Information, not advice: Phinisi Owner is an independent editorial guide — not a shipyard, broker, surveyor, or licensed adviser. Costs and regulations change and every vessel differs; verify figures with yards, independent surveyors, and licensed Indonesian counsel before committing money. If you engage a partner we introduce, that partner may pay us a referral fee at no cost to you.
Boat registration in Indonesia is governed by the Directorate General of Sea Transportation (Ditjen Perhubungan Laut, commonly called Ditjen Hubla) under the Ministry of Transportation. For a phinisi operating commercially — carrying paying guests on routes in Komodo, Raja Ampat, or anywhere in the archipelago — registration is not a single document but a layered certification stack. Getting one certificate without the others does not make a vessel legally operable for charter. This page sequences that stack in the order you actually need to complete it.
A note before we start: Indonesian maritime regulations change with some regularity. Law 17/2008 on Shipping was amended in 2024 (Law 66/2024), and fee schedules at the Harbour Master’s Office (Syahbandar dan Otoritas Pelabuhan, KSOP) are set by government regulation that is updated periodically. Every fee or processing-time figure in this page should be verified against current tariffs at your local KSOP or Ditjen Hubla office before you act on it. Nothing here is legal advice; engage qualified Indonesian maritime counsel for your specific transaction.
Why the Stack Matters: What “Fully Compliant” Actually Means
Tour operators marketing phinisi vessels routinely describe them as “fully certified” or “fully compliant.” Those phrases are not definitions. A vessel can hold a grosse akta (ownership deed) without ever having been measured for tonnage. It can have a tonnage certificate without holding a current passenger safety certificate. The compliance conversation is meaningless unless someone specifies which certificates, issued by which authority, and when they were last renewed. The stack has seven distinct layers, and most charter phinisi operate somewhere in the middle of it — a fact that matters for insurance, for liability, and for what happens if the Syahbandar boards your vessel at Labuan Bajo.
The Registration and Certification Stack: Process Order
The sequence below reflects the logical dependency order — you cannot apply for later certificates without completing earlier ones. Actual processing may overlap at the KSOP level, and requirements can vary by vessel GT class. The flowchart summary is below the table.
Step 1: Grosse Akta Kapal — The Ownership Deed
The grosse akta kapal (also written “gross akta” informally) is the primary vessel ownership instrument under Indonesian law. It is the maritime equivalent of a land title. The deed is issued by the Ditjen Hubla ship registry and must be held by the registered owner — which, for a commercial phinisi, must be an Indonesian entity (see the cabotage and foreign-ownership section below).
To register a vessel and obtain the grosse akta, you typically need proof of construction or purchase (builder’s certificate or bill of sale), identification of the owner entity, and payment of the applicable registration fee. For vessels that have changed hands informally — as many older phinisi have — the ownership chain recorded on the existing grosse akta may have gaps. Stale or broken ownership chains are one of the more common title problems in the used-phinisi market. A maritime lawyer should trace the chain before any purchase is finalized. Undischarged liens on the grosse akta are also a real risk, though Indonesia does not maintain a publicly searchable ship mortgage registry equivalent to some other jurisdictions.
The pas besar kapal is the vessel’s nationality document — the equivalent of a flag certificate — issued alongside or after registration for vessels above a certain GT threshold. For smaller vessels, the pas kecil applies. For most commercial liveaboard phinisi (typically 30–50+ GT), the pas besar is the relevant instrument.
Step 2: Surat Ukur Kapal — Tonnage Measurement Certificate
Before most downstream certificates can be issued, the vessel must be formally measured and assigned a gross tonnage (GT) figure. This is recorded in the surat ukur kapal (vessel measurement letter). The measurement is conducted by a government surveyor and establishes the classification basis for subsequent safety certificates, crew manning requirements, and port dues.
GT in the Indonesian system follows international convention (it is a volume measure, not a weight). A 30-metre phinisi typically measures in the 60–120 GT range depending on freeboard and superstructure volume, though figures vary and the official surat ukur is the only authoritative number for regulatory purposes. Do not rely on broker or builder GT estimates for compliance planning.
Step 3: Company-Level Licensing — SIUPAL or SIOPSUS
A vessel certificate does not by itself authorise a company to operate a commercial shipping service. The operating entity needs a company-level licence from the Ministry of Transportation. For most charter phinisi operations, the relevant licences are:
- SIUPAL (Surat Izin Usaha Perusahaan Angkutan Laut) — sea-transport company operating licence for general domestic sea transport.
