FINAL ICS SUBMISSION TO THE FMC INVESTIGATION INTO SO-CALLED ‘FLAGS OF CONVENIENCE’
Following extensive consultations with members, the ICS Secretariat has now finalised and submitted comments in response to the FMC’s investigation into so-called ‘FOCs’ and the potentially ‘unfavourable conditions’ arising from certain flagging practices.
The final submission is attached at Annex A.
The final submission stresses that “open registers” are legitimate and often among the highest-performing flag States. It highlights that these registries comply with IMO and ILO standards on safety, environment and labour, reinforced by Port State Control oversight. It cautions against subjective criteria, such as those used by the ITF, and urges reliance on objective performance data. It also acknowledges concerns over fraudulent registries and “dark fleets,” supporting U.S. engagement at the IMO to strengthen enforcement.
The ICS extends its sincere thanks to members for their valuable input and engagement throughout this process.