The French Department of Maritime Affairs has recently published guidance on planned changes to the French Labour Law. The changes would apply to commercial vessels under 650 GT that operate between French ports.
650GT is interesting in itself; it is not a tonnage limit that we are familiar with in the Yachting Industry or in Commercial Shipping, as most regulations are applicable to those vessels over or under 500GT.
It is unclear at this stage if all Shipowners and Management Companies operating yachts in France will be required to comply with the ruling.
If they do, Shipowners and Management Companies would need to complete a ‘Declaration of Activity’ to the Departementale des territories et de la mer [DDTM] 72 hours in advance; provide evidence of affiliation with social security institutions; provide seafarers with contact details of the French Labour inspection office and translate documents into French. Seafarers Employment Agreements may also need revising to accommodate the changes.
How this change would be implemented and controlled is unknown at this stage but it is thought that the inspections would be carried out by the French Ministry of Labour & Employment, many of who will be unfamiliar with the Yachting Industry and its Regulations.
Since 2013 the Yachting Industry has been complying with the MLC 2006 to protect seafarer’s rights through an organized framework. To impose additional requirements for vessel that operate in, or are based in France could have an impact for the Industry.
With over 4500+ yachts operating in the Mediterranean this Season, owners and shipowners of commercial vessels under 650GT will need to be mindful of the potential ramifications of the revised Labour Directives and associated cost implications.
The team at Rosemont Yacht Services & Management are continuing to monitor the situation and will provide an update to our owners and vessel’s when we have a clearer picture.