Anavre has sent us an official statement on his opinion on this matter.

In response to the communiqué issued by the General Directorate of the Merchant Navy concerning the technical consultation on "Validity of the Dutch PCI to sail in Spanish maritime waters and obligations of persons or entities resident in Spain who have their vessels in flags of another EU country."the lack of validity of the Dutch PCI as a document suitable for sailing through territorial or external waters, with emphasis on the "Dutch flag not applicable"Anavre has sent us the following statement:

It is certainly Dutch legislation that makes it impossible to use the PCI as valid for sailing outside its inland waters by eliminating the protection of the Dutch flag to the ships registered by this means, for this purpose they have the Kadaster, which is the official register of the country.

The PCI is a certificate issued under UNECE Resolution 13, which has not been ratified by the Kingdom of Spain, although the Spanish maritime authorities have been accepting and accepting this type of document as valid in our waters provided that the State that protects its issue grants them its flag, as the Netherlands was doing and continues to do Germany.

The problem already arises in 2018 when the PCI was misused by some NGO dedicated to the rescue of illegal migrants in the Mediterranean, since two of the ships dedicated to such tasks were registered by this type of document. When they were arrested by the Italian Maritime Authorities, they claimed that they were under the Dutch flag and showed PCI's, which violated the regulations, as both ships were over 24 metres and were not used for recreational purposes. The Government of the Netherlands therefore decided that the PCI issued in its country should not be attributed to the flag and that the PCI would therefore become a certificate of property valid for sailing in Dutch inland waters.

Portugal stopped admitting it as a valid document two years ago, as did Italy, and now our country does.

We are aware of the problem that this regulation causes to dozens of ships owned by Spanish residents who are currently registered through PCI and located in our waters.

The communiqué in no way prevents the application of any other flag whose country allows it and has a register that allows its flag, such as Poland, France, or the United Kingdom, among others, and we therefore urge those affected to start the flag proceedings in the country of their choice as soon as possible.

In order to avoid an allude of sanctions and immobilizations of ships, Anavre will proceed to ask the DGMM for a moratorium that will allow shipowners, administrators and nautical councillors to process these new flag within a reasonable time, taking advantage of the season of the year in which we are.

As for the reference on the RD on the safety regulations for foreign flag ships, the said RD is already in final stage of approval and entry into force, and we have not been asked for additional contributions from the DGMM, which has already taken on many of the proposals made by the nautical community at the time.