Luxembourg - Specific requirements by the Luxembourg Administration

Flag instructions relating to statutory surveys

Flag procedural requirements

General policy

Single contact point

All correspondence between the Administration (Commissariat aux Affaires Maritimes / CAM) and Recognised Organisation (RO) is to be channelled through the following single contact point: B&L_CSC.

Agreement

An Amendment to the Agreement has been signed between the Commissariat aux Affaires Maritimes du Luxembourg and Recognised Organisation (RO) Marine & Offshore SAS and entered into force on 1st January 2017 (see Agreement concerning surveys and certification to Annex 2 to the Agreement).

A new Annex1 to the Agreement concerning Surveys and Certification of Seagoing Ships has been signed on 22 March 2023 (see Annex 1 to the Agreement)

An Amendment to the Agreement has been signed between the Commissariat aux Affaires Maritimes du Luxembourg and Recognised Organisation (RO) SA and entered into force on 23rd October 2020 (see Agreement concerning surveys and certification)

Flag State Inspection

The Commissioner of Maritime Affairs has established the Flag State Inspection Service to enhance the safety standards of the Luxembourg flagged ships. This inspection is performed by independent inspectors appointed by the Flag Administration.

The Flag State Inspection consists of control of certificates and documents in combination with a random check of the general condition of the ships, of the conditions of work on board and of the accommodation.

The Recognised Organisation (RO) surveyor should not be requested to attend the Inspection by the Flag State inspector. Should need be, instruction for attendance will be forwarded by the Marine Centre upon request from the Flag Administration.

Exemptions

The Administration requests that exemptions are handled in a consistent manner for their fleet. In case of issuance of an exemption for a sister vessel, existing exemptions for other sisters shall be consulted for consistency of reference/text.

During renewal surveys, the attending surveyor shall verify that existing exemptions remain in compliance with possible update of the related regulation (such as renumbering). If this would not be the case, MOC shall be contacted in order to submit an amended proposal to the Administration, for their confirmation before re-issuance.

Convention requirements left “to the satisfaction of the Administration”

Whenever the implementation of international statutory requirement (in particular in SOLAS, MARPOL, LOAD LINES, COLREG and TONNAGE conventions) requests that it should be fulfilled “to the satisfaction of the Administration”, the Administration shall be informed before any decision is taken (refer to article 3 of the Agreement). Such a request should include the relevant data and documentation, and the opinion of Recognised Organisation (RO).In general, a tailor-made decision will be taken on a case by case basis by the Administration. However, if deemed appropriate and necessary, the matter will be dealt with through a circular letter which will be published and forwarded to all actors concerned.

Ship Registration

According with Art.61 of the Luxembourg Maritime Act 1990, no ship exceeding 15 years of age from the date when the keel was laid may be registered for the first time under the Luxembourg flag.

In case, for a ship over 15 years an owner want to change flag to Luxembourg, he has to contact the Minister managing the Luxembourg Maritime Administration in order to obtain a special agreement.

List of Authorized ROs

Refer to Circular CAM 006/2020 in attached file “Circular CAM 006-2020.pdf”.

Incidents and accidents reporting obligations

Refer to Circular CAM 03/2023 in attached file “003 Accident reporting obligation.pdf”.

Reporting PSC deficiencies / detentions

(Circular CAM 09/2025)

If deficiencies are identified during a PSC inspection, the Administration requires submission of a Corrective Action Report (CAR) completed on the relevant CAM PSC CAR form within two weeks from the date of the PSC inspection. CAR shall be sent to: cam@cam.etat.lu. The CAM PSC CAR form is available on the Administration’s website.

If a deficiency is issued with an action taken code 17 (to be rectified before departure), objective evidence of the rectification of this deficiency shall be submitted to the Administration per email at cam@cam.etat.lu prior to the vessel’s departure from the port.

Any detention shall be immediately notified to the Administration at cam@cam.etat.lu with a copy of the PSC inspection report.

Reporting PR 17 to the Administration

MOs are to submit to B&L_CSC the PR 17 reports issued by Recognised Organisation (RO), after their validation by the MO, with copy to C-R_STAT.

B&L_CSC will in turn submit these to the Administration.

LL 66

Multiple Load Line Certificates

(Circular CAM 02/2023)

Multiple load line certificates may be directly issued to a ship by Recognised Organisation (RO).

However, the Administration shall be notified of such cases and advised of the vessel's highest deadweight tonnage.

When a ship is issued with multiple load line certificates:

• For paper certificates, the unused certificates must be placed in a sealed envelope and kept in the custody of the Master (NOT in the current ship’s certificates file).

• For electronic certificates, both the active and inactive certificates shall be displayed on the Recognised Organisation (RO) database and shall be capable of being verified. Preferably the system should highlight which certificate is active.