- SIOPSUS (Surat Izin Operasi Khusus) — special operation licence for vessels with a specific or limited route/purpose category.
For tourist vessels operating under KBLI code 50113 (Angkutan Laut Wisata — sea tourism transport), the applicable licence category may differ from standard SIUPAL. The sea-tourism transport classification also has foreign-equity implications: it falls under the sea-transport sector, where foreign ownership in a PT PMA is capped at 49% under the Positive Investment List (Perpres 10/2021 as amended). Get OSS (Online Single Submission) and KBLI guidance from a business-licensing consultant at the time of application — the current OSS portal requirements and minimum investment thresholds should be verified against the live system, not this page.
Step 4: BKI Classification — Biro Klasifikasi Indonesia
BKI (Biro Klasifikasi Indonesia) is Indonesia’s national classification society, operating under the International Association of Classification Societies (IACS) framework. Classification by BKI is not universally mandated for every phinisi by statute, but in practice it is effectively required for two critical purposes: commercial marine insurance and eligibility for the passenger safety certificate regime that most liveaboard operations need.
BKI classification involves a plan-approval process and survey during construction for newbuilds, or a special survey for vessels seeking class for the first time mid-life. The classification notation assigned (covering hull, machinery, and for passenger vessels, additional notations) determines periodic survey intervals — typically annual surveys plus a special survey cycle every four or five years.
For a phinisi being bought used, the first question to ask is: does it currently hold BKI class, and when was the last annual survey? A vessel that has lapsed from class faces a re-entry special survey, which on an older wooden hull can be extensive and expensive. Some older phinisi operating in the budget day-trip or open-trip market have never been classed; their insurability is accordingly limited.
Indonesian vessels may also be classed with foreign societies (Germanischer Lloyd, Lloyd’s Register, Bureau Veritas) in some circumstances, and naval architect Michael Kasten’s publicly available notes on phinisi construction reference Germanischer Lloyd structural standards and IMO stability requirements for phinisi designed to international yacht standards. For a standard Indonesian-flag commercial passenger vessel, BKI is the primary path.
Step 5: Passenger Ship Safety Certificate (Sertifikat Keselamatan Kapal Penumpang)
This is the annual operating certificate for a passenger-carrying vessel. It covers structural and equipment compliance with the passenger ship safety requirements set under Indonesian maritime regulations (which draw on the SOLAS framework, scaled to vessel size and route). The certificate is issued by the Syahbandar (Harbour Master) following an inspection, and must be renewed annually.
The inspection covers lifesaving appliances (liferafts, lifejackets, EPIRBs, flares), fire detection and suppression equipment, navigation lights, bilge pumps, and general vessel condition. For an older phinisi, these annual inspections can generate required-repair notices that must be resolved before the certificate is re-issued — creating unplanned downtime. After liveaboard safety incidents in Indonesian waters in recent years, Syahbandar inspection intensity has increased in several ports, particularly Labuan Bajo. Budget for 2–4 weeks of potential off-charter time around the annual survey cycle.
Step 6: Load Line, Radio, and Pollution-Prevention Certificates
Beyond the passenger safety certificate, a fully certificated commercial vessel carries several additional instruments:
- Load Line Certificate (Sertifikat Garis Muat)
- Establishes the maximum permissible draught markings for various operating zones and seasons. Required for vessels on domestic routes above a certain GT threshold. Determines how much freeboard the vessel must maintain when fully laden.
- Radio Station Certificate (Sertifikat Radio)
- Certifies the vessel’s GMDSS (Global Maritime Distress and Safety System) radio equipment is installed, tested, and the operator holds the relevant radio operator endorsement. Specific equipment requirements (VHF, MF/HF, EPIRB class, SART) depend on the area of operation — coastal versus offshore.
- Pollution Prevention Certificate (IOPP / Sertifikat Pencegahan Pencemaran)
- For vessels above certain thresholds, covers oil record book keeping, oily water separator installation, and sewage treatment requirements. MARPOL annex compliance in Indonesian domestic interpretation depends on vessel size — verify with your flag-state surveyor.
