In our previously published client alert, we had explained how Türkiye took a critical step globally in the field of green ship recycling by ratifying the 2009 Hong Kong International Convention for the Safe and Environmentally Sound Recycling of Ships (“Hong Kong Convention”). Since then, the Hong Kong Convention entered into force globally as of 26 June 2025.

The "Regulation on the Authorization of Ship Recycling Facilities" ("Regulation"), was published in the Official Gazette on 22 June 2026 and has entered into force except for certain articles which will enter into force on 31 December 2028. The Regulation constitutes a concrete step aimed at integrating the Hong Kong Convention and European Union ship recycling regulations into Turkish law and the preservation of Türkiye’s pioneering position in the global ship recycling market. The former Ship Breaking Regulation dated 8 March 2004 has been entirely repealed, and a brand-new legal regime based on strict international standards has been introduced.

1. Main Innovations and Amendments Introduced by the Regulation

The Regulation eliminates the general framework established by the former legislation and aligns facility management and operational processes directly with the Hong Kong Convention and the European Union ship recycling regulations. The prominent legal changes are the following:

• It has become mandatory for all facilities that will conduct ship recycling activities to obtain an authorization certificate from the Turkish Ministry of Transport and Infrastructure with maximum validity period of 5 years. Conducting activities without such a certificate has been prohibited.

• The Regulation stipulates that the standards of the guidelines contained in the European Union ship recycling regulations shall be adopted and the activities of the facilities shall be conducted accordingly for the protection of human health and the environment.

• The primary document for facilities during the authorization phase will be the Ship Recycling Facility Plan (“SRFP”). This plan, to be approved by the board of directors or the authorized administrative organ of the facility, is the document that will form the basis of all operations in the facility.

• The facility official is obliged to prepare a ship-specific Ship Recycling Plan (“SRP”) taking Hong Kong Convention and the European Union ship recycling regulations into account before the breaking and recycling process of each ship begins, and to submit it for Ministry approval. The SRP will be prepared in Turkish and, following the approval process, will be translated into one of English, French, or Spanish languages.

• Inventory of Hazardous Materials tracking, disposal of hazardous waste in a manner that does not harm the environment, continuous camera monitoring system, entry-exit logs and the obligation to maintain barriers/equipment preventing marine pollution have been rendered operational prerequisites.

2. Inspection and Administrative Sanctions

The Regulation has established an effective inspection model to ensure that the facilities maintain standards and implementation of commitments on site. An Inspection, Determination, and Audit Commission shall be established within the Ministry to carry out planned and unannounced inspections targeting the facilities.

In case of non-compliance with the Regulation, the Hong Kong Convention or the European Union ship recycling regulations, or any unauthorized activity or activity that is non-compliant with the plans, the following serious consequences will arise:

Violation	Sanction / Administrative Fine
Conducting suspended activities at the facility or for uncertified recycling activities.	TRY 1,000,000 Administrative Fine
Failure to comply with the rules governing the berthing of the vessel at the facility or failure to give notice of arrival.	TRY 500,000 Administrative Fine
Carrying out activities that are non-compliant with the SRP or the SRFP.	TRY 100,000 Administrative Fine
Failure to input data, failure to process completion notifications or ship information into the Ship Breaking Data Program (GSVP) system.	3 Business Days Period / TRY 100,000 Administrative Fine if the non-compliance persists.
Failure to provide information and documents during audits and inspections or to cooperate with the auditors	TRY 500,000 Administrative Fine
Recurrence	In the event that the same violation is repeated within a calendar year, the applicable fine shall be increased twofold (up to TRY 1,000,000).

3. Impacts on the Sector

The Regulation will create radical changes for facility operators in Türkiye, shipowners, P&I insurers and financial institutions offering green financing:

• Foreign and domestic shipowners who will send vessels to facilities in Türkiye must now meticulously examine whether the facilities possess an up to date "Ship Recycling Authorization Certificate". Working with unapproved facilities may lead to various administrative and legal risks for the shipowner.

• From the perspective of facility owners, administrative and financial obligations have been increased. Operating the pre-notification mechanism before commencing ship breaking operations (a written notification of intent to the Port Authority pursuant to Article 18) and the ship-specific SRP approval processes will require meticulous management of operational schedules. Consequently, facilities are required to provide services in accordance with the Hong Kong Convention and the European Union standards.

• From the perspective of P&I insurers, environmental pollution and occupational accident risks in the ship recycling process must be evaluated within the context of the Regulation and international standards in risk analyses.

• For banks and financial institutions, it will become easier to provide green financing to facilities and shipowners in accordance with international standards.

The Regulation demonstrates Türkiye’s intention to strengthen its position among international competitors as a "sustainable, safe, and green recycling" option. Sector stakeholders are advised to align their current contracts, facility plans and operational safety infrastructures with the Regulation legislation in order not to encounter operational losses and heavy administrative fines. Please do not hesitate to contact us if you have any questions or require assistance on compliance with the rules.