The following must be verified for issuance or change of Load Lines:

- The ship must comply fully with all statutory requirements appropriate for a ship of the maximum deadweight corresponding to the minimum freeboard assigned in the certificates issued;

- There must be no reduction in safety standards when sailing at an increased deadweight;

- Only one set of load line marks shall be on display at any time, and the other sets shall be obliterated by paint;

- The Master must ensure, with a Recognised Organisation (RO) surveyor in attendance, that the correct set of marks are displayed together with the corresponding load line certificate, that the other sets of marks are properly obliterated, and that the other load line certificates are in safekeeping and not on display. In the case of Recognised Organisation (RO) surveyor unavailability, the change of load line may be carried out on the Master’s instructions, provided that arrangements for verification at the next available port have been agreed with Recognised Organisation (RO);

- The option of a remote survey will be accepted in accordance with the Recognised Organisation (RO) procedures for remote surveys. When remotely accepting a change of load line, the received documentation shall provide equivalent proof of load line marking as if Recognised Organisation (RO) were attending the ship and visually confirming this.

At least the following documentation shall be provided to Recognised Organisation (RO) prior to perform the remote survey:

• Extract of the deck logbook singed by the master, ensuring date and location where the change took place, and photos of full load line marking with a draught scale at midship on both sides.

• Photos of the newly painted full load line mark with mid ship draft scale in JPG format.

• Photos of the previous mark obliterated by paint of the same color than the ship hull in JPG format.

• Pdf file of the log book entry confirming the date and location of the change of mark signed by the master.

• A clear photo of punched or cut marks (painting only is not accepted) in JPG format.

• In case the permanent marking is not clearly visible to the remote surveyor, the master should upon request provide better pictures. The photos received will be the basis for verifying that the load line is permanently marked and must be of high quality, clearly showing that the marking is permanent (welded, stencil/plate, punched, cut).

• If the received pictures are not convincing, Recognised Organisation (RO) can request further photos or cancel the remote survey and to request an on board survey.

- The current version of the IACS UR Z29 - Remote Classification Surveys applies;- The Master is to make an entry in the ship’s Official Logbook on every occasion that the load line marks are changed;- Recognised Organisation (RO) is to ensure that all marks are verified, and all their corresponding load line certificates endorsed at each subsequent load line inspection.

SOLAS 74

Cargo Ship Safety Construction Certificate

Initial testing of watertight bulkheads (SOLAS II-1/11)

(Circular CAM 007/2018)

To satisfy the requirements of SOLAS II-1 Regulation 11 the Commissariat aux Affaires Maritimes (CAM) accepts the use of IACS UR S14 for the initial testing of watertight bulkheads under the following conditions:

• the tank testing plan shall be reviewed and confirmation of the structural similarity of tanks as stated in IACS URS 14, as amended, shall be provided by the Recognized Organization’s (RO) plan approval department;

• the shipyard where the ship is being built shall have in place a certified quality management system according to a recognized standard, e.g. ISO 9001 or an equivalent standard acceptable to the RO which ensures the shipbuilding quality standard covering the production process; and

• the RO shall have experience with the yard and their records so that the provisions of IACS UR S 14 are considered adequate for the purpose of ensuring the required tightness and structural strength of watertight boundaries.

For further information, refer to attached file “Circular CAM 007-2018”.

Lifting appliances and anchor handling winches (SOLAS Regulation II-1/3-13)

(Circular CAM 08/2025)

With regard to Resolution MSC.532(107), introducing SOLAS Regulation II-1/3-13 on lifting appliances and anchor handling winches, Recognised Organisation (RO) is authorised to conduct plan approval, surveys, testing and certification on behalf of the Administration.

After due consideration of the provisions of the SOLAS Regulation II-1/3-13.1.3 and the associated IMO guidelines, the Administration has determined that lifting appliances with an SWL below 1000 kg fall outside the mandatory scope of approval, survey, and certification requirements contained in paragraphs 2.1 and 2.4 of the SOLAS Regulation II-1/3-13.

Nevertheless, ship owners and operators are encouraged to apply these requirements on a voluntary basis.

In all cases, the following minimum safety measures shall remain applicable:

• Each appliance must be permanently and legibly marked with its SWL and documentary evidence of the SWL shall be retained on board.

• Ship owners and operators should assess the appliances’ usage and associated risks, and incorporate procedures for inspection, maintenance, and training/familiarization within the Safety Management System (SMS).

Cargo Ship Safety Equipment Certificate

Electronic Chart Display and Information System (ECDIS)

(Refer also to the attached file ‘Circular CAM 09/2011’)

Until the corresponding implementation dates mentioned in SOLAS 74 regulation V [19.2.10], the use of a type-approved ECDIS on board of existing ships flying the Luxembourg flag, as the primary means of navigation will be accepted by the Commissariat aux Affaires Maritimes (CAM) provided that the relevant chart information is available as an Electronic Navigational Chart (ENC) and back-up arrangements are in place at all times.

For back-up purposes, the following arrangements are currently accepted:

• an appropriate folio of up-to-date paper nautical charts (APC)¹;

• a second type-approved ECDIS connected to the main and emergency source of power.

Moreover, when sailing in waters not covered by ENC charts or when no up-to-date ENC charts are available for the intended voyage, a folio of updated paper nautical charts must be used.

Requirements on, among others, the equipment approval and the training of masters and officers with navigation responsibilities are also displayed in this circular.

