Reassessing the Tide: A Critical Analysis of UAE's Ship Recycling Regulation and Its Global Sustainability Implications

19 Dec 2023
Author: Dr. Anand Hiremath

The United Arab Emirates' introduction of a new Ship Recycling Regulation (SRR) heralds a significant shift in maritime environmental practices. This regulation, banning the traditional beaching and landing methods of ship recycling, aims to elevate environmental standards in the industry. However, it raises critical questions about its pragmatic approach and potential unintended consequences on global sustainability, particularly concerning the robust ship recycling practices in India. The UAE's new Ship Recycling Regulation (SRR) brings a transformative approach to the industry, potentially increasing the number of UAE-flagged ships and impacting the global maritime sector.

The Critical Role of Ship Recycling in Environmental Sustainability


More than 95% of end-of-life ships currently rely on landing and beaching methods for recycling. These methods are integral to the global ship recycling industry. They enable the recycling of over 97% of a ship, including steel, non-ferrous metals, and other materials. This high rate of recycling plays a significant role in environmental sustainability by reducing the need for new material production and minimizing associated greenhouse gas emissions.

Indian Ship Recycling: A Model of Efficiency and Sustainability


India stands as the world's largest green ship recycling country, with more than 110 HKC-compliant yards. The Indian approach to ship recycling is not just about dismantling; it's a comprehensive process of reusing, recycling, refurbishing, and upcycling, turning what was once considered waste into valuable resources. This not only offers the highest residual value to ship owners but also significantly contributes to global decarbonization efforts.

Analyzing the Practical Implications of the UAE's Ship Recycling Regulation

  1. Global Dependence on Beaching and Landing Methods: The majority of the world's ship recycling happens via beaching and landing. The shift mandated by the UAE's SRR could significantly disrupt this global dependence, leading to a reduction in recycling capacity and increased costs. Under the UAE SRR, ship owners unable to secure a slot at a compliant yard have the option to transfer ownership to a UAE entity. This provision could lead to a significant increase in UAE-flagged ships. Additionally, with most drydocks already booked until 2025 due to the demand for energy-efficient refurbishments, this regulation might strain the already limited recycling capacity.

  2. Variability in Recycling Practices: The effectiveness and environmental impact of ship recycling vary widely. The new UAE regulation might not adequately address this variability. While it bans beaching and landing, these methods are not inherently unsustainable. The quality of recycling practices is more dependent on the management and operation of the yards rather than the method itself.

  3. Impact on the UAE's Maritime Industry: The regulation could deter ships from entering UAE waters, impacting essential services like bunkering and ship repair. This avoidance could lead to a decrease in maritime traffic in UAE ports, affecting the local economy and potentially leading to a loss in business opportunities.

  4. Wider Implications for Global Sustainability: By potentially pushing the industry towards alternatives the regulation may inadvertently negate the sustainability benefits achieved by efficient recycling practices.

The UAE's SRR notably incorporates the Inventory of Hazardous Materials (IHM) requirement, a significant step towards enhancing maritime environmental safety. This inclusion ensures comprehensive documentation and management of hazardous substances on ships, aligning with global best practices in ship recycling. The IHM's role is pivotal in promoting not just regulatory compliance but also in safeguarding the health of workers and the marine environment, reflecting the UAE's commitment to a more environmentally conscious and responsible maritime industry.

Potential Economic and Environmental Impacts


The potential economic repercussions of the UAE's decision could extend beyond its own borders. Ships avoiding UAE waters to escape the constraints of the new regulation could impact the country's maritime industry. The regulation may shift tank cleaning operations out of UAE waters, potentially affecting local businesses and leading to a relocation of these activities to non-UAE regions. Furthermore, the recycling of UAE-flagged vessels in drydocks outside the country could impact the UAE's circular economy goals and conservation of resources. The drydock method of recycling often leads to the melting of ship scrap in furnaces rather than rerolling and upcycling, reducing the residual value of the ships.



The UAE's SRR, while laudable in its environmental aspirations, necessitates a holistic and pragmatic examination. To truly align with global sustainability goals, the UAE should consider allowing HKC-compliant yards for the recycling of both UAE and non-UAE-flagged vessels. This approach would acknowledge the current 637 UAE-flagged ships, as per UNCTAD data, ensuring they have sustainable recycling options. A balanced approach, weighing both environmental and practical ship recycling aspects, is essential. The regulation presents complex challenges, affecting local maritime businesses and the circular economy. Its broader implications extend beyond environmental concerns, impacting the economic landscape and established recycling practices. This comprehensive critique underscores the need for inclusive and collaborative dialogue among global stakeholders to align environmental standards with the realities of the ship recycling industry.


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About Author

Dr. Anand M. Hiremath, Chief Sustainability Officer of GMS Leadership, is a Civil Engineer and holds a Master's Degree in Environmental Engineering from the Indian Institute of Technology Guwahati (IIT Guwahati) India. He has a diploma in industrial safety and is a qualified lead auditor for ISO 9k, 14k and 184.

Dr. Hiremath published the first practical handbook on ship recycling, entitled: 'The Green Handbook: A Practical Checklist to Monitor the Safe and Environmentally Sound Recycling of Ships' which highlights the procedures the GMS SSORP follows to help both Ship and Yard Owners recycle a vessel in an environmentally-friendly manner. Dr. Hiremath is the Course Director for the first-of-its-kind 14-week online course on Ship Recycling offered by Lloyd's Maritime Academy, London."

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Ship Recycling Team