Categories: a-port-information, EuropePublished On: 14.03.2022365 words2 min read



MIN 674 (M) – Guidance for shipowners regarding seafarers affected by Russia’s invasion of Ukraine

This notice provides guidance on the extension of Ukrainian Certificates of Competency (CoC) in line with IMO Circular Letter No. 4232/Add. 16 (please see annex A of this Notice) and an update on UK Flag State Endorsements (FSE) for holders of a CoC issued by Ukraine.


Annex B – MTWTU’s Official Letter

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  • Under UK legislation implementing the Maritime Labour Convention, 2006 (MLC), every seafarer on a UK ship is entitled to repatriation on the expiry of their Seafarer Employment Agreement (“SEA”) or after a maximum of 11 months of continuous service on board their ship (as well as in other specified circumstances). The requirements of the MLC apply at all times, and there is no provision which allows them to be suspended under any circumstances.
  • The volatile situation in Ukraine means that it may not be appropriate to repatriate seafarers to Ukraine. In addition, restrictions on movement since Russia’s invasion of Ukraine may cause obstacles when repatriating seafarers. The MCA also notes that Ukrainian seafarers may not wish to return home in these circumstances.
  • While recognising the exceptional obstacles in the current situation, as a flag State which has ratified the MLC, the UK has a legal obligation to protect the living and working conditions of seafarers and fishers on its ships.
  • This notice therefore requires shipowners of UK ships to notify the MCA of any seafarers remaining on board beyond the maximum period.
  • This notice reminds shipowners of MLC guidance for seafarers on entering war zones.
  • The MCA recognises that seafarers from other nationalities may also be affected, this notice also sets out guidance for other seafarers affected by the conflict.
Published 11 March 2022
MTWTU’s Official Statement on Crew Changes of Ukrainian Seafarers