Requirements for maintenance, thorough examination, operational testing, overhaul and repair of lifeboats and rescue boats, launching appliances and release gear (MSC 402(96))

(Circular CAM 008/2019)

The Administration delegates Recognised Organisation (RO) for authorization of Authorized Service Providers (ASP).

IACS members Approved Service Suppliers are the same as authorized service providers as defined in the IMO Resolution MSC.402(96).

Five-year thorough examination, any overhaul, overload operational tests and repairs shall be conducted by certified personnel of either the manufacturer or an authorized service provider. This shall be done in the presence of a Recognized Organization (RO) surveyor authorized to act as RO on behalf of the Grand Duchy of Luxembourg.

Authorized service provider

An authorized service provider is an entity authorized by an RO authorized to act on behalf of the Grand Duchy of Luxembourg in accordance with the requirements given in IMO Resolution MSC.402(96), section 8. The authorization shall be limited to the make and type of equipment to be serviced. A service branch of a manufacturer also needs to obtain authorization. The authorized service provider will certify their personnel for each make and type of equipment.

The Commissariat aux affaires maritimes (CAM) also accepts or recognizes service providers authorized by a Maritime Administrations from another European member State or by their Ros, as long as this RO is also authorized to act as RO on behalf of the Grand Duchy of Luxembourg.

Certification of service personnel

Service personnel shall be certified by the manufacturer or by an authorized service provider for each make and type of the equipment to be worked on. An authorized service provider can only certify its own personnel (i.e. employed by the same service provider).

Certification of service personnel shall be performed in accordance with a recognized international or industry standard as applicable, or a manufacturer’s established certification program. In either case, the certification process and program shall comply with requirements of IMO Resolution MSC.402(96), section 8, for each make and type of equipment for which service is to be provided.

Considering that the related IMO Resolutions MSC.402(96), MSC.404(96) as well as the current IACS UR Z17 version do not make any reference to ISO 23678:2022 standards, the Administration confirms that only Circular CAM 008/2019 applies. The ISO 23678:2022 (Part 1 to 4) standards are not to be considered in this matter.

Upon completion of personnel certification, a certificate shall be issued (by the manufacturer or service provider) defining the level of qualification (annual or five-yearly) and the scope of the certification (i.e. makes and model of equipment). The expiry date shall clearly be stated on the certificate and shall not exceed three years from the date of issuance.

It should be noted that the definition of “make and type” is the same as “make and model” mentioned in IACS UR Z17 para 5.1.1 and is understood as the following:

• Make of equipment: name of equipment’s manufacturer

• Type of equipment: type/model of equipment, or series of equipment if there is no difference in maintenance and examination

The specification of the model or series in the competency certificate should be left to each manufacturer or service supplier who retains the responsibility for the certification process of service personnel.

Recommendation: For the five-year inspection, the approval certificate of the authorized service provider shall be recorded or attached to the survey statement issued by the relevant RO authorized by the Grand Duchy of Luxembourg.

For further information, refer to attached file “008 Rescue boats and lifeboats.pdf”.

Guidelines for the Maintenance and Inspection of fixed Carbon Dioxide Fire-Extinguishing Systems (MSC/Circ. 1318 Rev 1)

(Circular CAM 01/2022)

For New and Existing ships with high-pressure cylinders less than 10 Year of ages:

At the 10-year inspection, at least 10% of the total number provided should be subjected to an internal inspection and hydrostatic test. If one or more cylinders fail, a total of 50% of the onboard cylinders should be tested. If further cylinders fail, all cylinders should be tested. Before the 20-year anniversary and every 10-year anniversary thereafter, 100% of cylinders should be subjected to a hydrostatic test.

Existing ships with cylinders greater than 10 years of age, but less than 20 years of age that are equipped with no cylinders that have been hydrostatically tested:

10% of the total number provided at the next annual survey. If one or more cylinders fail, a total of 50% of the onboard cylinders should be tested. If further cylinders fail, all cylinders should be tested.100% of the cylinders are to be subject to a hydrostatic test at the intermediate or renewal survey coinciding with the cylinders reaching 20 years of age and every 10-year anniversary.

For Existing ships with high-pressure cylinders of age 20 or more years:

At the previous 10-year anniversary, at least 10% of high-pressure cylinders have been subject to an internal inspection and hydrostatic test. All cylinders, which were not subject to a hydrostatic test during the previous 10-year period, are to be hydrostatically tested latest at the next intermediate, renewal or scheduled drydock survey, whichever comes first.

100% of the cylinders are to be subject to a hydrostatic test at the intermediate or renewalsurvey every 10-year anniversary thereafter.

Cargo Ship Safety Radio Certificate

Passenger Ship Safety Certificate

Others

IP Code

(Circular CAM 01/2024)

Grandfathering provisions for obtaining IP certification are provided in the SOLAS Chapter XV, Regulation 3 for existing cargo ships and high-speed cargo craft which prior 1 July 2024 have been authorized by the Administration to carry more than 12 industrial personnel based on the Resolution MSC.418(97).