Step 7: Safe Manning Certificate (Sertifikat Pengawakan Minimum)
The safe-manning certificate specifies the minimum number of certificated officers and crew the vessel must carry at sea. It is issued by the Syahbandar based on the vessel’s GT, route, and passenger capacity, and references the STCW (Standards of Training, Certification and Watchkeeping) framework as applied in Indonesian regulation.
For a 30–50 GT commercial phinisi carrying passengers, a typical minimum manning requirement includes a certificated master (kapten), a certificated chief engineer, and a specified number of deck and engine ratings holding appropriate certificates. The exact numbers depend on the vessel’s safe-manning determination — which is vessel-specific and issued by the competent authority, not set by a single national table you can look up.
The Certification Stack at a Glance
| Document | Issuing Authority | Validity / Renewal | Primary Purpose |
|---|---|---|---|
| Grosse Akta Kapal | Ditjen Hubla (ship registry) | Permanent (re-issued on ownership change) | Ownership title / vessel identity |
| Pas Besar Kapal | Ditjen Hubla | Periodic renewal | Indonesian flag / nationality certificate |
| Surat Ukur Kapal | Ditjen Hubla / surveyor | Permanent (re-measured on major alteration) | Official GT and dimensions |
| SIUPAL / SIOPSUS | Ministry of Transportation (OSS) | Periodic renewal (company-level) | Authorisation to operate commercial sea transport |
| BKI Class Certificate | Biro Klasifikasi Indonesia | Annual surveys + 4–5 yr special survey | Structural/machinery fitness; insurance basis |
| Passenger Safety Certificate | Syahbandar (KSOP) | Annual | Seaworthiness for carrying passengers |
| Load Line Certificate | Ditjen Hubla / BKI | Annual endorsement | Maximum permissible laden draught |
| Radio Station Certificate | Ministry of Communication / Syahbandar | Annual | GMDSS compliance |
| Pollution Prevention Certificate | Syahbandar | Annual endorsement | MARPOL oil/sewage compliance |
| Safe Manning Certificate | Syahbandar (KSOP) | Tied to vessel/owner/route | Minimum certificated crew requirements |
Fee note: registration and certificate fees are set by government tariff regulation and are updated periodically. Do not rely on any figure quoted in a broker’s information pack or a forum post. Verify current tariffs directly with the relevant KSOP office or Ditjen Hubla before budgeting.
Registration Process Flowchart
The dependency order — each step unlocks the next — runs as follows:
- Establish ownership entity → Indonesian PT or PT PMA (majority-Indonesian) with appropriate KBLI
- Obtain builder’s certificate or bill of sale → basis for grosse akta application
- Apply for surat ukur → government surveyor measures vessel, assigns official GT
- Register vessel at Ditjen Hubla → grosse akta issued, pas besar issued, vessel entered in ship register
- Obtain SIUPAL/SIOPSUS → company-level operating authority (can proceed in parallel with vessel survey if entity is already established)
- Engage BKI for classification survey → plan approval (newbuild) or special survey (existing vessel), class certificate issued
- Apply to Syahbandar for passenger safety certificate → physical inspection, equipment verification
- Obtain load line, radio, pollution-prevention certificates → often surveyed in the same Syahbandar inspection cycle
- Apply for safe manning certificate → Syahbandar issues based on vessel characteristics; crew qualifications verified
Total elapsed time from starting the process on a new-build phinisi with no existing documentation: commonly 3–9 months for a reasonably well-documented vessel with an experienced agent. Older vessels with ownership-chain gaps, lapsed class, or incomplete prior surveys take longer. No processing time is guaranteed — verify current timelines with a licensed KSOP agent or maritime lawyer.
Ready to plan a voyage on a fully certified phinisi? Browse our independent fleet notes and reach us via our enquiry form or WhatsApp — we’ll point you to boats that can produce their paperwork on request.
The Cabotage Principle and Foreign Ownership
The cabotage rules are the legal reason that how to register a phinisi under Indonesian flag is not a simple bureaucratic question for a foreign buyer. Under Law 17/2008 on Shipping (Article 8), as strengthened by Law 66/2024, the domestic carriage of passengers in Indonesia is reserved exclusively for Indonesian-flagged vessels owned by Indonesian shipping companies. Running paying guests from Bali to Komodo on a foreign-flagged vessel is a cabotage violation, not a grey area.
