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1 INTRODUCTION
All stakeholders in the maritime industry are actively
working to enhance the sustainability of shipping.
Reducing the negative impact of ship emissions on
human health and the environment throughout their
entire life cycle is only possible through the prohibition
and strict control of harmful materials used in ships
[17]. It is one of the main objectives of the two
regulatory instruments: the International Convention
for the Safe and Environmentally Sound Recycling of
Ships (HKC) and the EU Ship Recycling Regulation
(EU SRR). Although the HKC was adopted in 2009, its
entry into force has been slow, with the
implementation date set for 26 June 2025 [6]. To
promote better recycling practices and speed up the
adoption of the Convention, the EU Ship Recycling
Regulation (EU SRR) was introduced in 2013 and came
into effect on 31 December 2014.
The responsible design, construction, maintenance,
and recycling of ships are ensured by prohibiting or
restricting the use of materials listed in Appendix 1 of
the HKC (asbestos, ozone-depleting substances,
polychlorinated biphenyls, and anti-fouling
compounds and systems) and Annex I of the EU SRR,
which includes the same materials as Appendix 1, plus
perfluorooctane sulfonic acid [19]. Additionally, both
the HKC and EU SRR require the identification of the
type, quantity, and location of materials listed in
Appendix 2 (HKC)/Annex II (EU SRR), which includes
cadmium and its compounds, hexavalent chromium
and its compounds, lead and its compounds, mercury
and its compounds, polybrominated biphenyls,
polybrominated diphenyl ethers (PBDEs),
Ship Recycling as a Source of Mercury Pollution:
Is There a Need for Regulatory Change?
J. Čulin, J. Orović, V. Knežević & Z. Pavin
University of Zadar, Zadar, Croatia
ABSTRACT: The Minamata Convention on Mercury was established to combat the profound global threat posed
by mercury and its compounds, which exhibit persistent environmental contamination, bioaccumulation, and
long-range atmospheric transport, leading to severe ecological and human health consequences, particularly for
vulnerable populations in developing nations. In contrast, the International Convention for the Safe and
Environmentally Sound Recycling of Ships (HKC) and the EU Ship Recycling Regulation (EU SRR) permit the
use of mercury onboard ships. Furthermore, the current listing in Appendix 2/Annex II of these regulations allows
the recycling of existing ships without requiring specific data on the location and quantity of mercury, potentially
leading to unintentional environmental releases. This paper analyses data on mercury environmental
contamination by ship recycling activities. Considering the projected increase in ship recycling activities in South
Asia, there is a significant risk of escalating mercury emissions. Therefore, we recommend that relevant
authorities conduct a thorough assessment of the regulatory status of mercury under the HKC and EU SRR to
ensure consistency with the Minamata Convention and to mitigate further environmental and health risks.
http://www.transnav.eu
the International Journal
on Marine Navigation
and Safety of Sea Transportation
Volume 20
Number 1
March 2026
DOI: 10.12716/1001.20.01.15
148
polychlorinated naphthalenes (with more than three
chlorine atoms), (PCNs), radioactive substances, and
certain short-chain chlorinated paraffins (SCCPs).
Annex II of the EU SRR includes the same materials as
Appendix 2, with the addition of brominated flame
retardant HBCDD.
Both instruments allow for possible modifications
to the lists of hazardous materials due to various
factors, including new scientific findings, emerging
chemicals, regulatory updates and technological
advances. In doing so, Annexes I and II of the EU SRR
must include at least the substances already listed in
Appendices I and II of the HKC. Until now, only one
change has been made to Appendix /Annex 1, driven
by amendments to Annex 1 of the 2001 International
Convention on the Control of Harmful Anti-Fouling
Systems on Ships (AFS Convention), which introduced
restrictions on cybutryne and came into force on
January 1, 2023.
However, since the inclusion of hazardous
materials in the lists of the HKC in 2009 and the EU SRR
in 2013, the increasing understanding of chemical risks
and the global commitment to reducing or eliminating
substances that pose significant threats to health and
the environment have led to substantial changes within
the international framework. The Stockholm
Convention on Persistent Organic Pollutants
mandated a production ban for hexabromobiphenyl,
PBDEs, PCNs, and SCCPs, while their use was subject
to either a ban or restrictions [7].
