National Institute of Maritime Affairs (NIMA) Bahria University, Pakistan
NIMA POLICY PAPER Series # 003 March 2019
Research Paper
EVOLUTION OF FLAG OF CONVENIENCE: SUGGESTIONS TO IMPROVE PAKISTAN’S SHIP REGISTER
Authors: Syed Khawar Ali Shah Kanwar Muhammad Javed Iqbal
First Edition
National Institute of Maritime Affairs (NIMA) Bahria University, Pakistan
Category: Policy Paper
Title: Evolution of Flag of Convenience: Suggestions to Improve Pakistan’s Ship Register
Authors: Syed Khawar Ali Shah* Kanwar Muhammad Javed Iqbal**
Reviewed by: Muhammad Akhtar, Deputy Director, NIMA Karachi Muhammad Nadeem, Deputy Director, NIMA Islamabad
First Edition: March 2019
Property Rights: National Institute of Maritime Affairs, Islamabad
* Vice Admiral (R) and Director General at National Institute of Maritime Affairs (NIMA) reachable at [email protected] ** Senior Researcher at National Institute of Maritime Affairs (NIMA) reachable at [email protected]
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Contents
ACRONYMS ...... ii 1. INTRODUCTION ...... 1 2. HISTORICAL EVOLUTION OF FOC ...... 2 3. INTERNATIONAL OBLIGATIONS AND FOC ...... 3 4. NATIONAL LINES VS FOC ...... 4 5. STRENGTHS OF FOC ...... 5 6. THE CASE OF PAKISTAN ...... 7 7. CONCLUSION AND RECOMMENDATION...... 7
i
ACRONYMS
EU European Union FBR Federal Board of Revenue FOC Flag of Convenience ICS International Chamber of Shipping ILO International Labour Organization IMO International Maritime Organization IUU Illegal, Un-reported and Un-regulated MARPOL Marine Pollution Convention MLC Maritime Labour Convention MMD Mercantile Marine Department in Pakistan MoU Memorandum of Understanding NOC No Objection Certificate OECD The Organisation for Economic Co-operation and Development PSC Port State Control SOLAS Safety of Life at Sea STCW Standards of Training, Certification and Watch-keeping for Seafarers UNCLOS The United Nations Convention on the Law of the Sea UNCTAD The United Nations Conference on Trade and Development
ii 1. INTRODUCTION The modern era of global Shipping sector has witnessed shifting trends in ship registration processes from traditional to open registries, provides alternate choice to the owner for flag of convenience over the business as usual practices. A Flag of Convenience (FOC) or open registry is a distinctive phenomenon in the global shipping industry. FOC is a specific business practice in which a trader's vessel is registered in a country other than that of owner’s own country. This ship flies that country’s flag. The most relevant term used for FOC is an open registry to define a firm that will allow ship owned by foreign nationals1. In the past 30 years, the Flag of Convenience (FOC) tonnage has been rising steadily. The FOC fleet will go on increasing as long as the FOC device contributes a significant cost reducing and revenue maximizing factors to the maritime sector. There is enough historical evidence for supporting the change of flag to another in different countries for economic or regulatory purposes2.
After the mid of 20th century, flags of convenience have produced large economic footprint and benefited the economic operators and the open registries worldwide. The business trends under open registries have influenced the traditional registries for a convergence between the two processes3. There are different arguments regarding various check and balances to be part of open registries such as safety and labour related regulations. The open registries have realized the importance of the outstanding issues, such as Panama (ratified the ILO’s Maritime Labour Convention 2006 on 6 February 2009), by addressing the needs for upgradation in the safety standards and were successful in advocating and improving their image by ratification of the conventions4. Thus, the convergence is the need to adhere to the international conventions by the FOCs and requirement of the national flag to be more commercially competitive.5
The Pakistan’s Shipping sector has not lived up to the potential which can support the national economy on a large scale. Though, ship registration procedure of Pakistan is in compliance with international obligations, but, it is a reality that Pakistan’s global share in the shipping market has shrunk over period of time and private sector has negligible contribution due to several reasons for which ship registration is an important issue.
