U.S. Reflag Process Guidelines

The U.S. Registry is primarily composed of vessels that are designed, constructed, inspected and certified in accordance with either the traditional comprehensive USCG process or the ACP process. Other U.S. registered vessels are those that have been inspected and certified through the MSP.

1) Traditionally Inspected USCG (U.S. Flag) Vessels

The USCG has primary responsibility for plan approval and inspection of traditionally inspected U.S. Flag vessels in accordance with applicable requirements of Title 46 of the Code of Federal Regulations (46 CFR). These vessels are issued a Certificate of Inspection (COI) by the USCG, which may also directly issue the applicable statutory certificates.

Key Requirements for Reflagging as a Traditional USCG Vessel

Vessels transitioning to the U.S. Flag under this approach may not use the guidance provided in NVIC 01-13, CH 2.

Traditionally inspected vessels must comply with applicable 46 CFR requirements, independent of class rules and international conventions. Required plans and drawings must be submitted to the USCG Marine Safety Center (MSC) for review and approval. Any deficiencies identified during the review must be addressed, including necessary vessel modifications.

Certain equipment may require USCG Type Approval. Equipment subject to this requirement that is not appropriately approved may need to be replaced. USCG-approved equipment can be verified through CGMiX, the USCG’s publicly searchable database.

The USCG may also require construction records or other supporting documentation to verify compliance with applicable construction standards and material requirements.

Certain plan review, inspection and certification activities may be delegated to ABS, while other statutory certification and services remain under direct USCG responsibility.

2) Alternative Compliance Program (ACP) Vessels

The Alternative Compliance Program (ACP) is a voluntary process that allows eligible U.S. Flag vessels to obtain a USCG Certificate of Inspection (COI) by complying with the rules of an authorized classification society, applicable international conventions and the U.S. Supplement.

The U.S. Supplement identifies additional U.S. requirements and Flag Administration interpretations that are not fully addressed by classification rules or international conventions. Together, these requirements provide an alternative means of demonstrating compliance with applicable 46 CFR requirements.

To participate in the ACP, a vessel must be classed by a USCG-recognized organization authorized to participate in the program, such as ABS, and certificated under an applicable 46 CFR subchapter that permits alternative compliance. Certain novel or unconventional vessel designs may be considered on a case-by-case basis.

For vessels enrolled in the ACP, ABS may perform plan review, surveys, inspections and statutory certification activities on behalf of the USCG, within the scope of its authorization. This includes reviewing applicable plans for compliance with ABS Rules, international requirements and the current U.S. Supplement. Matters requiring USCG acceptance or approval are referred to the appropriate USCG authority.

Certain regulatory approvals, certifications and other functions remain under the direct responsibility of the USCG.

Key Requirements for Reflagging into ACP

Foreign-flagged vessels transitioning to the U.S. Flag under the ACP must comply with the ACP Standard, which consists of:

1. ABS Rules recognized by the USCG;
2. Applicable international conventions, including SOLAS, MARPOL and Load Line requirements; and
3. Applicable requirements of the U.S. Supplement.

The USCG may consider equivalencies to U.S. Supplement requirements on a case-by-case basis, which may require the development of a gap analysis. Vessels must also comply with applicable USCG Type Approval requirements for equipment and systems.

3) Maritime Security Program (MSP)

The Coast Guard Authorization Act of 1996 established provisions for eligible foreign-flagged vessels to transition to U.S. Registry and obtain a USCG Certificate of Inspection (COI) in support of the Maritime Security Program (MSP). The MSP supports a fleet of commercially viable, militarily useful U.S. Flag vessels available to meet national defense and security needs.

The USCG and MARAD coordinate inspection and certification requirements for eligible vessels. Receipt of MSP payments is not required for issuance of a COI, provided the vessel meets applicable MARAD eligibility criteria and the owner or operator demonstrates intent to participate in an eligible voluntary sealift support program.

Key Requirements for Reflagging Under MSP

Vessels must first be found eligible for the MSP) by MARAD. Eligible foreign-flagged vessels must then transition to the U.S. Flag.

