices with its principles. This included investments in improved infrastructure, safer handling of hazardous materials, structured Ship Recycling Facility Plans, and stronger occupational safety measures.
India’s decision to accede to the Convention was therefore seen as a natural and progressive step. In fact, India became the first major ship recycling nation to formally accede, a move widely welcomed across the global maritime sector. It was interpreted as a strong signal that India intended to lead the transition toward safer and environmentally responsible ship recycling worldwide.
However, the present situation raises a number of difficult and concerning questions.
India Missing from IMO Ship Recycling Lists…
The concern arises from official documentation published by the International Maritime Organization (IMO).
According to the List of Ship Recycling Facilities Authorized under Article 12.1 of the Hong Kong Convention, there is a notable absence: no ship recycling facility from India appears on the list. This is deeply surprising given that India is one of the world’s largest ship recycling nations and was among the earliest to commit to the Convention.
An equally troubling issue appears in another IMO document—the list of Competent Authorities designated under Article 12.2 of the Convention. In that list as well, India does not appear.
For a country that proudly acceded to the Convention and publicly positioned itself as a leader in responsible ship recycling, the absence from both lists is difficult to reconcile.
Compliance Efforts vs. Authorization Gap…
Over the past decade, many ship recycling facilities in India have undertaken extensive upgrades in anticipation of the Convention’s entry into force. These upgrades involved substantial investments in infrastructure, environmental safeguards, hazardous material management systems, and worker safety protocols. Facilities implemented detailed Ship Recycling Facility Plans and adopted operational practices aligned with the Convention’s requirements.
In other words, the industry itself has made considerable efforts to prepare for compliance.
However, under the Convention framework, ship recycling facilities must obtain a Document of Authorization for Ship Recycling (DASR) from the national authority in order to be formally recognized as authorized facilities. This authorization is then communicated to the International Maritime Organization and included in the official global list.
Without the issuance and notification of DASRs, even compliant facilities cannot appear in the official list.
This suggests that the issue may lie not with the readiness of the industry but with the administrative process required for formal authorization.
Administrative Accountability…
The responsibility for implementing the Convention and establishing the necessary regulatory mechanisms lies with the Ministry of Ports, Shipping and Waterways, along with the authorities designated to oversee ship recycling within the country.
Acceding to an international convention is not simply a diplomatic or symbolic act. It requires the establishment of legal, administrative, and regulatory frameworks that enable the convention’s provisions to be implemented in practice. This includes the designation of competent authorities, issuance of authorization documents, and communication of these details to the International Maritime Organization.
The credibility of a country’s commitment ultimately depends on how effectively the convention is implemented domestically.
Credibility at Stake…
That is precisely where the irony becomes most evident.
India has frequently articulated ambitious plans for the ship recycling sector, including expanding the country’s recycling capacity, becoming the world’s leading destination for ship recycling, and securing inclusion of Indian facilities in the European Union’s list of approved ship recycling yards. These goals are regularly highlighted in policy discussions and industry forums.
However, the same country currently does not appear in the fundamental lists maintained under the Convention by the International Maritime Organization. From an international perspective, this creates an uncomfortable contradiction.
Ship recycling is a global industry where credibility and regulatory certainty play a decisive role in commercial decision-making. Shipowners, insurers, classification societies, and financial institutions carefully examine international compliance frameworks before selecting recycling destinations.
When official records indicate that no Indian facilities are authorized under the Convention, it inevitably raises questions within the international maritime community about the operational status of India’s regulatory framework.
Highlighting Urgency, Not Criticism…
The intention should not be viewed as criticism for its own sake. The objective is to draw attention to an issue that directly affects the credibility of one of India’s most important maritime industries. Silence would only allow the problem to persist, potentially damaging the industry’s international standing.
India’s ship recycling sector has demonstrated its willingness to align with international standards. What appears to be missing at this stage is the administrative urgency required to complete the formal implementation process.
India’s Facilities Ready, But Await Authorization…
The path forward is relatively straightforward. The competent authorities must complete the necessary administrative processes, including issuing Documents of Authorization for Ship Recycling (DASR) to compliant facilities and formally notifying the International Maritime Organization of both the authorized facilities and the designated competent authorities.
Once this process is completed, India’s ship recycling facilities can rightfully appear in the official lists maintained under the Convention.
India has the expertise, infrastructure, and industrial capacity to lead the world in responsible ship recycling. The industry is ready. What is required now is timely administrative action to ensure that India’s commitment to the Convention is reflected in the international record.
Until that happens, one question will continue to linger within the global maritime community: How did the country that led the adoption of the Convention fail to appear in its implementation?
Marex Media