In the context, this policy paper aims to examine in depth the topic of importance i.e., FOC practices and compare them for policy options for Pakistan, firstly by taking into account a range of relevant analyses and opinions generated by experts, relevant national / international documents, and academicians in peer reviewed publications. Secondly, the paper identifies and lists key issues raised by way of thematic and content analysis. Thirdly, the policy paper deduces inferences and generates recommendations for practical actions including policy measures proposed for Pakistan’s ship register.
1 Jihong Chen et.al. "The development of ship registration policy in China: response to flags of convenience." Marine Policy 83 (2017): 22-28. 2 Basil N. Metaxas. "Flags of convenience." Marine Policy 5, no. 1 (1981): 52-66. 3 Mitroussi, Kyriaki, and Peter Marlow. "The impact of choice of flag on ship management." In The Handbook of Maritime Economics and Business, pp. 609-632. Informa Law from Routledge, 2013. 4 Francisco Piniella et al. "The Panama ship registry: 1917–2017." Marine Policy 77 (2017): 13-22. 5 Kyriaki Mitroussi & Michael G. Arghyrou,” Institutional performance and ship registration”, Transp. Res. E 85 (2016) 90–106.
1 Based on analysis, this paper argues that Pakistan needs to revamp its registry and other legal/institutional/policy framework in order to harness the actual potential of this sector. The policies can be revised in light of best contemporary practices of FOCs and National registers and at same time address the needs to meet its international obligations like the case of Panama for the ratification of ILO’s MLC.
2. HISTORICAL EVOLUTION OF FOC Historically, ships have sailed under a Flag which became formalized in early eighteenth century. As per International Law a ship of above a certain tonnage must be under a flag of a State where the ship is registered. States have given their flag to their owned ships, which was an endorsement of the authority over these ships and signified that Ship was under the law and jurisdiction of that State; Countries give nationality to their Ships6 and a State where a ship of a non-national is registered is said to have an open register or the ship is said to have a Flag of Convenience (FOC). In the early 1900’s the US congress recognized that US Ships could not compete with Shipping Line conference members who acted like a cartel and had the collective strength to engage in predatory wars in order to eliminate outsiders from shipping trade. Realising this in 1920, US congress enacted Merchant Marine Act, also known as Jones Act, which stipulated that goods between two ports of US may only be carried out by American Flagged vessels; which are crewed by American Nationals and built in US Shipyards. Consequently American Ship owners grew frustrated by increased regulations and rising labour costs, began registering ships in Panama7. First ship under Flag of Convenience was registered in Panama in 1922. Initially the lure of Flag of Convenience was due to relaxed rules of ship’s age and its state, cheap crew, ownership remaining anonymous and no taxes.
FOCs increased rapidly after 2nd World War but number of ships under Panama and Liberian flags remained significant only. The Liberian ship registry was opened in 1948 with head office in Virginia, USA. For Panama and Liberia; ship registration became a source of income and these particular countries started open registries because of closeness of these countries to USA and majority of owners also being American. US ship building and Ship operations were heavily subsidized from 1936 onwards to make the American industry competitive but despite that FOC share of US owned ships continued to increase. By 1950’s US had become a very high cost ship operator, consequently its Merchant Marine declined rapidly. Following Panama and Liberia’s example many countries opened up their registries, some of the notable ones were; Lebanese flag grew rapidly in the 1960’s but due to no restrictions on age and condition of ships, this led to many Lebanese Merchant ships sinking and accidents which eventually became the cause of decline of the Lebanese register. The Somali flagged ships in the 1960’s were not under positive control of the state and few of their ships went to North Vietnam during the US- Vietnam war; consequently US cut off aid to Somalia. Another dark side of FOCs is South Africa during Apartheid and Israel have used them extensively.