Unlike the ACP, MSP reflagging does not require compliance with a U.S. Supplement. For initial USCG certification, eligible foreign-built vessels may demonstrate compliance with:

1. Applicable ABS Rules recognized by the USCG; and
2. Applicable international conventions, including SOLAS, MARPOL and Load Line requirements, as interpreted and implemented by the vessel’s previous flag Administration.

MSP eligibility requirements, including vessel, ownership, operator and citizenship criteria, are provided in 46 CFR Part 296, Subpart B.

Additional Requirements for Tankers

Foreign-flagged tankers seeking enrollment in the MSP are subject to additional evaluation during the reflagging process. Under an agreement between the USCG and MARAD, these vessels must:

1. Provide evidence of a valid Foreign Tank Ship Certificate of Compliance (COC) (Form CG-3583) issued by the USCG; or
2. If a valid COC is not available, satisfactorily complete a COC examination during the reflagging process.

Accordingly, MSP tankers must comply with the requirements applicable to foreign tankers calling at U.S. ports before transitioning to the U.S. Flag.

MSP legislation does not prescribe the scope or manner of USCG inspections used to determine whether a vessel meets the requirements for issuance and continued maintenance of a Certificate of Inspection (COI). Since the inception of the MSP, regulatory oversight has been conducted through a combination of USCG inspections and ABS surveys.

4) Voluntary Sealift Support Programs

There are two voluntary sealift support programs: the Voluntary Intermodal Sealift Agreement (VISA) and the Voluntary Tanker Agreement (VTA). Both provide the U.S. Government access to commercial sealift capacity during national contingencies. VISA provides access to dry-cargo and intermodal capacity, while VTA provides access to U.S. Flag tanker capacity.

Authorized under the Defense Production Act of 1950, VISA is a partnership between the maritime industry and the U.S. Government that provides the Department of Defense (DoD) with assured access to commercial sealift capacity and intermodal resources during war, national emergencies and peacetime. In return for committing resources to VISA, operators of qualified U.S.-flagged vessels receive priority consideration for government-impelled cargo under cargo preference laws.

VISA also provides access to participating carriers’ global intermodal networks, helping maximize available resources while minimizing disruption to commercial operations. The program is activated in three stages, with progressively higher levels of capacity commitment:

• Stage 1: Requires the carrier to Commit 15% of its Vessel Capacity
• Stage 2: Requires the carrier to Commit 40% of its Vessel Capacity by the Carrier
• Stage 3: Requires the carrier to Commit 40% of its Vessel Capacity, except for carriers in the MSP, who must commit 100% of their capacity.

VISA carriers have historically volunteered sufficient capacity to support U.S. sealift needs during crises and conflicts without requiring formal activation by MARAD or the DoD.

The VTA operates similarly to VISA. However, when activated, enrolled tankers are selected based on their characteristics and suitability for the specific contingency. As a result, only a portion of the committed tanker fleet may be activated.

Key Requirements for Reflagging into a Voluntary Sealift Support Program

These vessels must meet the same requirements as vessels reflagging under the MSP.

5) Ready Reserve Force (RRF)

The RRF is a fleet of us government-owned vessels managed by MARAD; its vessels are not engaged in commercial trade. The government acquires vessels from commercial sources based on specific defense needs. Once a vessel is purchased, its ship manager assists in the transition to the us flag.

Key Requirements for Reflagging into the RRF

These vessels will need to meet the same requirements as vessels reflagging under MSP.

The guidance below applies to vessels entering the U.S. Registry through the following programs:

• Alternative Compliance Program (ACP)
• Maritime Security Program (MSP)
• Ready Reserve Force (RRF)
• Voluntary Sealift Programs (VISA) and VTA

The reflagging process follows the guidance in NVIC 01-13, CH 2. A key part of this process is the development of a gap analysis to identify differences between the vessel’s existing design, equipment and arrangements and applicable U.S. requirements.

For vessels determined eligible by MARAD for the MSP, RRF or other sealift support programs, the gap analysis may be used as the basis for requesting equivalencies to applicable 46 CFR requirements.

For vessels entering the ACP, the gap analysis is used to identify areas requiring compliance with the ACP Standard. The U.S. Supplement may be used as a reference when developing the gap analysis. The USCG may consider equivalencies on a case-by-case basis.