Furthermore, a significant development regarding
mercury and its compounds occurred following years
of extensive discussions and negotiations. The
Minamata Convention on Mercury was adopted by
over 140 countries in October 2013 [21]. The Minamata
Convention entered into force in August 2017 and
currently has 152 parties. The European Union adopted
Regulation (EU) 2017/852 to align its policies with this
global framework in May 2017. In June 2024,
Regulation (EU) 2024/1849 was adopted to restrict the
remaining usage of mercury further [18].
Given these developments, it is essential to assess
whether adjustments are needed regarding the status
of mercury and its compounds in both the HKC and
the EU SRR to ensure consistency with relevant global
instruments. This paper seeks to evaluate the
implications of mercury's current status within these
frameworks, particularly in light of prevailing ship
dismantling practices, and to propose potential
changes aimed at reducing risks to human health and
environmental quality.
2 ENVIRONMENTAL CONTAMINATION BY
MERCURY FROM SHIP DISMANTLING
The long-standing practice of ship dismantling for
recycling has generated substantial environmental
pollution, primarily due to the widespread use of the
unsustainable open beaching method. Improper
practices and inadequate waste management lead to
uncontrolled emissions of many hazardous materials,
including metal/loids [12]. Oceanic brine, landmass
substrates, settled detritus, and underground water
reserves within the shipbreaking zones of India,
Pakistan, and Bangladesh, regions where the majority
of ships are dismantled, are heavily contaminated with
significant quantities of toxic metal/loids [8]. These
pollutants, through bioaccumulation and
biomagnification, present a potential hazard to both
fauna and human populations. Among them, mercury,
identified by the World Health Organization in 2020 as
one of ten chemicals of public health concern, is
particularly problematic [2].
Mercury, a global pollutant from natural and
anthropogenic sources, persists in the environment,
circulating through air, soil, water, and biota.
Mercury's health effects vary significantly depending
on whether exposure is to methylmercury (organic),
elemental (metallic), or inorganic mercury compounds
and on the dose and duration of exposure [1].
Generally, mercury acts as a neurotoxin, potentially
damaging the nervous system, kidneys, and lungs.
Methylmercury (MeHg), primarily from contaminated
seafood, poses the greatest risk, particularly to
developing brains, causing neurological and
developmental issues. Elemental mercury, inhaled as
vapor, can induce tremors, emotional changes, and
respiratory problems. Inorganic mercury, ingested or
absorbed through the skin, can lead to kidney and
gastrointestinal damage. All forms can cause
neurological issues, but MeHg is the most concerning.
For example, over 10,000 individuals in China are
estimated to die annually from heart attacks caused by
MeHg [23]. Furthermore, the developmental impact of
MeHg on cognitive function in the USA and EU is
associated with economic costs reaching $16 billion.
On board vessels, mercury and mercury
compounds may be found in a range of products,
including fluorescent lights, mercury lamps, mercury
cells, liquid-level switches, gyro compasses,
thermometers, measuring tools, manganese cells,
pressure sensors, light fittings, electrical switches, and
fire detectors. Mercury quantities per million gross
tonnage were estimated within a 2010 World Bank
report to be 75 kg for navy vessels and 44 kg for
merchant vessels [20].
This highlights a significant risk of environmental
contamination in these regions. In 2022, 2023, and 2024,
the GT of ships dismantled in South Asia was 6,583,121,
6,524,244 and 6,583,121, respectively [15]. Using an
estimated 44 kg of mercury per million GT, this
corresponds to approximately 0.78 tonnes of mercury
(Table 1).
Table 1. Estimated mercury content (in tonnes) in ships
dismantled in South Asia from 2022 to 2024, calculated
using GT data [15] and a mercury factor of 44 kg per million
GT [20].