Vessels which currently (and within 1 July 2024) do not operate with more than 12 industrial personnel, and which have no specific authorization from the Administration to do so, will not be covered by the grandfathering provisions, and hence they have to be certified with respect to the complete IP Code to obtain an Industrial Personnel Safety Certificate.

Documentary evidence of compliance with MSC.418(97) will be necessary in order to benefit from the grandfathering provisions of the SOLAS Chapter XV, Regulation 3. Due to this fact, ship owners and ship operators of vessels under Luxembourg flag carrying more than 12 industrial personnel are kindly requested to seek authorization in accordance with Resolution MSC.418(97) prior the IP Code comes into force. All such applications shall be made through Recognised Organisation (RO) and the Administration shall be informed accordingly in each case. Recognised Organisation (RO) shall issue a Statement of Compliance (SoC).

Should any other standard than what is specified in MSC.418(97) be considered, a prior approval from the Administration shall be sought and same shall be also reflected in the SoC.

(Administration email dated 08/05/20224)

With regards to item 6 of the Annex to MSC.418(97): industrial personnel may be carried on boards ships meeting the provisions of the 2008 SPS code or other standards, providing they meet an equivalent level of safety acceptable to the Administration, taking into consideration the number of persons on board.In this context, the Administration may consider A.534(13) (1983 SPS Code) as a standard meeting an equivalent level of safety to that of the 2008 SPS Code, for vessel’s keel laid before 13/05/2008.Nevertheless, one difference between the old Code (1983 SPS Code) and the new 2008 SPS Code is how the requirements are applied. The old Code (1983 SPS Code) has thresholds depending on number of special purpose personnel onboard (at 50 and 200 special personnel), whereas the 2008 SPS Code has thresholds depending on total number of persons onboard (at 60 and 240 persons). For each category, the degree of SOLAS passenger ship requirements imposed to the vessels are enhanced.Due to the above thresholds, for existing vessels certified according to the old Code (1983 SPS Code) for a maximum of 50 special personnel, there are vessels that may not be considered as having an equivalent level of safety to the 2008 SPS Code. This relates to vessels with a substantially larger total person onboard number compared to the number of special personnel onboard.This may also be seen in relation to the requirements of the new SOLAS Reg. XV/3.2 where it is required that vessel covered by the grandfathering shall meet the IP Code regulations III/1, III/2 (except for paragraph 2.1.7), IV/7 and IV/8.

Example:

• A vessel with load line length below 85 m, certified according to IMO Res. A.534(13) (1983 SPS Code) for a maximum of 50 special personnel and a total POB of 90 will normally be arranged with LSA arrangement with liferafts and rescue boat only, according to SOLAs Reg. III/31.1. With reference to IP Code Reg. IV/7 as mentioned above, this vessel would most likely need to reduce to 60 POB when operating in IP mode, due to the requirements of IP Code Reg. XV/7.

• If the same vessel had load line length above 85 m, the vessel would be provided with LSA arrangement including lifeboats according to SOLAS Reg. III/31.1. With respect to IP Code Reg. XV/7, the vessel could comply with SOLAS passenger ship requirements to LSA provided the installation of an additional rescue boat, davit launching of the liferafts and personal LSA (SOLAS Reg. III/21.1).

• However, the vessel would still have stability as for a cargo vessel and remain with a deviation from some of the stability requirements in the 2008 SPS Code for vessels with more than 60 persons on board.

Therefore, a gap analysis (2008 SPS Code against 1983 SPS Code) has to be carried out in order to demonstrate that 1983 SPS Code provides an equivalent level of safety as the 2008 SPS Code. This gap analysis has to be performed for each vessel individually due to their different scope of certification as demonstrated on the before mentioned example.

The gap analysis has to be carried out, reviewed and analysed by Recognised Organisation (RO) and then submitted to the Administration, including eventual Recognised Organisation (RO) proposal(s) for equivalent arrangement(s) in order to meet the required equivalent level of safety.

MARPOL 73/78

Use of Electronic Record Books (ERB) for MARPOL Related Record Keeping

(Circular CAM 009/2019)

This circular will be applicable from 01 October 2020. Using ERB before this date, may do so in parallel with the present MARPOL requirements, but must already follow the instructions and requirements described in this circular.

The Administration encourages and will accept the use of electronic record books (e-RBs) on board of Luxembourg flagged vessels for record keeping requirements related to the International Convention for the Preventions of Pollution from Ships (MARPOL Convention).

When e-RBs are used on board a Luxembourg flagged vessel, the guidelines provided in Resolution MEPC.312(74) must be followed.

ROs authorized by the Commissariat aux affaires maritimes will assess the electronic record book against the prementioned guidelines and will issue a declaration for the purpose of regulatory surveys or inspections.

For further information, refer to attached file “009 Use of EORB.pdf”.

Annex VI

Data Collection System for Fuel Oil Consumption of Ships

(Circular CAM 004/2018 Rev.2)

Recognised Organisation (RO) is authorized to perform the following statutory services:

• Reviewing of SEEMP Part II and issuance of Confirmation of Compliance, (MARPOL Annex VI, Regulation 5.4.5)

• Verification of reporting data, (MARPOL Annex VI, Regulation 22A) and Issuance of Statement of Compliance (MARPOL Annex VI, Regulation 6)

• Submission of reported data to the IMO Ship Fuel Oil Consumption Database ((MARPOL Annex VI, Regulation 22A.9)

For further information, refer to attached file “004 IMO DCS Rev 2.pdf”.

