Ship Recycling as a Source of Mercury Pollution: Is There a Need for Regulatory Change?

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.