Country
2023
2024
Bangladesh
0.14
0.11
India
0.11
0.06
Pakistan
0.03
0.03
Total
0.29
0.20
The release of mercury into the environment during
ship recycling is a complex issue with multiple
contributing factors. Firstly, mercury-containing items,
when damaged or improperly disposed of, directly
release mercury. Secondly, the process of steel cutting
can liberate organic mercury from older anti-fouling
paints, which were used as biocides. For example,
preliminary analysis of paint samples from a UK-
recycled passenger ferry, subjected to oxy-fuel torch
149
cutting, revealed mercury concentrations between 0.14
and 2.52 mg/kg [5]. Thirdly, ballast water, particularly
in tankers servicing oil and gas fields, can become
enriched with mercury due to its adherence to the steel
hull.
However, data regarding the actual quantities of
mercury released during shipbreaking operations is
unavailable [10]. Moreover, the literature regarding
mercury concentrations in shipbreaking regions is
sparse. Despite the absence of reliable quantitative data
regarding mercury releases into local ecosystems from
ship beaching and the limited number of studies
comparing the adverse effects of ship recycling with
other poorly regulated industrial activities, the
significant pollution levels observed in shipyard
locations provide valuable indicative evidence [16].
The research performed in Pakistan measured total
Hg and MeHg concentrations in surface sediments
from the Gadani ship recycling area and a local
reference area. The highest total Hg and MeHg
concentrations were found in samples from the beach
at the yard zone, followed by sediment samples from
the inter/sub-tidal zone where ships are dismantled.
These concentrations were significantly (3–50 times)
higher than those observed in the reference area [10].
Similarly, mercury concentrations in sediment
samples from Aliağa Bay, a ship recycling zone in
Turkey, were higher than average shale and
Mediterranean background levels [14]. More
concerning, Hg levels exceeded the probable effect
level (PEL), indicating a high probability of adverse
effects on marine life.
The negative impact of elevated levels of Hg due to
shipbreaking extends to human populations. A study
investigating metal/loid exposure among residents
working and/or living in proximity to a major open-
beaching shipbreaking yard in Bangladesh reported
elevated urinary mercury (Hg) levels [9]. Urinary Hg is
recognised as a valuable biomarker for kidney
dysfunction, and the findings indicate that
environmental exposure to mercury may pose a health
risk.
3 POTENTIAL CONSEQUENCES OF THE
CURRENT LISTING OF MERCURY
The HKC and EU SRR requirements apply to new and
existing ships. For new ships, a current listing of
mercury and mercury compounds in Appendix
2/Annex II permits their use. Their location and
quantity must be documented in Part I of the Inventory
of Hazardous Materials (IHM), developed during the
design and construction stage. However, the
manufacture, import, and export of mercury-added
products that could be used on ships are banned under
the Minamata Convention and (EU) 2017/852 and (EU)
2024/1849. The phase-out deadline for most of these
products is 2025, with exceptions for certain types of
fluorescent lamps, which have phase-out dates in 2026
or 2027. Additionally, mercury-free alternatives are
available. Therefore, it is highly unlikely that new ships
will contain mercury. Namely, a comparison of data
from the 2024 Review of maritime transport and the list
of parties of the Minamata Convention reveals that
from 35 leading flag states and 35 countries of ship
ownership all are parties of the Minamata Convention
except Russian Federation and Malaysia that have
signed it but not ratified it yet and Bermuda, which has
neither signed nor ratified it.
Therefore, the risk of future mercury emissions
stems from requirements related to existing ships.
Notably, for existing ships, the IHM must be
established within five years of the regulation’s
enforcement or before the ship undergoes recycling,
whichever occurs first. However, materials listed in
Appendix 2/Annex II do not have to be included in Part
I of the IHM. Consequently, existing ships may
proceed to recycling without detailed information on
the location and quantity of mercury, potentially
leading to unintended environmental contamination.