6 Francisco Piniella et al. “The Panama Ship registry: 1917-2017.” Marine Policy 77 (2017): 13-22. 7 Priyanka Ann Saini, “Flags of convenience, Advantages and Disadvantages and impact on Seafarers.” Sea News, Oct 27, 2017. Available at https://seanews.co.uk/features/flags-of-convenience-advantages-disadvantages-impact-on-seafarers/ (Last accessed on 25.02.2019)
2 FOCs gained further popularity in the 1960’s and during this period Liberia surpassed UK as a country with largest Ship registry. UK commissioned a study in 1970 to find the reasons for decline in UK’s registry. In their inquiry into shipping, the UK committee under Lord Rochdale identified following key reasons for growth of FOCs:8
a. The country of registry allows vessels to be owned by non-citizens. b. Access to registry is easy. c. Taxes on the income from the ships are not levied locally or are low. A registry fee and an annual fee are the only charges. d. The country has a small power with no national requirement/obligation to requisition ships during war or periods of emergency. e. Manning of ships by non-nationals is freely permitted.
During the 1970s, the countries of open registries had neither the power nor the administrative machinery to effectively impose any government or International regulations/conventions on ships flying their flag. In this period, FOC continued to be considered as registry of lower quality then the closed registries because of relaxed requirements as well as the room they gave to ship owners to employ Seamen of any nationality. To solve this problem of poor state of ships; the leading FOC countries started delegating some of its obligatory roles for inspection of their ships to recognized International classification societies and nautical surveyors. This was allowed as per Maritime Laws but still did not relieve the state of its exclusive responsibility for its ships as imposed by article 94(1) of UNCLOS. The number of FOCs continued to increase due to the existence of Tax havens, where anonymous owners could operate, buy and sell ships under FOCs easily and at times these ship owners were also unethical9. The most serious violations were in the form of Marine pollution, sailing substandard ships, illegal fishing, abuse of Seafarers and un- governed ships. By 1971 the FOC States had grown from initial three countries of Panama, Liberia and Honduras to thirteen more i.e., Costa Rica, Cyprus, Dominican republic, Greece, Lebanon, Maldives, Malta, Morocco, Nicaragua, Singapore, Somalia, Sri Lanka and Vanuatu. Singapore was unusual for FOC States as it was able to enforce International conventions and regulations on its registered ships. This type of registry came to be known as quasi open register.
3. INTERNATIONAL OBLIGATIONS AND FOC In 1978, in reaction to noncompliance of FOCs to maintain the ships properly and treat the Seafarers manning them equitably, European countries decided to inspect FOC state ships visiting their ports, this became known as Port State Control (PSC), it is an inspection regime to inspect foreign registered ships other than owned by the nationals of the flag state. The inspections were to determine Ships visiting the European ports were in compliance with SOLAS; International conventions of International Labour Organization (ILO); Standards of Training, Certification and Watch-keeping for Seafarers (STCW) and Marine Pollution (MARPOL). Later, some non-European countries were included and this emerged as Paris MOU. Inspections included the competency of the master and the crew, state of Machinery, Hull and Equipment. The Paris MoU started categorization of the FOC Ships into three lists
8 Rex S.Toh, and Sock-Yong Phang. "Quasi-flag of convenience shipping: the wave of the future." Transportation Journal (1993): 31-39. 9 Hamad Bakar Hamad. “Flag of Convenience Practice: A Threat to Maritime Safety and Security.” IJRDO-Journal of Social Science and Humanities Research (2016): 1. 207-230.
3 White, Grey and Black based on the PSC Inspections. Ships under Black list were not allowed in Paris MoU countries or were detained till deficiencies could be removed. Modelled on Paris MoU more regional MoUs were signed including Tokyo (Pacific), Riyadh(Persian Gulf), Central and South America, Mediterranean, Abuja (West Central Atlantic Africa), Indian Ocean, Caribbean and the Black Sea MoU. This led to improvements in FOC Ships and registries.
Another issue which still persists is Illegal fishing under FOC10. Illegal, unreported and unregulated (IUU) or private fishing is plundering fish stocks, devastating Marine Environments and stealing from some of the poorest people of the world. Globally private fishing as per estimate accounts for $ 10-28 Billion a year, representing 11-26 M tons of fish. Many deliberately target poor countries. FOCs reduce the operating costs in absence of any taxes. Vessels can re-flag and change names many times in a season. This practice is known as flag hopping. The owners remain hidden and offshore shell companies operate these fishing vessels. Such type of fishing vessels are supported by large Refrigerated transport Vessels (Reefers), who have been implicated in Illegal Fishing. Virtually all Reefers fly FOCs. These vessels allow fishing vessels in an area to trans-ship their cargoes and re- crew; without the need of the fishing vessel to return to a port and re-fuel11.