The gap analysis should also identify equipment subject to USCG Type Approval and any items that do not meet applicable approval requirements.

U.S. Reflag Process Flowchart for NVIC 01-13, CH2.

Timely communication is key to any successful reflagging certification process. Vessel owners/operators should provide detailed and accurate information to the U.S. Coast Guard and ABS as soon as possible. Although not required, owners/operators may also request meetings with the U.S. Coast Guard to review specific issues of concern prior to certification. Such meeting requests should initially be directed to the Commanding Officer, U.S. Coast Guard Marine Safety Center (MSC), and later, if necessary, to the officer in charge, marine inspection (OCMI) in whose zone the inspection for certification will take place. ABS should be involved in all such meetings.

The key steps for successfully reflagging to U.S. registry are outlined below.

1) Standards for Reflag

The U.S. Coast Guard may accept surveys previously conducted by ABS and existing international certificates as evidence of compliance with applicable ABS Rules and international requirements, provided that:

• The vessel is classed by ABS and designed in accordance with applicable ABS Rules recognized by the USCG.
• Immediately before reflagging, the vessel complies with applicable international conventions and associated guidelines, as determined by its current flag Administration.
• The current flag Administration has not been identified by the USCG as inadequately enforcing international vessel requirements. Vessels reflagging from a targeted flag or classification society may be subject to additional inspections, tests, thickness gauging, internal examinations or ISM Code audits, as deemed necessary by the USCG. See the Annual Targeted Flag List.
• The vessel's classification society has not been identified by the USCG as inadequately enforcing international vessel requirements. If the vessel is not already classed by a recognized classification society, a transfer of class will be required as part of the reflagging process.
• The vessel and its equipment have been maintained in compliance with applicable requirements.

2) Eligibility Determination by MARAD

Vessel owners seeking to participate in U.S. Flag programs must apply to the Maritime Administration (MARAD) for eligibility under the applicable program:

• Maritime Security Program (MSP)
• Tanker Security Program (TSP)
• Cable Security Fleet (CSF)
• Voluntary Intermodal Sealift Agreement (VISA)
• Voluntary Tanker Agreement (VTA)

MARAD's determination confirms the vessel's eligibility for the applicable program and allows its transition to the U.S. Flag.

• USCG coordination: The USCG generally begins the initial inspection process after receiving formal notice of eligibility from MARAD.
• Advance coordination: Based on its preliminary review, MARAD may advise the USCG that a vessel is likely to be eligible, allowing discussions and plan review to begin before formal approval.
• ACP vessels: MARAD eligibility determination is not required for reflagging vessels under the Alternative Compliance Program (ACP).

3) Application for Inspection

Once eligibility is established, the vessel owner/operator must apply for a USCG inspection:

• Application: Complete Form CG-3752 (Application for Inspection of U.S. Vessel) with the required vessel, operational and compliance information.
• Submission: Submit the completed form to the Officer in Charge, Marine Inspection (OCMI) responsible for the vessel's area of operation and the USCG Traveling Inspection Staff. See the External Prevention Directory Contact List.
• Compliance: The vessel must comply with applicable U.S. regulations and international pollution prevention requirements, including the Oil Pollution Act of 1990 (OPA 90).
• Tankships: A valid USCG Certificate of Compliance (COC), Form CG-3583, should be submitted with the application. Vessels without a valid COC will undergo a full compliance examination during the initial reflag inspection; vessels with a valid COC will be subject to a USCG spot check.

Submission of Form CG-3752 initiates the USCG inspection process, including the applicable plan reviews and inspections.

4) Submission of Documentation

Prior to the reflag inspection, vessel owners/operators must submit all relevant plans, documentation and supporting information to the U.S. Coast Guard and other applicable authorities at least 30 days before the requested inspection date.

The items listed below are not all-inclusive, and the OCMI may request additional documentation as necessary.