An Indonesian flag requires that the vessel be owned by an Indonesian citizen, a wholly Indonesian company, or a PT PMA (foreign-invested limited liability company) that is majority Indonesian-owned. The Positive Investment List (Perpres 10/2021 as amended) caps foreign equity in sea-transport companies at 49%.
Law 66/2024 introduced a further complication for new investors: PT PMA sea-transport companies established after 28 October 2025 face new shareholding requirements and a minimum vessel size raised to 50,000 GT for SIUPAL/SIOPSUS registration under certain categories. This makes the classic “set up a 49% PMA shipping company for one phinisi” route effectively impractical for new entrants. In practice, most tourism-focused vessels are routed through the sea-tourism transport KBLI (50113) rather than the general sea-transport SIUPAL category, but the equity cap remains. The legal architecture here changes with investment-policy cycles — this is an area where maritime counsel is not optional.
Nominee arrangements — where a foreign buyer holds beneficial ownership while an Indonesian national appears as the registered owner of the company or vessel — are explicitly illegal under Investment Law 25/2007 (Article 33). Such agreements are void and expose both parties to licence-revocation risk. The “local partner holds the paperwork, we have a side letter” structure is not a workaround; it is an enforcement risk that is attracting increasing regulatory attention.
The practical structures that experienced maritime lawyers use for foreign-participation investments involve either a properly capitalised 49/51 JV with a genuine Indonesian partner, or a creditor/financier position where the Indonesian PT holds full ownership and the foreign party holds a financial instrument (loan, profit-share agreement, debenture) secured against the business rather than the vessel itself. Each structure has different tax, enforcement, and exit implications. None of this is simple, and none of it should be done without professional structuring advice.
Crew Licensing: ANT/ATT Certificates, BST, and the Foreign Staff Question
The safe-manning certificate specifies what certificates crew must hold, but the underlying requirement is that commercial passenger vessel officers hold Indonesian competency certificates issued under the STCW framework as administered by the Ministry of Transportation.
Officer Certificates: ANT and ATT
Indonesian deck officer certificates are issued in five grades: ANT I through ANT V (Ahli Nautika Tingkat — Nautical Officer Level). ANT V is the entry-level deck officer ticket, qualifying a holder to serve as an officer on smaller vessels; ANT I is the senior qualification for master of large vessels on international voyages. The equivalent series for engineer officers is ATT I through ATT V (Ahli Teknika Tingkat).
For a typical 30–50 GT commercial phinisi, the master will hold at least ANT IV or ANT III depending on the vessel’s GT and route. The safe-manning certificate for the specific vessel specifies the minimum certificate level required for each position — the operator should be able to produce both the certificate and the safe-manning document together for verification.
Limited exemptions exist for foreign nationals to serve as master or chief engineer, particularly on vessels operating international routes or under special circumstances approved by the Directorate General. These exemptions are not common in the domestic charter-phinisi market and should not be assumed without specific regulatory confirmation.
BST: Basic Safety Training for All Crew
All crew serving on a commercial vessel — including deckhands, cooks, and crew without officer qualifications — must hold a BST certificate (Basic Safety Training), which covers personal survival techniques, fire prevention, elementary first aid, and personal safety and social responsibility. BST is an STCW requirement and is routinely checked in Syahbandar inspections.
Crew who cannot produce a valid BST certificate are technically non-compliant crew. On a 12–16 person crew phinisi, even one or two non-compliant crew members creates a potential inspection issue. Operators who work with seasonal or casual crew should have a system for verifying certificates before embarkation, not after.
Foreign Cruise Directors, Dive Staff, and the Regulatory Grey Area
This is the area where the honest answer is: the rules are not fully settled in practice, and you should flag this honestly when evaluating a vessel or operator.
Many premium phinisi liveaboards employ foreign national cruise directors, dive instructors, or naturalist guides. These staff are typically not designated as ship’s crew for manning-certificate purposes — they are carried as service personnel or under specialist staff arrangements. The Indonesian vessel’s safe-manning certificate covers the navigation and engineering functions; the foreign staff occupy positions that are not directly regulated under the maritime crew licensing framework.