EEXI and CII

(Administration email dated 12/07/2022)

The Administration confirms that the EEXI verification, the EEXI technical file, the EEXI calculation as any other technical requirement in MARPOL which requires survey and certification must be submitted to the RO that classes the vessel.

The involvement of another RO than the RO that classes the vessel may lead to misunderstandings and delays in certification process.

Engine Power Limitation (EPL) / Shaft Power Limitation (ShaPoLi) system - IACS Rec. 172

(Administration email dated 24/10/2022)

The Administration confirms acceptance in principle of IACS Recommendation No. 172 - EEXI Implementation Guidelines.

The Engine Power Limitation (EPL) / Shaft Power Limitation (ShaPoLi) system has to be an integral part of the class approved system and also has to be in accordance with MEPC.335(76).

Furthermore, the following shall be observed:

• Recognised Organisation (RO) accepts the related Engine Power Limitation (EPL) / Shaft Power Limitation (ShaPoLi) system as in line with its class rules and regulations.

• the ship's crew is fully responsible for the operation of the Engine Power Limitation (EPL) / Shaft Power Limitation (ShaPoLi) System and is operating the system by following the manufacturer manuals, recommendations and service intervals.

A respective remark has to be documented in the Recognised Organisation (RO) survey report.

BWM Convention

De-harmonization of the IOPP survey

(Refer also to the attached file “Circular CAM 10_2016.pdf”)

Luxembourg is presently finalizing the BWMC ratification procedure and strongly encourages owners to fulfill the requirements of the BWMC as early as possible.

CAM (“Commissariat aux Affaires Maritimes”) will not object to the principle of the IOPP renewal survey to be adjusted so that it is “de-harmonized” with the other renewal surveys carried out under the HSSC Guidelines.

Owners wanting to take advantage of this possibility must introduce a special request with a well-founded and documented justification for a case by case examination by the vessel’s RO (Recognised Organisation (RO)).

On the basis of the Recognised Organisation (RO) positive report, CAM will confirm its principle agreement and authorize Recognised Organisation (RO) to perform a renewal survey for IOPP for the vessel and to issue a new full term IOPP certificate with a 5 year validity upon satisfactory completion of the said survey.

Owners are invited to reintegrate the IOPP survey into the HSSC at the earliest opportunity.

Recognised Organisation (RO)'s positive report" to CAM is to be worded as follows: "In accordance with Circular CAM 10/2016 underlining that CAM has no principle objection to IOPP deharmonisation, Recognised Organisation (RO) has, for the subject ship XXXXXX, no objection to IOPP de-harmonisation. Recognised Organisation (RO) asks CAM to confirm its agreement and authorization for the subject ship".

Re-harmonization of IOPP surveys

(Email from the Administration dated 18/08/2017)

The Administration does not object in principle to the re-harmonisation of the IOPP certificates. This matter must be planned together by the Company and the RO.In order to monitor the status of the ships flying the Luxembourg Flag, the Administration is to be updated if an whenever any action is taken.

Unmanned vessels that discharge ballast water to reception facility

Discharging the ballast water to a port facilities shall be described as an option in the BWM Plan.

The Statement of Compliance is to indicate in accordance with Regulation D-2 and the method shall be described as free text in the BWM SOC: “Discharge only according to approved BWM plan”.

However, the Administration regards the certification of the D-1 standards as a feasible option.

If the ballast water was discharged to a reception facility, it is to be entered in the BWM Record Book.

Commissioning test

(Email from the Administration dated 10/03/2022)

According to MEPC.325(75), the Reg. E-1, par. 1.1 as amended with a requirement for a mandatory commissioning test (sampling and biological analysis) applies from 01/06/2022 and shall not apply retroactively to already commissioned BWMS (survey completed before 01/06/2022).

If the commissioning survey is completed before 01/06/2022, then no commissioning test (sampling and biological analysis) is required.Only in case there is later a change, replacement, or significant repair of the structure, equipment, systems, fittings, arrangements and material necessary to achieve full compliance with the BWM Convention then a commissioning test (sampling and biological analysis) will be required at “additional survey” according to Reg. E.1 par. 1.5. Nevertheless, considering that the Administration is not in the possession of information relating to any imposed national/local requirements, therefore encourage the maritime companies to do the commissioning test by sampling and this in order to avoid any future PSC issues.

Miscellaneous Technical Requirements

European Marine Equipment Directive 96/98/EC

Refer to Statutory surveys - General, Sections 7 & 8.

Newbuilding vessels and change of flag

(Email from the Administration dated 01/04/2022 and 06/07/2022)

Recognised Organisation (RO) is requested to issue a MED Statement of Compliance for any newbuilding vessels as well as for any vessel after change of flag to Luxembourg. A copy is to be forwarded to the Administration.

All newbuilding vessels constructed under Luxembourg flag are expected to be in full compliance with the latest Maritime Equipment Directive.

