Hong Kong Convention, Nine Months In: India's DASR Race Closes The Paper Gap, Not The Practice Gap

Nine months after the Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships entered into force, the global ship recycling market is running in a two-track mode: a paperwork track where almost every major yard in India now holds a Document of Authorization for Ship Recycling (DASR), and a reality track where NGOs, class societies, and European buyers keep finding the same enforcement gaps they were warning about in 2024.

The Convention became binding on 26 June 2025, 24 months after the entry-into-force conditions were met. From that date, any vessel sent for recycling has to go to a facility with a valid DASR, hold approved IHM Parts I, II and III covering hazardous materials, carry a ship-specific recycling plan, and present a ready-for-recycling certificate on arrival. Flag states and recycling states — not port state control — carry the enforcement load. The IMO maintains the authoritative list of DASR-authorized facilities, populated by submissions from Party States.

On paper, India has moved fastest. The Ministry of Ports, Shipping and Waterways has confirmed well over 100 DASR-authorized ship recycling facilities across Alang and other clusters, the largest national contingent of any Party State. Bangladesh, Pakistan and Turkey — the other three major recycling nations — are all contracting states, and their yards are progressively moving through DASR certification. ClassNK, Lloyd's Register and RINA have scaled audit teams in the sub-continent specifically for HKC surveys.

The paperwork gap is closing. The practice gap is not, at least not evenly. The NGO Shipbreaking Platform, which tracks end-of-life vessel flows yard by yard, continues to report that conditions at several DASR-listed Alang plots fall short of what a plain reading of HKC Annexes on worker safety, hazardous waste handling, and downstream disposal would require. Independent reporting, including Marex Bulletin's March 2026 "Commitment in Spirit, Gaps in Execution" review, has flagged persistent issues: no on-site or near-site hospital capacity for critical incidents, limited hazardous waste disposal infrastructure outside the yard perimeter, and no consistent long-term worker health monitoring. European Waste Shipment Regulation compliance for EU-flagged vessels remains stricter than HKC, and several European owners have continued to route tonnage to the small number of EU-list Turkish yards rather than test the Indian audit trail.

The financial consequence is already visible in the recycling market. HKC has removed an unknown number of yards from the addressable pool for quality-conscious owners, tightening scrap steel competition at the facilities that clearly meet both the letter and spirit of the rules. Scrap prices in Alang and Gadani softened in Q1 2026 as the early rush of HKC-deliverable tonnage cleared, but analysts including GMS and Best Oasis are projecting renewed upward pressure as pre-HKC inventory runs down and the non-compliant tail is squeezed out of the market.

What this means for operators: Owners planning vessel disposals in 2026 and 2027 need two sign-offs, not one. A DASR listing at a chosen yard is the minimum, but it is no longer a reputational shield on its own. Cash-buyer contracts should be stress-tested against independent audits of the specific plot, not the facility cluster; IHM inventories need to survive scrutiny at the scrap quay, not just in the survey file; and flag state compliance letters should be signed before the delivery voyage, not after. For the yards themselves, the message from Q1 2026 scrap pricing is that the market is already sorting them into tiers — and the gap between the top tier and the rest is widening, not narrowing.