After Brexit changes for UK flagged vessels operating in German waters

Vessels flying a non-EU flag (except Norway) generally require a Cabotage Approval when operating in German waters.

After the Brexit this regulation also applies to UK flagged vessels operating in German waters.

Cabotage is the fee-based carriage of passengers or goods with a foreign-flagged vessel from one place to another within German territory using German coastal waters (12 nautical mile area).

Shipping companies do not require a Cabotage Approval if their ships

• carry goods or passengers to places outside coastal waters (12 nautical mile zone) – for example to offshore wind farms in an Exclusive Economic Area or

• do not carry goods or passengers for a fee, as for example is the case with assistance tugs in a port.

Vessels flying an EU flag are not required a Cabotage Approval.

The Cabotage Approval is often understood to be the same as the Certificate of Equivalence (CoE). However, they are actually two different documents with different purposes. Cabotage is about counteracting disadvantages for the freedom of economic activity of German shipping while the Certificate of Equivalence ensures a comparable degree of safety of all vessels operating in German maritime waters.

The Cabotage Approval is being issued by the German Authorties.

Aggravation in application for German Certificate of Equivalence

Due to a high amount of new applicants and some amendments BG Verkehr has made for foreign vessels applying for a German CoE, the requirements to receive a CoE have become stricter and higher.

Especially for vessels that have just been Coded under MCA Workboat (or Brown Code) and have not been further classed by a classification society the German Authorities tightened the requirements and are

interpreting the regulations stricter than before which might even lead to major structural modifications.

Whereas formerly only certificates have to be handed in completely prior to an inspection, currently these documents are to be scrutinized and approved by BG Verkehr before an inspection date can basically be organized and is granted. This results in high lead times for on board inspections. BG Verkehr officially states partly up to 6 weeks. Furthermore, BG Verkehr reserves their right to also check construction and system drawings prior to an inspection.

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