Report : Post-HKC Implementation, Alang-Sosiya Preparing for Growth
Ahead of the Basel Convention's 15th Open Ended Working Group meeting in Geneva this June, SSI published a policy note addressing the long running governance gap between the Hong Kong Convention (HKC) and the Basel Convention, a gap that has stalled responsible investment in ship recycling since 2011.
The note is grounded in SSI's 2026 field research at a leading HKC-certified facility in Alang-Sosiya, the first independent operational assessment of its kind at a certified South Asian facility. That research confirms the HKC has established a genuine safety floor, with stage-specific risk controls, a decades-deep supervisory knowledge base, and material investment in physical infrastructure all functioning under real working conditions. Our position: the governance impasse that has deferred resolution since COP10 in 2011 can no longer be justified on evidentiary grounds.
SSI's ask to OEWG-15 was for coordinated engagement with the IMO's experience-building phase, rather than asking COP18 to resolve the HKC-Basel relationship cold. That should cover three things: recognising IMO as the central technical authority on HKC-related work, using flag state supervision and port state control as the compliance architecture, and addressing downstream material traceability, the one area where SSI's research found Basel's continuing jurisdiction most legitimate and most practically constructive. Hazardous materials currently move through a complex downstream chain of segregators, secondary processors and waste handlers with no manifest attached, a gap that affects the roughly 40,000 workers, many of them women, working beyond the yard gate.
We also called on the European Commission to use its position as a Basel party to advance this technical evaluation, given the tension between its own Industrial Maritime Strategy naming India as a transition partner and the continued exclusion of every Indian facility from the EU Ship Recycling Regulation list.
This work was supported by the Lloyd's Register Foundation and led by Maria Joseph, SSI's Ship Recycling Lead.
