Ship Recycling Facility and Vessel Plan Authorisation in Bangladesh
Legal advice for yard owners, cash buyers, shipowners, financiers and investors on ship recycling in Bangladesh, covering facility authorisation, ship recycling facility plans, vessel-specific plans, Hong Kong Convention compliance, vessel imports, environmental and labour obligations, and disputes arising before, during and after demolition.
- Assess the position
- Prepare the documents
- Secure the approvals
- Support through demolition
Ship recycling regulation in Bangladesh today
Ship recycling in Bangladesh is concentrated along the coast at Sitakunda near Chattogram, where yards dismantle large numbers of ocean-going vessels and supply steel to the domestic construction and re-rolling industries. The sector now operates under a far more demanding legal framework than it did a decade ago. Yards need authorisation, approved facility plans and ship-specific plans, and shipowners and cash buyers face scrutiny over hazardous materials and worker safety. We advise on these questions as part of our regulatory practice in Bangladesh, working with technical consultants, classification societies and marine surveyors where the work requires engineering input.
The domestic framework centres on the Bangladesh Ship Recycling Act 2018, which established the Bangladesh Ship Recycling Board under the Ministry of Industries as the competent authority for authorising facilities and supervising recycling activity. Environmental requirements under the Bangladesh Environment Conservation Act 1995 and the Hazardous Waste and Ship Breaking Waste Management Rules 2011 continue to apply, and the Department of Environment remains closely involved. Labour law, gas-free certification, customs, port and coast guard requirements all play a role at different stages. Each agency has its own documents and timelines, so coordination is essential from arrival to final demolition.
Internationally, the Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships entered into force on 26 June 2025. Bangladesh acceded in 2023, so authorised facilities must meet its standards. In practice that means an approved facility plan for each yard, a Document of Authorisation to conduct ship recycling, an Inventory of Hazardous Materials for each ship, and an approved ship-specific plan before work begins. Flag states issue a ready for recycling certificate for ships covered by the Convention. Gaps in any of these documents can halt a sale, delay beaching or expose parties to liability.
Shipowners, especially those subject to the European Union Ship Recycling Regulation or to banks and charterers with responsible recycling policies, examine Bangladesh yards closely before agreeing a sale. Cash buyers need sale contracts, delivery terms and documentation that work under both international rules and Bangladesh import requirements, including letters of credit and customs clearance.
Yard owners need finance, insurance and title arrangements that protect them if a sale collapses or a vessel arrives with undeclared hazards. Our corporate and finance team advises on these transactions alongside the regulatory work, so that commercial terms reflect the authorisation position of each party.
Disputes in ship recycling arise over late delivery, price adjustments, hazardous materials, environmental damage, worker accidents, customs valuation and regulatory enforcement, including suspension of a yard's authorisation. Our team includes Barrister Tahmidur Rahman and Barrister Remura Meheruba Mahbub for transactions, finance and arbitration, and Adv Syed Wahid for litigation in the courts of Bangladesh, including admiralty and writ proceedings in the High Court Division. We also work with counsel in the UK, UAE, India and Singapore on cross-border sales. To discuss a ship recycling authorisation, a vessel sale or a dispute, please contact our Dhaka office.
Core workstreams
Four clear stages
- 01Assess the position
- 02Prepare the documents
- 03Secure the approvals
- 04Support through demolition
Talk to a partner
Consultations in Dhaka or by video. Scope, team and fees are agreed in writing first.
Book →Our ship recycling services
Yard authorisation and upgrades
- Assess the position
- Prepare the documents
- Secure the approvals
- Support through demolition
Ship-specific recycling plans
- Assess the position
- Prepare the documents
- Secure the approvals
- Support through demolition
Vessel sale and purchase contracts
- Assess the position
- Prepare the documents
- Secure the approvals
- Support through demolition
Imports, customs and finance
- Assess the position
- Prepare the documents
- Secure the approvals
- Support through demolition
Environment, health and safety
- Assess the position
- Prepare the documents
- Secure the approvals
- Support through demolition
Disputes and enforcement
- Assess the position
- Prepare the documents
- Secure the approvals
- Support through demolition
Yard authorisation and upgrades
We advise yard owners on authorisation by the Bangladesh Ship Recycling Board, preparation and approval of the Ship Recycling Facility Plan, environmental clearance and the documents needed to demonstrate Hong Kong Convention compliance. We review lease and land arrangements, safety and environmental systems, and training records, and help yards plan upgrades such as impermeable floors, cranes and waste handling in a legally coherent sequence that inspectors and buyers can verify.
