From ECM Maritime Client Alert 17-2006 - 7 November 2006
In an earlier website article, also based on an ECM Maritime client alert, it was reported that for vessels transiting from one US Port to another, separate notifications to the USCG were required within the proper time specified. Further clarification on this statement is now required as follows:
- Vessels trading between U.S. Ports are still required to submit NOAs (e-NOA) within the same time requirements as vessels going from foreign to U.S. or U.S. to foreign.
- That is, if voyage time is 96 hours or more, an e-NOA must be submitted to the NVMC 96 hours prior to arrival. If voyage time is less than 96 hours, an e-NOA must be submitted before departure but at least 24 hours before arrival.
- Vessels trading from one US port to another need NOT submit an e-NOD upon departure
- Vessels trading US to foreign must submit an e-NOD with passenger/crew manifest (APIS submission) 60 minutes (changed from 15 minutes to 60 minutes) prior to departure from last US port of call.
- For a voyage between two U.S. ports, e-NOA submission need NOT include submission of the passenger/crew manifest (APIS). This is ONLY required at first U.S. port of call and last U.S. port of call.
- Since crew/passenger manifests with e-NOA submission are not required for transits between U.S. ports, a NOA could be faxed direct to the USCG without going through the NVMC with an e-NOA submission. However, it is suggested that all NOAs be sent as e-NOA via the NVMC. NVMC will in turn distribute this e-NOA to the USCG/CBP as necessary/required.
- Vessels transiting between two U.S. ports in the same USCG COTP zone are exempt from submitting e-NOA except when those vessels are carrying certain dangerous cargos (CDCs). Vessels carrying CDCs must submit e-NOA when transiting between two ports in the same USCG COTP zone, but this is not applicable if the vessel is moving within the same port i.e. changing berths or moving from anchorage to a berth or a berth to the anchorage.
- A complete definition of CDCs is provided in 33 CFR 160.204.
- Please note where e-NOA/D submission requires listing of a US Agent, the local agent in the U.S. should be listed.
- Although many US agents will not make e-NOA/D submissions on behalf of a vessel, the following nonprofit industry organizations will do so for a nominal fee:
Southern California Ship Services ([email protected])
The Maritime Exchange ([email protected])
The New Orleans Board of Trade ([email protected])
ECM recommends that if there is any doubt as to whether an e-NOA/D should be submitted, it is best to proceed with a submission; there are no fines or penalties associated with over-reporting.
Further information can be obtained from the USCG National Vessel Movement Center (NVMC) Frequently Asked Questions (FAQ) webpage