United Nations recognizing the need to promote the orderly growth of world shipping promulgated Convention on the Law of the Sea (UNCLOS) 1958 and later UNCTAD 1986 further elaborated that there must be a genuine link between the Ship and the State. The Flag State must have adequate maritime administration. The Flag State should ensure that those who are responsible for the management and operations of a ship on its register are readily identifiable and accountable. The state shall also fix the conditions for grant of its nationality. Ship means self-propelled sea going vessel except those less than 500 tons. Every state whether coastal or land-locked has the right to sail ships flying its flag. There are 48 land-locked countries and out of them many have started their registers; prominent amongst them are Luxemburg, Austria, Mongolia and Ethiopia. No ship will be entered in two or more state’s register. A ship may not change its flag except in case of a real transfer. The Flag Sate shall implement applicable international rules and standards. The Flag State will ensure safety of ships, persons on-board and prevention of pollution. The ships must carry relevant documents on-board. Ships must be periodically surveyed by its authorized surveyors. Article-10 states that the Flag State should ensure that the owner or persons accountable for the Management and operations of ships are financially able to pay out liability in case of damages to third parties. Article-12 allows bareboat charterer to fly the flag of the state which has chartered the ship. The regime of Ship inspections came to be known as Port State Control with all ships undergoing mandatory inspections after IMO’s resolution A.1052 (27) governing it was ratified12.
4. NATIONAL LINES VS FOC The evolution of the FOC can be better understood if it is compared with the conventional concept of “National Shipping Industry”. Definition of what constitutes a National Shipping company is varied due to different evolution and economies of
10 EJF (Environmental Justice Foundation). "Lowering the flag: ending the use of flags of convenience by pirate fishing vessels." (2009). 11 Ibid (source 10) 12 Captain John W Dickie. “Reeds 21st century ship management.” A&C Black, (2014).
4 countries. Broadly, the shipping line whose capital and resources originate from within the country are National Lines. Thus the National Shipping line has direct relation with the National economy. UN in the 1960s, started work on providing poorer countries with better share of the global trade13; it was analysed by UNCTAD that Shipping had direct link to the trading ability of a country. The under developed countries due to having less ships were being charged monopolistic rates by ships of the developed states. Consequently, the UN developed the Liner code in 1974 which had a provision of 40/40/20 rule; which allowed 40% of traded cargo each to trading partners and 20% to Independent shippers. Despite this the National Lines could not compete with the FOCs because they were more competitive, had no taxation and ease of transfer of ships and mortgages could be done with much more ease. However, national lines also continued to develop due to following motives:
a. To attain UN mandated 40% cargo. b. Provision of services which were uneconomical by commercial standards but desirable for the purpose of economic development or to provide essential communications. c. In case of war or transfer of sensitive cargo; own ships could be requisitioned. d. National prestige. e. Balance of payment motives to save foreign exchange. f. Protection of home shipping against competition of lower cost foreign companies. g. Uninterrupted trade in event of war.
5. STRENGTHS OF FOC Growth of FOCs clearly shows that the FOCs have continued to improve in last few decades. Another case in point worth mentioning is that of Cyprus and Malta; Cyprus register was opened in 1963 while that of Malta in 1973. Both these countries joined EU in 2004; EU has the most regulated and integrated system and when these two countries with large FOCs joined, it created a dilemma. This was initially tolerated but later due to number of lawsuits on Shipping in EU courts, FOCs were finally legitimized. EU commission challenged another contentious issue the genuine link between the ship and the State and EU court decided that it is not necessary to have a link of the owner with the state but it is sufficient to carry the management of the ship from that country14.Traditional registries like France and Germany have also opened International registries. The competitiveness of FOCs gives an additional saving of 14% to 17% to ship owners, which is quite substantial15. As taxes of shipping lines belonging to closed registers fall mainly on profit, it makes depreciating of high capital cost of ships difficult as depreciation is a much greater part of total annual cost in shipping than in most other industries. Unless sufficient profits can be retained to counteract the prices for new ships as ship owners cannot replace their ships when they become obsolete and old. Although most Maritime nations have made concessions in taxation to address this problem but they are not enough to offset the advantage in the virtually tax free profits of the FOCs. Today’s reality sees foreign owned vessels being registered not just in open registers but
13 Dong-Wook Song et.al. “Maritime Logistics: A Guide to Contemporary Shipping and Port Management.” Kogan Page Publishers, (2015): 2nd Edition. 14 Randolph Dilday DeArmond. "For Sale: Flags of Convenience and the Commodification of Sovereignty in the European Union." (2015). 15 O’Loughtin. “The Economics of Sea Transport.” Pergamon Press, (1967): pg 27.