The current fleet presents a significant downstream
issue regarding their eventual decommissioning. As
pointed out in the 2024 Review of Maritime Transport
by the United Nations Conference on Trade and
Development at the start of 2024, the average age of the
global fleet was 12.5 years by deadweight tonnage and
22.4 years by vessel count. Around 40 % of existing
ships were built more than 20 years ago [22]. Ship
demolition remained low throughout 2023 and the first
half of 2024 as high freight rates and shipping route
disruptions incentivised the continued use of older
vessels. Uncertainty surrounding future regulations
and low-carbon technologies further discouraged ship
demolition. However, in 2023, the maritime industry
faced a surge in climate regulations, with the EU's
Emissions Trading System implementation, the IMO's
Energy Efficiency Existing Ship Index and Carbon
Intensity Indicator compliance requirements, and the
adoption of an ambitious 2050 net-zero emissions
strategy. Therefore, it is anticipated that ship
demolition will rise in the coming years.
In line with this expectation, a February 2025
Commission report to the Council and the European
Parliament evaluating the EU Ship Recycling
Regulation (EU SRR) (the Report) projects future
volumes of dismantled ships covered by the Hong
Kong Convention [3]. The projections, which predict
recycling based on ship age, indicate a significantly
higher recycling rate than current trends. As stated in
the Report, this suggests a growing backlog of ships
awaiting recycling, likely driven by strong capacity
demand. Consequently, the average age of ships
recycled may rise. When demand falls and shipping
rates decline, recycling facilities could face a surge in
ships from an ageing, potentially unprofitable fleet.
Non-South Asian ship recycling facilities are
projected to maintain a small market share. In 2022,
2023, and 2024, Bangladesh, India, and Pakistan
received 83%, 85%, and 80% of decommissioned ship
tonnage (GT), respectively [15]. This trend is likely to
continue due to economic reasons. Ship dismantling
provides valuable recyclable materials essential for
various industries, with the steel extracted from end-
of-life ships being a key resource in Bangladesh and
Pakistan. Additionally, the shipbreaking industry
creates significant employment opportunities,
attracting countries to import large numbers of end-of-
life ships to generate revenue and create jobs.
Compared to other ship dismantling methods, the
open-beached method reduces costs in labor,
operations, infrastructure, and hazardous material
150
handling. Therefore, non-standard shipbreaking yards
in South Asia often offer higher prices for these ships
than other regions, making them attractive to
shipowners seeking higher profits while avoiding
regulatory compliance costs. Throughout 2014 to 2023,
the financial offers from ship recycling yards utilising
the beaching technique were consistently 30% to 90%
greater than those provided by recycling yards located
in Turkey [3]. Moreover, there is a worldwide shortage
of ship recycling facilities that meet regulatory
standards [13].
The EU SRR allows recycling EU-flagged ships only
at facilities listed on the EU List of ship recycling
facilities. As of February 2025, 43 facilities (31 in
Europe, 11 in Turkey, and 1 in the United States)
operate following human health and environmental
protection standards required by the EU SRR [3].
Unlike HKC, the EU SRR includes the requirements to
operate on built structures (prohibits beaching) and to
document the quantities of removed hazardous waste.
However, the EU SRR has proven largely ineffective
[11]. Flag-switching by ship owners undermines its
jurisdiction, failing to prevent the transfer of polluting
end-of-life vessels from the EU to developing nations.
The anticipated increase in recycling activity in
Bangladesh, India, and Pakistan has implications for
the potential release of mercury from dismantled ships.
Based on a reported average of 44 kg of mercury per
million GT, the estimated total mercury content in
ships projected to be dismantled in South Asia until
2030 could reach 15.02 tonnes, as detailed in Column 1
of Table 2. However, to account for the possibility of
continued lower recycling rates observed in recent
years, an adjustment was applied to the initial
projection using the ratio of actual GT dismantled in
2024 to the literature-projected GT for the same year.
The resulting estimated mercury content, presented in
Column 2 of Table 2, remains substantial.
Table 2. Projected future mass of mercury (in tonnes) in
ships dismantled in South Asia from 2025 to 2030.