Ship-specific recycling plans
For each incoming vessel, we help yards and cash buyers prepare and obtain approval of the ship-specific plan, checking that it reflects the Inventory of Hazardous Materials, the yard's approved facility plan and the conditions of its authorisation. We coordinate with surveyors and the flag state on certificates, and advise on what to do when the inventory proves inaccurate after the ship has arrived and work must be replanned with the authority.
Vessel sale and purchase contracts
We draft and negotiate memoranda of agreement, cash buyer contracts and back-to-back sales for ships sold for recycling, covering price, delivery position, condition, bunkers and remaining fuel, documentation, hazardous materials warranties and responsible recycling undertakings. We align delivery and payment terms with the authorisation timeline in Bangladesh, so that neither the buyer nor the yard is left holding a ship it cannot lawfully beach or dismantle, with costs mounting at anchorage.
Imports, customs and finance
We advise on import formalities for vessels bought for recycling, letters of credit, customs valuation and duties, port and coast guard clearances, and the documents banks require. We review financing and security for yards and cash buyers and help resolve disputes over documentary credits and customs assessments. Getting these elements right avoids demurrage, penalties and arguments about title, risk and payment at the point of arrival in Bangladeshi waters, when commercial pressure is at its highest.
Environment, health and safety
We advise yards on environmental clearance conditions, hazardous waste handling, asbestos and oil removal, worker safety, training, protective equipment and accident reporting under environmental and labour law. After a serious incident, we help the yard respond to inspections, show cause notices, police investigations and compensation claims, while preparing a credible remediation plan that addresses the concerns of the Board, the Department of Environment and international stakeholders, including shipowners and their financiers.
Disputes and enforcement
We represent yards, cash buyers, shipowners and lenders in disputes over ship recycling contracts, defective inventories, delays, price renegotiation, arrests and regulatory action, including suspension or cancellation of authorisation. We act in arbitration, in the Admiralty Court and in writ proceedings before the High Court Division, and coordinate with foreign counsel where the contract is governed by English law or seated in London, Singapore or elsewhere, and enforcement is needed in Bangladesh.
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Trade, Competition & Regulation matters at TRW are led by partners, supported by associates, with one responsible lawyer from first advice to final outcome.
Meet the firm →01Does a Bangladesh yard need authorisation before beginning ship recycling?
Yes. Under the Bangladesh Ship Recycling Act 2018, a facility must be authorised by the Board created under that Act, and since the Hong Kong Convention entered into force in 2025, the authorisation must reflect the Convention's standards. A yard is expected to have an approved facility plan, environmental clearance and systems for safety, training and hazardous waste. Authorisation may carry conditions, may be time-limited and can be suspended for serious breaches. Buyers and shipowners increasingly ask to see these documents before agreeing a sale, so yards should keep them current and readily available for inspection.
02What is a ship-specific recycling plan and who approves it?
It is a plan prepared for an individual vessel, based on its Inventory of Hazardous Materials and the yard's approved facility plan, describing how that ship will be safely and soundly dismantled. It covers matters such as gas-freeing, removal of hazardous materials, the order of cutting, waste management and worker protection. The plan must be approved before recycling begins. Inconsistencies between the inventory, the plan and what is actually found on board are a frequent cause of delay and cost. We help yards and buyers prepare consistent documents and respond to queries from the authority and the flag state.
03How has the Hong Kong Convention changed ship recycling in Bangladesh?
Since 26 June 2025, ships covered by the Convention may only be recycled at facilities authorised in line with its standards, and they must carry an Inventory of Hazardous Materials and an international ready for recycling certificate issued on behalf of the flag state. Yards need approved facility plans and ship-specific plans, and the Board must supervise compliance. Many Bangladesh yards invested in upgrades and third-party statements of compliance before entry into force. The Convention has also raised buyers' due diligence expectations, so contracts now include detailed compliance warranties, documentation duties and remedies for any breach.
04Can EU-flagged ships be recycled in Bangladesh?
Ships flagged in European Union member states are subject to European Union rules that require recycling at facilities included on the European List of approved ship recycling facilities. A Bangladesh yard can only accept such ships if it appears on that list, so EU-flagged ship recycling in Bangladesh depends on each yard's listing status at the time. Some owners have changed flag before sale, which raises separate legal and reputational questions under EU and other rules. We advise on the position of a particular vessel and on contractual protections where flag or listing status is uncertain.
