Multiple, diverging, standards are not helpful for a global industry like shipping. Nor, indeed, are they generally good for society either.
A new case study and analysis, commissioned by the International Chamber of Shipping and the European Shipowners Association supports the need for single standards.
There are key areas of divergence between the EU Ship Recycling Regulation (EU SRR) and the International Maritime Organization’s Hong Kong Convention (HKC), the study demonstrates.
Key findings
Authorisation of ship recycling
EU – applicants for EU authorisation from outside of Europe must get an independent certification that they meet the EU rules, then must apply to the European Commission to show how the rules are met. Facilities are then subject to a technical assessment and inspection. Specific technical guidelines must be met.
IMO HKC – a mechanism must be set up for authorising ship recycling facilities to ensure the requirements of the Convention are met, which includes inspection, monitoring and enforcement. Individual countries determine the exact mechanism and do not have to share it with the IMO. Accordingly, there is no standard approach.
Legal text
There are differences in the legal texts. The EU SRR sets more specific requirements on waste leakage and waste management. The IMO HKC requires wastes to be transferred to an authorised management facility, as defined by the relevant jurisdiction.
There are differences in specific transparency requirements, such as information about the method of recycling used at authorised facilities.
The EU SRR also provides a much more direct mechanism for stakeholders to raise concerns about possible breaches compared with the IMO HKC; the IMO was (at the time of the study) still developing means of information dissemination.
Consequences
The authors of the study argue that the IMO HKC has the advantage of applying across a “far wider” scope, covering more ships and ship recycling facilities. “The broader reach is a major strength, as it increases the potential impact of stronger social, human and environmental protection,” the authors write.
However, in balance, they add that the HKC’s more flexible and less specific requirements offer less protection against uneven implementation. They argue making the HKC more specific and consistent could better ensure safe and environmentally sound ship recycling.
Context
Ships are complex objects, and dismantling them can generate a variety of environmental, safety and health hazards. Both the EU and the IMO have adopted rules in the sector, and, of particular importance, is that the EU SRR was based on the HKC.
In 2013 the EU adopted the EU SRR, which has been applicable since 31 December 2018. The IMO Hong Kong Convention (HKC) was adopted in 2009 and entered into force on 26 June 2025.
Same problem in Australia
Australia has a similar problem. Australia has thousands of industrial standards and there are potential annual savings worth billions of dollars from simplification and harmonisation, the Productivity Commission has found.
In the Productivity Commission’s Interim Report (2025), it was reported that there are 7,519 Australian standards, of which 893 are incorporated in legislation. Of the Incorporated Standards, only 22% are identical to international standards. The rest are either modified, not based on an international standard, or have no equivalent international standard.
The Productivity Commission found that aligning domestic and international standards promotes trade, although the magnitude of effects will vary. Higher trade volumes increase product diversity, lifts consumer welfare, and national income.
Even a small alignment, of about 190 Australian standards, could produce a total benefit of AUD$1.9 billion to AUD$3.8 billion a year, although further research is needed.
(For more information on the Australian context, see the discussion in Wilson, J. (2025). Billions could be saved by harmonising standards across Australia, Productivity Commission says. Shipping Australia. https://www.shippingaustralia.com.au/billions-could-be-saved-by-harmonising-standards-across-australia-productivity-commission-says/).
Shipping Australia comments
Shipping Australia is keen to make the point that we are not saying that the EU SRR is actually better than the IMO HKC, or that the IMO HKC is better than the EU SRR.
The point, the key point, is that there should be one standard.
Having more than one standard to comply with causes confusion and costs time, effort, and money. The Productivity Commission report clearly demonstrates that.
From an institutional viewpoint, it therefore follows that if there is to be one set of rules then there should be one regulator. Shipping Australia’s longstanding position is that international shipping is best regulated by the IMO because it creates global rules, which is essential for a global industry.
But, look, this is not just us being policy-nerds, econo-nerds, or law-nerds, although of course we are all of those things.
This is about us being opposed to unnecessary administrative duplication, which is really bad for all of us.
Unnecessary, unwanted, unethical
Unnecessary bureaucracy which causes unnecessary expenditure is ethically bad because it wastes scarce resources that could have otherwise been saved for use on better things.
Incidentally, we’re not attacking the officials in what we’re about to say next. Officials get a lot of criticism, especially from business, but we would like to emphasise that they are generally decent people who work hard and who believe in delivering a better society for all of us. It’s the policy design we are criticising, not the people.
Public agencies have a moral duty of stewardship i.e. not to squander taxpayer money (or to cause other people to squander their money) and, accordingly, it’s not ethical for government policy to force public bodies to squander taxpayer money.
From a procedural ethics viewpoint, rules need legitimacy, which means, in part, rules should serve some kind of reasonable purpose. Forcing the public to waste their money through complying with overly burdensome or duplicated standards is not defensible.
Such burdens are not cheap. They are not necessary. They are not wanted. They are not ethical.
Life is short. Work is hard.
Your time on this amazing Earth is limited.
Your time is scarce, valuable, and expensive.
You shouldn’t be using it to fill in pointless forms.