In case of MED non-compliance, a detailed list of MED non-compliant equipment should be established including reference to the equivalent certification and submitted to the Administration for approval.

A template, approved by the Administration, is available in the attached files: LUXEMBOURG_MED_Statement of Compliance.docx

Ships fitted with Dynamic Positioning Systems

(Circular CAM 03/2020)

The Administration recommends the use of the current Guidelines (MSC.1/Circ.1580) for vessels and units constructed on or after 9 June 2017.For vessels and units constructed on or after 1 July 1994 but before 9 June 2017, the previous version of the Guidelines (MSC/Circ.645) may continue to be applied, however the Administration recommends that section 4 (operational requirements) of the new Guidelines be applied to all new and existing vessels and units as appropriate.

In any case, should a “Flag State Verification and Acceptance Document“ (FSVAD), based on MSC/Circ.645, or a “Dynamic Positioning Verification Acceptance Document”, based on MSC.1/Circ.1580, be required, Companies are invited to contact their ROs for issuing such document on behalf of the Grand duchy of Luxembourg.

These documents will be valid for a period of five years and the equipment is subject to annual verification by the RO of the ship.

For further information, refer to the Circular CAM 03/2020 in the attached file “Circular CAM-03_2020.pdf”.

National legislation

Unofficial English translations of the following texts are available on the Administration website:

• Technical Regulations applicable to commercial cruise ships under 24 meters in length http://www.maritime.lu/sites/maritime.lu/files/files/pdf/technical-regulation-ships-under-24m.pdf

• Technical Regulations applicable to ships of 24 meters length or above, displacing less than 500 tons and carrying a maximum of 12 passengers http://www.maritime.lu/sites/maritime.lu/files/files/pdf/technical-regulation-ships-more-24m-less-500t.pdf

Ship Recycling and IHM

EU Regulation No 1257/2013

Recognised Organisation (RO) is fully authorized to carry out survey and issue a Certificate on Inventory of Hazardous Material in accordance with Regulation (EU) No.1257/2013 on Ship Recycling.

(Circular CAM 012/2018 Rev 1)

Recognised Organisation (RO) can offer related certification services on behalf of Luxembourg flagged vessels even for vessels that are not classed with Recognised Organisation (RO).

For further information, refer to the attached file “Circular CAM 012-2018 rev1.pdf”.

(Circular CAM 05/2020)

With reference to the European Commission’s guidelines “Guidelines on the enforcement of obligations under the EU Ship Recycling Regulation relating to the Inventory of Hazardous Materials of vessels operating in European waters”, it is possible for owners to take the necessary arrangements to have their ships provided with an approved Inventory Certificate or Ready for Recycling Certificate (that does not contain on-board sampling) based on a semi-completed IHM.

In this case, owners have to approach the Administration, as evidence of flag State’s agreement will need to be provided to the PSCOs. For the Administration to be able to confirm its acceptance of this, owners will need to provide plans and arrangements indicating when it will be feasible for qualified samplers to complete the IHM with respect to limitations caused by the Covid-19 pandemic.

Owners are requested to inform the Administration and the relevant classification society if they operate a ship that will not be able to fully comply with the requirements of the EU Regulation upon entry into force. In doing so, they must provide the above mentioned evidences and eventually request the authorization to have a semi-completed IHM completed.

For further information, refer to the attached file “Circular CAM 05-2020.pdf”.

(Administration email dated 09/04/2026)

Since Luxembourg has ratified the Hong Kong International Convention, vessels registered under the Luxembourg flag are eligible to obtain an International Certificate in accordance with the Hong Kong Convention.

The Administration therefore recommends implementing the new combined International/EU Certificate as per Commission Implementing Decisions (EU) 2026/116 and 2026/121 at the vessel’s next scheduled IHM Renewal Survey, but no later than 26 June 2030, or prior to the ship’s recycling, whichever comes first.

Hong Kong Convention

(Circular CAM 012/2018 Rev 1)

Circular CAM 012/2018 is applicable and Recognised Organisation (RO) can offer related certification services on behalf of Luxembourg flagged vessels even for vessels that are not classed with Recognised Organisation (RO).

For further information, refer to the attached file “Circular CAM 012-2018 rev1.pdf”.

(Circular CAM 03/2025 and Annex)

1. Replacement of Existing Statement of Compliance on IHM

For IHM Statements of Compliance with the Hong Kong Convention issued on behalf of Luxembourg, Recognised Organisation (RO) is requested to replace the SoCs with International Certificates, at the latest, upon completion of the Renewal Surveys for other statutory certificates (referred to as “R.S.” in the attached file Annex to Circular CAM 03/2025) on or after the entry into force of the Hong Kong Convention (26 June 2025); and upon request from Owners, taking also into consideration the harmonization of the validity of statutory certificates as per 2. below.

