1. International Group of P&I Clubs Comments and clarifications on the evidence of the existence of insurance coverage as required by the Insurance Directive Naples 8 October 2012

2. The International Group General observations from an IG perspective:  EU Insurance Directive text agreed in April 2009 is very different to the original Commission proposal tabled in November 2005  Implementation of the Directive should not be complicated or difficult  No significant problems have arisen for the IG Clubs since implementation effective date of 1 January 2012  Not all EU Member States have yet given effect to the Directive 2

3. The International Group Explanations:  IG has, directly or indirectly, liaised with every single EU Member State on implementation since the Directive was agreed in April 2009  Most owners already maintain third party liability insurance cover  Key provisions of the Directive reflect existing IMO Guidelines: Article 3 (1) of Directive/Article 1.2 of IMO Guidelines: “ Insurance means insurance with or without deductibles, and comprises, for example, indemnity insurance of the type currently provided by members of the International Group of P&I Clubs, and other effective forms of insurance (including [proved] self-insurance) and financial security offering similar conditions of cover”. 3

4. The International Group Position of EU Member States:  Acceptance of IG cover – Article 3 (1)  Acceptance of IG Club issued Certificates of Entry as evidence of compliance – Article 6 (1)  Acceptance of non-IG P&I providers? 4

5. 5 The International Group of P&I Clubs Issues of Debate with States:  Scope of P&I to cover all claims subject to limitation?  Application to all seagoing vessels, seaborne craft of any type whatsoever?  Non-ratification of LLMC 96 Protocol by some EU Member States?

6. International Group of P&I Clubs