Ship recycling is a highly specialized industrial activity positioned at the intersection of maritime engineering, environmental management, occupational safety, and international regulatory compliance. End-of-life ships contain large volumes of recoverable steel and equipment, but they also carry significant quantities of hazardous materials such as asbestos, polychlorinated biphenyls (PCBs), heavy metals, ozone-depleting substances, and contaminated operational residues. If not managed through a scientifically planned and regulated process, ship recycling poses serious risks to human health, coastal ecosystems, soil and groundwater quality, and marine biodiversity.
India has emerged as one of the largest ship recycling nations globally, contributing substantially to steel recovery, employment generation, and circular economy objectives. Facilities such as Alang–Sosiya in Gujarat handle a major share of global tonnage. However, the historical practice of ship breaking in India was often characterized by beaching methods, fragmented regulatory oversight, and reliance on environmental guidelines rather than binding technical standards. This created regulatory gaps in hazardous material management, worker protection, and lifecycle accountability of ships.
Historically, ship breaking in India was governed by the Ship Breaking Code, 2013, issued under the Merchant Shipping Act, 1958. While the Code provided basic safety and environmental guidelines, it lacked the statutory strength and international alignment required to address emerging global concerns.
In response to increasing international scrutiny and India’s commitment to global maritime conventions, the Government enacted the Recycling of Ships Act, 2019, thereby providing a dedicated legislative framework for ship recycling. This marked a significant shift from a guideline-based approach to a legally enforceable regulatory regime aligned with international standards.
India is a party to the Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships, 2009, adopted by the International Maritime Organization (IMO). The Convention establishes legally binding requirements for:
The Recycling of Ships Act, 2019, and the subsequent rules and notifications are designed to give full effect to the provisions of the Hong Kong Convention within Indian jurisdiction.
The Recycling of Ships Act, 2019 (Act No. 49 of 2019) is the principal legislation governing ship recycling in India. Enacted in line with the Hong Kong International Convention, 2009, the Act aims to ensure safe, environmentally sound, and regulated ship recycling practices.
The Act provides for the establishment of a National Authority and designation of Competent Authorities to oversee implementation, authorize ship recycling facilities, and monitor compliance. It mandates certification, surveys, and inspections of ships intended for recycling, including the requirement for an Inventory of Hazardous Materials (IHM) to control risks arising from hazardous substances on board.
Ship recycling facilities must obtain formal authorization and comply with prescribed standards relating to infrastructure, occupational health and safety, environmental protection, and waste management. The Act also regulates the handling and disposal of hazardous materials, addressing long-standing concerns related to worker safety and coastal pollution.
To ensure effective compliance, the Act includes enforcement provisions, penalties, and appeal mechanisms. Its scope extends to Indian-flagged ships, foreign ships entering Indian waters for recycling, and all ship recycling facilities in India, reinforcing India’s commitment to responsible and sustainable ship recycling.
In exercise of powers under Section 42 of the Recycling of Ships Act, 2021, the Central Government issued the Draft Recycling of Ships Rules, superseding the Ship Breaking Code, 2013. These Rules provide detailed procedural and technical requirements, including:
The Rules act as the operational backbone of the Act and ensure uniform implementation across all recycling yards
The Recycling of Ships Act, 2019, was notified in the Official Gazette of India following Presidential assent. The notification formally brought the Act into force, replacing the Ship Breaking Code, 2013, and granting statutory authority to regulate ship recycling activities across India.
1. Inventory of Hazardous Materials (IHM): Technical Foundation
The Inventory of Hazardous Materials (IHM) is the most critical technical document in the ship recycling process. It provides a comprehensive, ship-specific identification of hazardous substances present on board, including their location, quantity, and nature.
Technical Scope of IHM
The IHM is structured into three parts:
The hazardous materials listed include asbestos, PCBs, ozone-depleting substances, heavy metals (lead, mercury, cadmium), PFOS, radioactive substances, and restricted anti-fouling systems.
IHM Development Methodology
Only authorized service suppliers, approved by government notification, are permitted to conduct IHM surveys and sampling.
2. Ship Recycling Plan (SRP)
Prior to dismantling, every vessel must have a Ship Recycling Plan (SRP) approved by the Competent Authority. The SRP is a technical control document that defines the step-by-step dismantling sequence, hazardous material removal methods, safe-for-entry and safe-for-hot-work procedures, waste segregation and disposal systems, and emergency response arrangements. The SRP is developed using the IHM as its primary technical input.
3. Surveys and Certification
To ensure technical compliance, ships undergo initial, renewal, additional, and final surveys conducted by the National Authority or Recognized Organizations. These surveys verify the accuracy of the IHM, control of prohibited materials, and readiness for recycling. Successful completion results in the issuance of a Certificate on Inventory of Hazardous Materials and a Ready for Recycling Certificate, which are mandatory for lawful recycling.
The Draft Recycling of Ships Rules represent a substantive shift in the governance of ship recycling in India by embedding technical discipline, legal certainty, and lifecycle accountability into a sector historically governed by fragmented controls. Read together with the Recycling of Ships Act, 2019, the Rules convert India’s international commitments under the Hong Kong Convention into enforceable domestic obligations that directly address the environmental, occupational, and engineering risks inherent in end-of-life vessel dismantling.
By institutionalizing critical technical instruments such as the Inventory of Hazardous Materials and the Ship Recycling Plan, and by linking them with mandatory surveys, certification, and facility authorization, the Rules ensure that hazardous substances are identified, quantified, and managed through a planned and auditable process. This shift from reactive control to preventive regulation significantly reduces risks to workers, coastal ecosystems, and surrounding communities.
Overall, the Draft Rules establish a coherent regulatory architecture that balances industrial viability with environmental protection and worker safety. Their effective enforcement will not only strengthen compliance and transparency within Indian ship recycling yards but will also reinforce India’s credibility as a responsible and sustainable destination for global ship recycling.
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