In summary, the international shipping industry is broadly satisfied with the status quo
with respect to the current text of the Convention, including Article 8. However, with
respect to the current text of Article 15, opinions within the shipping industry appear to
differ. ICS is cautious about commenting on proposed changes whose wider
implications are difficult to fully understand, despite having been carefully studied by our
members. ICS therefore suggests that the proposed changes to the OECD Model
Convention need to be subjected to a far more comprehensive review.
The purpose of this initial informal submission is to present the view of the liner shipping industry with respect to the need for continuation of the Consortia Block Exemption Regulation (BER), with the aim of assisting the Commission as it continues its review of the Consortia BER. WSC, ECSA, and ICS respectfully urge the Commission to continue the current successful policy authorized by Article 103 of the Treaty and by Council Regulation (EC) No 246/2009 by extending the Consortia BER for at least another five years.