05Who is responsible if the Inventory of Hazardous Materials is wrong?
Responsibility depends on the contract chain and the regulatory framework. The shipowner is generally responsible for preparing and maintaining the inventory, the flag state or recognised organisation verifies it, and the yard plans its work on that basis. If undeclared hazardous materials are found, the yard may face extra cost, delay and regulatory exposure, and will look to the cash buyer, which in turn looks to the seller. Well-drafted warranties, indemnities, inspection rights and price adjustment clauses reduce these disputes. We advise on contract terms in advance and on recovery where an inaccurate inventory has caused loss.
06What approvals are needed to import a vessel for ship recycling?
The process typically involves the yard's authorisation and approved plans, approval of the ship-specific plan, import documentation and letters of credit through a Bangladeshi bank, customs procedures and valuation, port and coast guard clearances for arrival and beaching, and gas-free and safe-for-hot-work certification before cutting begins. Environmental clearance conditions also apply. The order of these steps matters, because a ship that arrives before approvals are in place can incur heavy costs while waiting at anchorage. We map the sequence for each vessel and coordinate with the agencies, agents and surveyors involved.
07What happens if a worker is injured or killed in a ship recycling yard?
A serious accident triggers obligations under labour and safety law, including reporting, compensation and cooperation with inspections, and may lead to police investigation and regulatory action by the Board and the Department of Environment, including suspension of work. Families may bring compensation claims, and buyers and shipowners may review their relationships with the yard. The immediate priorities are care for the injured, preserving evidence and making accurate reports. We help yards manage investigations, cooperate with the authorities, settle claims fairly and lawfully, and prepare remediation plans that address the underlying causes of the incident.
08Can a ship recycling yard challenge suspension of its authorisation?
Yes, in appropriate cases. A yard should first respond to any show cause notice with a full factual account, documents and a credible plan to correct the issues identified, because many concerns can be resolved at that stage. If the authority suspends or cancels authorisation without proper process or on an unreasonable basis, the yard may seek review within the administrative framework or challenge the decision through a writ petition in the High Court Division. Interim relief may be available in some cases. We advise on the merits, prepare the response and represent yards in hearings and proceedings.
From first call to resolution.
- 01
Assess the position
We review the yard's authorisation, facility plan and environmental clearance, or the vessel's documents and sale terms, and identify gaps against Bangladesh law and the Hong Kong Convention before any commitment is made, so that risks are priced or resolved early.
- 02
Prepare the documents
We prepare or review the facility plan, ship-specific plan, sale contracts, import documents and compliance records, coordinating with surveyors and consultants so that every document is consistent with the others, with the authorisation and with what is physically on board.
- 03
Secure the approvals
We engage with the Board, the Department of Environment, customs, port authorities and banks, track progress, answer queries and keep the commercial timetable, letters of credit and delivery dates aligned with the approvals actually granted.
- 04
Support through demolition
During recycling we advise on incidents, inspections, inventory discrepancies, payment issues and disputes, and help close the file with completion records that protect the yard, buyer and shipowner if questions arise later from regulators, auditors, financiers or the flag state.
“Demonstrates an extraordinary command over both domestic litigation and international arbitration.”
The Legal 500 Asia Pacific, Bangladesh: Dispute resolution, client feedback
Related reading.

Shipbuilding and Ship Breaking Business in Bangladesh 2026: Ship Recycling Act, Hong Kong Convention

Maritime Law in Bangladesh (2026): Admiralty Claims, Ship Arrest, Shipping and Logistics

Environmental Compliance in Bangladesh 2026: ECC Renewal, ETPs, Inspections and Penalties

Letter of Credit in Bangladesh: Opening, Types, UCP 600, Recovery and Stopping Payment in 2026
All insights →
Which authority regulates ship recycling in Bangladesh?
Is beaching still permitted under the Hong Kong Convention?
What documents should a shipowner request from a Bangladesh yard?
Do ship recycling contracts usually choose English law?
Can a vessel be arrested in Bangladesh before recycling?
How is waste from ship recycling regulated?
Does Invest Bangladesh have a role in ship recycling investment?
How can TRW help with ship recycling matters?
Recycle ships lawfully and with confidence
Speak with the partners about ship recycling in Bangladesh or across borders.
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