This does not mean it is straightforward. Work permit requirements (KITAS, RPTKA for employing foreign nationals), immigration compliance, and the demarcation between “ship’s officer” and “tourism service staff” are all areas where the regulatory line can be tested. Reported enforcement actions against foreign dive staff operating without proper permits have occurred in Raja Ampat and Komodo areas. The correct approach is to have Indonesian maritime labour counsel review specific employment structures — not to rely on “everyone does it.”
The table below summarises the key crew certification requirements at a glance.
| Position | Required Certificate | Nationality Requirement | Notes |
|---|---|---|---|
| Master (Kapten) | ANT III or higher (vessel-GT dependent) | Indonesian national (exemptions exist but uncommon) | Safe-manning cert specifies minimum grade |
| Chief Engineer | ATT III or higher (vessel-GT dependent) | Indonesian national (exemptions possible) | Verify with safe-manning cert |
| Deck Officers | ANT IV or V (grade per safe-manning cert) | Indonesian national | — |
| Engineer Officers | ATT IV or V (grade per safe-manning cert) | Indonesian national | — |
| All ratings/deck crew | BST (Basic Safety Training) | Indonesian national | Check currency — BST has a validity period |
| Cook | BST minimum | Indonesian national | — |
| Foreign cruise director / dive guide | No ANT/ATT required (not ship’s officer) | Foreign national possible; KITAS/work permit required | Regulatory grey area — get specific legal advice |
NCVS Certification and the Domestic Passenger Vessel Framework
The term “NCVS certification” (Non-Convention Vessel Standard) appears in discussions of phinisi certification, particularly in the context of vessels that do not reach the size thresholds for full SOLAS convention application. Indonesia’s domestic passenger vessel certification regime for smaller commercial vessels draws on the NCVS framework — essentially a set of safety standards for vessels below the SOLAS convention thresholds — adapted into national regulation.
For most charter phinisi (under 500 GT, on domestic routes), the relevant standards are applied through the national passenger-vessel safety certificate system administered by the Syahbandar, with BKI surveying for classification purposes. A vessel described as having “NCVS certification” should be able to produce the specific certificate with its issuing date and the surveying authority. If an operator cites “NCVS compliance” without being able to show the actual passenger safety certificate from the Syahbandar, treat that claim as unverified.
Practical Due Diligence: Documents to Request and Check
Whether you are buying, chartering long-term, or evaluating a management arrangement, the following is the document set that a properly certificated charter phinisi should be able to produce on request. Inability to produce any of these — or excessive delay in producing them — is a material compliance signal.
- Grosse akta kapal — original or certified copy; verify owner name matches the operating entity
- Pas besar kapal — current and not expired; verify vessel name, GT, and owner match other documents
- Surat ukur kapal — verify GT figure matches what is declared in manning and safety certificates
- BKI class certificate — verify classification notation, survey status, and next survey due date
- Annual survey endorsement from BKI — confirm it is current year and not lapsed
- Passenger safety certificate — issued by Syahbandar, verify issue date and validity period
- Load line certificate — current endorsement
- Radio station certificate — current
- Safe-manning certificate — specifies minimum crew numbers and certificate grades; verify it matches actual crew on board
- SIUPAL or SIOPSUS — company-level sea-transport operating licence in the name of the operating entity
- Crew certificates — ANT/ATT grades for officers, BST for all crew; cross-check against the safe-manning minimum
For a purchase, add the ownership transfer documentation and instruct a maritime lawyer to verify there are no undischarged liens or encumbrances recorded against the grosse akta. The Indonesian ship registry is not a fully digitised public system; a lawyer who works in the relevant port registry (Benoa, Makassar, Jakarta, or wherever the vessel is registered) can conduct a manual check.
Costs: What We Can and Cannot Tell You
Registration and certification fees are set by government tariff regulation that is updated by ministerial decree. Published fee schedules online — including on some government portals — are frequently out of date. Agents who handle registrations routinely bundle unofficial facilitation fees into their quoted all-in prices, which makes comparing quoted prices difficult. The only reliable way to know current official tariffs is to ask the relevant KSOP or Ditjen Hubla office directly, or to work with a licensed maritime agent who can produce the official tariff schedule.
What we can say is that the cost of getting a new phinisi fully certificated from scratch — including the BKI classification survey, all Syahbandar certificates, registration at Ditjen Hubla, and initial SIUPAL application — is commonly described by operators as running into “several thousand to tens of thousands of dollars” in total, with annual renewal costs for the ongoing certificate portfolio in addition. One builder’s marketing blog characterises annual permit and certification costs as “thousands of dollars annually,” which we cite only as a directional reference from a single interested source — not a reliable benchmark. Verify current costs with KSOP before you budget.