2. Harmonization of the validity of statutory certificates

The Administration agrees to offer the following option to harmonize the validity of the International IHM Certificates with other statutory certificates for Owner’s choice.The proposed method is detailed in the attached file Annex to Circular CAM 03/2025. In accordance with Regulations 10.1.2, 11.5, 11.3 as well as 10.5 of the Annex to the Convention, Recognised Organisation (RO) is hereby authorized to:

• conduct an IHM Initial Survey (and issue an HK International Certificate on IHM) prior to (or at least until) the first Renewal Survey for other statutory certificates (referred to as “R.S.” in the attached file Annex to Circular CAM 03/2025) after the entry into force of the Hong Kong Convention; and

• when the R.S. comes around, an IHM Renewal Survey is conducted to harmonize with other statutory surveys, so that the validity of the certificates will also be harmonized.

Lithium Battery Fire Extinguisher

(Circular CAM 04/2025)

The Administration highly recommends the carriage of MED-approved Lithium Battery Fire Extinguishers for the Luxembourg flagged vessels having such batteries on board.

Recognised Organisation (RO) should be consulted for additional assistance in this matter, since the number and location of needed extinguishers will depend of the number and location of Lithium devices carried on board.

A proper Lithium Battery Fire risk assessment, updated Fire Fighting procedures, a reviewed Fire Safety plan and adequate familiarisation of the crew with this particular Fire Fighting Equipment shall be done, documented and recorded accordingly.

TONNAGE 69

Tonnage Certificate

Vessel less than 24mts

(Administration emails dated 09/04/2019 and 03/05/2019)

ITC69 is applicable to all vessels by the Luxembourg Maritime administration and this regardless of their Lpp (> 24 mts or < 24 mts).

Recognised Organisation (RO) is authorized to issue an International Tonnage Certificate for vessels less than 24mts, if and when requested.

The mention “NON CONVENTION” will be added on the certificate in order to avoid confusion in case of change of flag.

COLREG 72

Exemption certificate

(Administration email dated 23/01/2024)

The Administration agrees with the implementation of COLREG exemption certificates (see also Exemptions).

A dedicated form “COLREG Exemption Certificate” is available in ASMS2/National Certificate.

Existing COLREG exemptions, which were indicated on standard SOLAS exemption form (under the Safety Equipment certificate), are to be checked by the Recognised Organisation (RO) surveyor at the next renewal survey, and are to be re-issued using the dedicated form “COLREG Exemption Certificate”.

ISM Code

Authorizations and Instructions

ISPS Code

Authorizations and Instructions

Additional requirements

(Circular CAM 005/2017)

The following procedures are reminded to RSOs:

1. Procedure to follow in the case of a ship changing flag to Luxembourg

   When a ship changes flag to Luxembourg, section A 19.2.1 of the ISPS Code has to be followed. Therefore, an International Ship Security Certificate (ISSC) may not be issued on the basis of the initial verification done for the previous flag. In this case, only an interim ISSC can be issued, even if the company remains unchanged.

2. Verification and Certification of Ships

   In accordance with section A 19 of the ISPS Code, an ISSC can only be issued if all identified failures identified during the verification have been rectified to the satisfaction of the RSO.

For further information, refer to attached file “005 RSO_instructions”.

MLC, 2006

Scope of authorisation

Extracts from procedure for shipowners to obtain the DMLC Part I and the Maritime Labour Certificate

In accordance with MLC 2006 requirements, the DMLC Part I will be issued by the Government Commissioner for maritime affairs. Shipowners are requested to prepare the DMLC Part II for each of their ships and to organize their certification through the Recognized Organization (RO).

After completion of the ship’s inspection, the RO will issue an Interim or a Maritime Labour Certificate with limited validity period on behalf of the Government of Luxembourg. The full term certificate will be issued by the Government Commissioner for maritime affairs at a later stage and as soon as the relevant information has been received.

Request for the DMLC Part I

Step 1: Shipowners should perform a gap analysis of the ship and the company policies against the national provisions of Luxembourg outlined in the DMLC Part I;

Step 2: Any areas of concern, such as where an equivalency/exemption may be considered, shall be brought to the attention of the Government Commissioner for maritime affairs for evaluation.

Step 3: A formal request for the issuance of the DMLC Part I must be prepared by the shipowner and sent to the Government Commissioner for maritime affairs, detailing the following information for each vessel:

1. Vessel’s name;

2. IMO number;

3. Gross tonnage;

4. Keel laying date;

5. Type of ship;

6. Trade: international or coastal (with description);

7. Details of the crew of board (crew list);

8. Any equivalencies as may have been granted by the previous Flag State (indicate “none” otherwise);

9. Any exemptions that may have been granted (before 20^th August 2013) by the previous Flag State or by the Government Commissioner for maritime affairs (indicate “none” otherwise);

10. Any exemptions that have been requested or may have been granted (after 20^th August 2013) by the previous Flag State or the Government Commissioner for maritime affairs (indicate “none” otherwise);

11. RO selected for MLC 2006 (with email address);

12. Address of the shipowners to where the original DMLC Part I needs to be sent.

Step 4: The DMLC Part I is issued by the Government Commissioner for maritime affairs; a PDF copy is emailed to the shipowner and the selected RO for MLC matters, while the original document will follow in due time.