Year
Projected Mercury
Content a
Adjusted Projected
Mercury Content b
2025
2.19
0.26
2026
2.26
0.27
2027
2.38
0.29
2028
2.54
0.31
2029
2.73
0.33
2030
2.91
0.35
Total
15.02
3.60
a) Based on literature-projected dismantling volumes [3] and a
mercury factor of 44 kg per million GT [20]
b) Adjusted using the ratio of actual GT dismantled in 2024 to
projected values for the same year
This is concerning given that despite the ratification
of the HKC by Bangladesh, India, and Pakistan, the
ship recycling industry in South Asia continues to
encounter significant challenges in implementing safe
and environmentally responsible practices. These
difficulties are evident even in HKC-compliant yards,
where accidents and hazardous working conditions
persist, raising concerns about the effectiveness of
enforcement and oversight. Furthermore, a significant
number of ship recycling facilities in South Asia have
not sought inclusion in the European List, which sets
higher environmental and safety standards for ship
dismantling operations. Notably, no ship recycling
facilities in Bangladesh or Pakistan have submitted
applications for inclusion in the European List,
underscoring the gap between international regulatory
frameworks and on-the-ground implementation in
these regions [3]. This ongoing disparity raises serious
concerns that mercury emissions during ship
dismantling will continue to exacerbate existing
environmental contamination, which is already
burdened by industrial pollutants and inadequate
waste management. Additionally, the uncontrolled
sale of mercury-containing components salvaged from
dismantled ships in local markets poses a considerable
risk. These items often end up in general circulation,
eventually leading to improper disposal in landfills or
open dumps, thereby releasing mercury into the
environment and further contaminating soil and water
resources.
The inclusion of mercury in Appendix 1/Annex I
could provide a more structured approach to its
management in ship recycling. Such a classification
would ensure that all relevant stakeholders were
informed about the presence, location, and quantity of
mercury-containing materials. This documentation
would enhance awareness and facilitate the
implementation of appropriate safety measures during
the recycling process. If a detailed inventory were
available, ship recycling workers would be better
equipped to apply necessary protective measures, such
as using personal protective equipment, following
designated handling procedures, and adopting
controlled dismantling techniques. Additionally, a
comprehensive inventory aids in designing and
implementing waste management strategies by
enabling the segregation and secure storage of
mercury-contaminated materials, thereby reducing the
risk of environmental dispersion. This approach also
allows for the application of suitable disposal methods,
such as specialised incineration or stabilisation
techniques, which help minimise mercury emissions. If
these measures were implemented, the structured
handling and disposal of mercury-containing materials
would contribute to worker safety and reduce
environmental impact while aligning with the broader
objectives of the Minamata Convention on Mercury. By
ensuring that standardised procedures and responsible
recycling practices are executed, the HKC and EU SRR
could support global efforts to mitigate mercury
pollution and its associated risks to human health and
ecosystems. Such a harmonised approach would help
ensure that progress made in reducing mercury
contamination was not undermined by uncontrolled
releases from end-of-life vessels.
4 CONCLUSIONS
Research indicates that mercury emissions occur
during ship recycling in South Asia, exacerbating an
environment already burdened by heavy metal
pollution. Given the continued dominance of the
beaching method, these emissions are likely to persist.
However, this risk could be mitigated by amending the
HKC and the EU SRR to prohibit mercury and its
compounds. Such measures would ensure the
identification of mercury sources on board and enable
proper treatment during recycling. Additionally,
aligning these regulations with the Minamata
Convention on Mercury would support its objective of
151
protecting human health and the environment from
mercury emissions. Therefore, we recommend that
relevant authorities initiate the process of proposing
amendments to assess the benefits and costs of such a
measure.
Given that the list of hazardous materials has
remained largely unchanged (apart from the addition
of cybutryne) for 16 years under the HKC and 12 years
under the EU SRR, a reassessment of its relevance and
potential updates may be warranted. Over this period,
considerable advancements have been made in
understanding the impacts of other hazardous
materials that may be found onboard ships in relevant
quantities. Future research could explore whether
revisions are necessary to reflect these new insights
and ensure that the list remains aligned with the latest
scientific findings and relevant international
conventions.
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