The BKI survey fee for a new classification will depend on vessel GT and survey scope. Annual survey endorsements are typically less expensive than the initial classification entry. Ask BKI directly for current tariff schedules applicable to your vessel class.
Related Reading on This Site
The registration and certification questions do not exist in isolation from the ownership structure. Whether you can register a vessel in your name at all depends on whether you can hold the right type of entity. Our pillar page on foreign ownership of boats in Indonesia covers the PT PMA structure, the cabotage law, and the nominee-arrangement risks in more depth. For Indonesian-language readers, our izin kapal wisata and grosse akta kapal guides cover this material in Bahasa Indonesia.
If you are at the stage of evaluating a specific vessel for purchase, our phinisi survey checklist covers the physical and document due-diligence process side by side.
Thinking about chartering a fully compliant liveaboard rather than buying? We are happy to match you with vessels that can produce their paperwork without hesitation. Reach us on our enquiry form or via WhatsApp — no hard sell, just independent information.
Frequently Asked Questions
What is a grosse akta kapal and why does it matter for buying a phinisi?
The grosse akta kapal is the official vessel ownership deed issued by Indonesia’s Directorate General of Sea Transportation (Ditjen Hubla). It is the primary title instrument for the vessel — the equivalent of a land certificate. When buying a phinisi, the grosse akta must show an unbroken ownership chain ending in the current seller, with no undischarged liens. Gaps in the chain, stale registrations, or informal family transfers that were never re-registered in the Hubla system are among the most common title problems in the used-phinisi market. A maritime lawyer should verify the grosse akta before any purchase is completed.
Is BKI classification mandatory for a charter phinisi in Indonesia?
BKI (Biro Klasifikasi Indonesia) classification is not universally mandated by a single statute for every small domestic vessel, but in practice it is effectively required for commercial charter operation in two respects: most marine insurers will not issue hull and machinery or P&I cover on a wooden commercial vessel without class, and the Syahbandar passenger safety certification process for liveaboard-scale vessels typically requires an active classification survey as part of its basis. A phinisi operating without BKI class is operating with reduced insurability and is more exposed to Syahbandar inspection findings. Verify current classification requirements directly with BKI and your target KSOP.
Can a foreigner serve as captain or chief engineer on an Indonesian-flagged phinisi?
Indonesian maritime regulation generally requires that the master and chief engineer of an Indonesian-flagged vessel hold Indonesian national competency certificates (ANT/ATT grades). Limited exemptions can be granted by the Directorate General for foreign nationals, particularly for vessels on international routes or under special circumstances, but these are not a standard feature of the domestic charter-phinisi market. If you are structuring a vessel operation that requires a specific foreign national in a command position, you need specific regulatory confirmation from the Ditjen Hubla — not a general assumption that it is permitted.
What is the difference between a pas besar and a surat ukur kapal?
They serve different purposes. The surat ukur kapal is the tonnage measurement certificate — it records the vessel’s officially measured gross tonnage (GT), dimensions, and hull characteristics as determined by a government surveyor. The pas besar kapal is the vessel nationality document — it is the flag certificate establishing that the vessel is registered under the Indonesian flag. Both are part of the vessel’s core documentation, but they are separate instruments issued in different processes. The surat ukur is needed first, because the GT figure it records feeds into the basis for subsequent certificates including the pas besar and the safe-manning certificate.
Do foreign dive guides or cruise directors on a phinisi need Indonesian maritime crew certificates?
Generally no, in the sense that foreign dive instructors and cruise directors are not typically designated as ship’s officers on the vessel’s safe-manning certificate — they are carried as service or tourism personnel rather than in a navigation or engineering role. However, “not required to hold an ANT certificate” is not the same as “no regulatory requirements.” Foreign nationals working in Indonesia require a valid work permit (KITAS and an RPTKA approval by the employer), and reported enforcement actions against foreign dive staff operating without proper work authorisation have occurred in Komodo and Raja Ampat waters. The regulatory treatment of foreign service staff on commercial vessels is not fully settled. Get specific immigration and labour law advice rather than relying on the common practice in your port of operation.