Issuance of an Interim Maritime Labour Certificate

Interim Maritime Labour Certificates may be issued for newbuildings or existing ships if one or more of the following conditions is / are applicable:

• New ship on delivery;

• New ship to the company;

• Ship changing flag to Luxembourg.

Existing vessels, not falling under any of these categories, shall not be required to undergo an interim certification.

At the time of the interim inspection, the DMLC Part I and DMLC Part II are not required to be on board.

Issuance of the Maritime Labour Certificate

A Maritime Labour Certificate as well as a DMLC shall be issued to ships of 500 GT or more, to which the convention applies, following a successful initial onboard inspection. The Maritime Labour Certificate confirms that both the working and living conditions have been inspected and verified to meet national legislation implementing the MLC.

Ships below 500 GT are subject to an inspection at intervals not exceeding three years, although no obligation exists to issue a certificate. One has to note however that shipowners may request a certificate on a voluntary basis. It is strongly recommended that ships below 500 GT are issued with a certificate in order to simplify matters involving Port State Control inspections and to avoid undue delays in ports.

Step 1: Upon the reception of the DMLC Part I from the Government Commissioner for maritime affairs, the DMLC Part II shall be prepared by the shipowner.

Step 2: Upon the completion of the DMLC Part II, the ship inspection process for issuance of the Maritime Labour Certificate shall be arranged by the shipowner with the RO. This process may include some preparatory documentation review ashore prior to the onboard inspection. The interim Maritime Labour Certificate, issued by the RO, shall have a maximum period of validity of six (6) months.

The RO shall forward as soon as possible a copy of the Interim Maritime Labour Certificate, the DMLC Part I, the DMLC Part II and the inspection report / inspection log to the Luxembourg Maritime Administration.

Step 3: Once notified by the RO that the ship fulfils the Luxembourg National provisions, a Maritime Labour Certificate valid for five (5) years will be issued by the Government Commissioner for maritime affairs.

This certification process shall be finalized before the expiration of the interim certificate.

Both the original of the DMLC Part I (issued by the Government Commissioner for maritime affairs) and the DMLC part II (completed by the shipowner and approved by the RO) shall be placed on board together with the Interim Maritime Labour Certificate (issued by the RO) or the full term Maritime Labour Certificate (issued by the Government Commissioner for maritime affairs).

Specific Requirements

MLC 2006 certification of ships of 200GT and more

(Circular CAM 04/2015)

MLC 2006 certification of all ships of 200GT and more is mandatory.The procedure for the certification is similar to the one for ships of more than 500GT. The Flag State Inspection checklist is attached (see file “004 ANNEX CheckList Commercial Yachts +24m_Rev 012015.pdf”) and shall be used for all flag state inspections on board of Luxembourg flagged commercial yachts above 24m.

For further information, refer to attached file “Circular_CAM_04-2015.pdf”.

Amendments (2018) to the Maritime Labour Convention (2006)

(Circular CAM 009/2020)

These Amendments entered into force on 26th December 2020.

Theydo not require any immediate changes to a Luxembourg DMLC Part I, nor to already issued Luxembourg Maritime Labour Certificates.

Nevertheless, Shipowners will have to comply with the new provisions once into force and be able to document their correct implementation on-board of all Luxembourg flagged ships to which the convention applies and to ensure ongoing compliance.

A new DMLC part I will be issued by the Government Commissioner for maritime affairs on request.

For further information, refer to the attached file “MLC amendements 2018_v1.pdf“.

MLC inspection report

(Administration letter in attached file “TO WHOM IT MAY CONCERN to ALL ROs_Signing MLC Inspection Reports”)

With reference to the requirement under Mémorial A — N“ 95 du 4 juin 2015, Chapter III, Section 2, Article 18, to have every inspection report of MLC inspections signed by both the MLC inspector, who conducted the inspection, and the Master of the vessel.

As this requirement is implied for a paper version of the MLC inspection report, the Administration confirms that for an electronic version of the report, it may be signed electronically by the attending MLC inspector only. However, the MLC inspector shall hand over the inspection report to the Master and verbally explain the content at the closing meeting. In case of no objection, the Master receives the inspection report. Should the Master disagree with the inspection findings, a respective remark needs to be included in the MLC inspection report by the attending MLC inspector.

Appendix — Agreement concerning surveys and certification

Agreement

See the attached files:

• “Agreement”.

• “Amendment_RO_Luxembourg_01012017”

• “Amendment_Luxembourg_RO SA_23102020”

Appendix — Annex 1 to the Agreement

Applicable instruments and degree of authorisation

See the attached file “Annex 1_Luxembourg_RO SA_22032023”.

Appendix — Annex 2 to the Agreement

Reporting to the Administration

See the attached file “appendix 2 to the agreement”.

Appendix — Commercial yachts under 24 metres in length

Untitled

See the attached file “Commercial yachts under 24 metres in length”.

Appendix — ISM audit check-list

Untitled

The auditor committed to the audit for the issue of a Document of Compliance and/or a Safety Management Certificate must ensure that the Safety Management System conforms with the points of the Luxembourg Maritime Law given below:

Appendix — Specific Certificates: National and bilingual International certificates

List of National certificates

- COLREG Exemption Certificate