5 also in quasi open registers belonging to traditional national flags, as the relaxation of fiscal regimes and employment related requirements like manning have acquired a universal character16. FOCs were 71% of the world shipping in 2015 and top open registries such as Panama, the Marshall Islands and Liberia, at the beginning of 2015 accounted for more than 41.5% of world shipping, which is over 1.7 billion Dwt17. In 2017, the world Merchant Fleet of 100 gross tonnage or more numbered 90,715 ships18.
A contemporary top FOC registry provides 24/7 services. A ship can be registered or deleted in few hours and all formalities completed. All services are web based with a worldwide network of offices. Liberia has Ecorp; the world’s premier electronic corporate registry, it is confidential, no audit or annual reporting, exempt from Liberian income and tax laws and it is in OECD white list. The Liberian Maritime law, allows waivers for sea going vessels less than 500 tons and also age of the ship can be waived off even if it is more than 20 years. Scott Berenson of Liberian International corporate registry, defends the FOCs by saying that in 2012, Liberia was one of 13 Flags which have been given a clean bill of health by the International Chamber of Shipping (ICS) in its Flag State Performance Table. The criteria is based on conventions ratified, age of vessels, IMO attendance and completion of standards of training.
World’s top registry as of 2015 is Panama with 8351 ships registered. Currently access to Panama registry is very easy, Ship owners chose a ship register for the convenience of shipping operations, with minimal interference from a flag state19. A registry fee based on tonnage is the only charge made and the manning of ships is freely permitted. The Panamanian ship registry has more than 64 maritime private consulates and 9 technical offices worldwide, operating on 24/7 basis. The registration process is automated and takes a maximum of four hours. Panama is also a Tax haven where the capital and owner remains anonymous. Another incentive for the ship owners is that Panama has ratified most of the conventions related to Shipping and is on the white list of Paris as well as Tokyo MoUs. Flag selection is a crucial decision with regards to ship operation, but also plays an important role in National and International Maritime policy. In May 2015, IMO Secretary General Koji Sekimizu remarked that FOCs have become international registries with international responsibilities.20 On the other hand, the congruence of the FOC and flag state ships is evident from that operators from traditional Maritime countries are found to flag out high quality vessels, whereas those from open registry countries flag out low quality ships.21 This is attributed to the low salary structure of FOC ships vis-a-vis a developed state, the difference can be upto 2.5 million US dollars, the reason for flagging out low quality ships by FOCs is now a need to avoid coming into grey/black list of PSC.22 In this age of competitiveness, there is requirement that International ship owner cut costs to compete. It can be
16 Kyriaki Mitroussi and Michael G. Arghyrou. "Institutional performance and ship registration." Transportation Research Part E: Logistics and Transportation Review 85 (2016): 90-106. 17 UNCTAD. “Review of Maritime Transport.” (2015): pg 41 18 The World Merchant Fleet 2017. Equasis 2014,p.8 19 Francisco Piniella et al., "The Panama ship registry: 1917–2017." Marine Policy 77 (2017): 13-22. 20 An Inquiry into the Increasing use of So-Called Flag of Convenience Shipping in Australia. International Shipping Chamber. Aavailable at http://www.ics-shipping.org/docs/default-source/Submissions/Other/australian-senate-inquiry-on-so-called-flag-of- convenience-shipping---submission-by-the-international-chamber-of-shipping.pdf?sfvrsn=2 (Last accessed on 28.02.2019) 21 Meifeng Luo et al. "Flag choice behaviour in the world merchant fleet." Transportmetrica A: Transport Science 9, no. 5 (2013): 429-450. 22 Captain Anwar Shah. “Flag of convenience – off shore registry to induce private sector in Pakistan”. Pakistan & Gulf Economist, (February 27, 2017) Available at http://www.pakistaneconomist.com/2017/02/27/flag-of-convenience-off-shore-registry-to-induce- private-sector-in-pakistan/ (Last accessed on 25.02.2019)
6 ascertained that FOCs have improved and some of them are even better than traditional registries as shipping registers have become truly global.
