Submitted by Croatia, Denmark, Singapore, ICS and Interferry, Sub-Committee on Pollution Prevention and Response, 2nd Session, Agenda Item 5, November 2014.
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.
CS believes this major policy change would involve inappropriate interference by the Government of Sri Lanka into commercial relationships between ocean carriers and their customers.
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.
Submission by Singapore, Liberia, Marshall Islands, International Chamber of Shipping (ICS) and Cruise Line International Association (CLIA),Maritime Safety Committee, 90th Session, Agenda Item 25, March 2012.