6. THE CASE OF PAKISTAN Pakistan Merchant Marine policy of 2001 governs the register of ships and in this policy flexibility was given as per the norms of International registry prevalent at that time. As per policy Pakistan has three registers i.e., Permanent, Temporary and a Second Registry. In essence, Pakistan has a closed register which has two parts, one is used for foreign going vessels and the other for Inland Ships/Boats. The owner(s) has to be a citizen of Pakistan or the corporation owning the ship has to be registered in country and the operations and management has to be controlled from Pakistan. The process of registration is lengthy and cumbersome e.g., the approval of the name of the ship has to be taken from the authorities and prior to its registration, the new name has to be advertised in a reputable paper. The registration form has to be signed in front of the Ship’s registrar. The requirement is to have the original bill of sale duly attested and original deletion certificate from the Flag State. The procedure for a ship outside Pakistan is to send the form to the nearest Pakistani consulate to the port of delivery, where someone from Embassy will physically go there and check the ship. This is indeed a very difficult process where different tiers of bureaucracy are involved and cannot be done without losing great amount of money for the ship owner. The registry office is manual and the capacity to handle the ship registry is limited especially the transfer of lien and liability of a ship in timely manner. The Office of Registrar is responsible for various inspections for which it does not have requisite qualified staff. In addition Pakistan register is not competitive to handle the transactions in a timely manner due to shortage of staff, capacity of the existing personnel and lack of automation. Website is not maintained and much below par as compared to regional countries. Salaries of the specialists are not market based, hence it is difficult to recruit and retain qualified and competitive persons23. One of the major hindrance for investors is deletion from registry as in the past due to requirement of an NOC from customs resulted in lengthy litigation due to which ship owners suffered losses. The key informant interviews of the former ship owners repeatedly laid the blame on customs, FBR and the bureaucracy and showed their mistrust on the overall governance mechanism which made them fearful to risk their investments. Another issue is mandatory requirement of Pakistani crew which makes registration difficult though a provision exists that allows foreign crew to sail provided no Pakistani is available with similar qualifications.
7. CONCLUSION AND RECOMMENDATION To conclude, if the country wants to be competitive in shipping, it has to make its register as per International requirements. Pakistan register of ships was unable to attract ship owners because of policy implementation issues. With one of the cheapest trained seafarers’ community available, it was the lack of capacity of MMD and coordination with customs and FBR which deterred the potential ship owners. There was also no effort to adequately market Merchant Maritime Policy 2001 and build up the capacity to adopt the changes. The mistrust of the investors and
23 Interviewed the Principal Officer of the Mercantile Marine Department on 14 Jan 2019.
7 bureaucracy and uncertainty regarding continuation of the policy was also the major contributing factor in achieving its objectives. The back-bone of shipping is the Mercantile Marine Department (MMD) in Pakistan. A complete man power audit and survey is needed urgently to identify the short comings and capacity of this vital department. It has to be computerized and automated to fulfil its functions. The last Merchant Marine Policy was promulgated in 2001, many new International conventions have been ratified which need study; and incorporation in the policy or alternatively a new one may be issued. Due to lack of capacity, difficult processes, bureaucratic red tape and FBR/Customs not following the spirit of the policy; the objectives of the Merchant Marine Policy of 2001 have not been achieved by a long measure despite extravagant and generous incentives given. A thorough review of the ship registration, MMD and Merchant Marine Policy of 2001 is the need of the hour.
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