1. MARAD Office of Sealift Support determination of eligibility (applies to MSP/CSF/TSP/VISA/VTA vessels only) 

2. MSC vessel security plan (VSP) review documentation

3. Contact information for the representatives attending on behalf of ABS and/or the previous flag Administration 

4. Contact information for the representatives attending on behalf of the recognized organization issuing the Safety Management Certificate 

5. Contact information for the representatives who will be conducting the survey of radio equipment on behalf of the U.S. Federal Communications Commission 

6. Reports on Port State Control (international) attendances for the previous five years (as applicable) 

7. The following regulatory and statutory documentation issued by ABS and the previous flag administration [NOTE: for new construction, documentation is not required until delivery]: 

A. ABS Class Certificate

B. Current Registry Certificate

C. SOLAS Cargo Ship Safety Construction Certificate (SLC)

D. SOLAS Cargo Ship Safety Equipment Certificate (SLE) and Form E

E. SOLAS Cargo Ship Safety Radio Certificate (SLR) and Form R

F. International Load Line Certificate

G. International Oil Pollution Prevention Certificate and Form A/B (as applicable)

H. International Pollution Prevention Certificate for the Carriage of Noxious Liquid Substances

I. International Air Pollution Prevention Certificate and Supplement

J. International Energy Efficiency Certificate (if applicable)

K. International Sewage Pollution Prevention Certificate (if applicable)

L. Safety Management Certificate (SMC)

M. ISM Document of Compliance

N. Cargo Gear Certificate

O. Document of Compliance for the Carriage of Dangerous Goods

P. Continuous Synopsis Record (all previous)

Q. Copies of any exemption certificates or equivalencies (see Verification of Equipment below)

R. International Tonnage Certificate (ITC)

S. Minimum Safe Manning Certificate (see Minimum Safe Manning below)

T. International Ship Security Certificate (ISSC)

U. Certificate of Fitness (as applicable)

V. International Anti-Fouling System Certificate (AFSC) (if applicable)

W. Polar Ship Certificate

8. Class record of approved safety equipment

9. Boiler and pressure vessel nameplate data

10. Proof of payment of User Fees and Overseas Inspection fees (as applicable)

11. Manning proposal

12. Reports of flag Administration attendances for the previous five years (as applicable)

13. Vessel Security Plan: Submit a compliant Vessel Security Plan (VSP) to the U.S. Coast Guard for approval.

14. Vessel Response Plan: Include the Vessel Response Plan (VRP), as well as applicable oil pollution plans, such as SOPEP (Shipboard Oil Pollution Emergency Plan) and SMPEP (Shipboard Marine Pollution Emergency Plan).

5) Submittal of Plans, Equivalencies and Exemptions

During initial certification of a reflagged MSP/CSF/TSP/VISA/VTA vessel, the U.S. Coast Guard may accept existing non-USCG-approved equipment and systems that comply with applicable international conventions, as interpreted by the previous flag Administration.

The vessel owner/operator must submit the required plans and supporting information to the cognizant OCMI, CG-5P-TI, and/or the MSC to demonstrate compliance with applicable international conventions and ABS Rules. ABS verifies that vessel plans comply with the applicable standards.

Any equivalencies or exemptions granted under applicable international conventions or ABS Rules must be identified and documented by the vessel owner/operator, previous flag Administration and/or ABS, and then submitted to the appropriate USCG office for review.

6) Prepare and Submit Gap Analysis

A gap analysis should identify areas where the vessel does not meet applicable U.S. Flag requirements, including equipment that does not meet USCG type-approval requirements. USCG type-approved equipment may be verified through the CGMIX database.

Each identified gap should include a proposed solution, equivalency or mitigation measure. ABS should review the gap analysis for accuracy before it is submitted to the OCMI responsible for the vessel’s initial inspection.

ACP vessels only: For vessels entering the Alternative Compliance Program (ACP), the vessel is expected to meet the ACP Standard. The USCG may accept equivalencies on a case-by-case basis when adequately documented and supported by appropriate solutions or mitigation measures.

The finalized gap analysis documents items accepted under international, class or previous flag Administration requirements that differ from U.S. requirements, helping ensure consistency during future inspections. Accepted gaps do not necessarily require correction at reflagging if they complied with the previous flag Administration’s requirements at that time. The final gap analysis should be retained in the permanent USCG and ABS vessel records, and a copy should be kept on board.

7) Minimum Safe Manning

The minimum safe manning of a vessel is determined by the cognizant OCMI) in accordance with U.S. law, the CFR and USCG policy. The Marine Safety Manual, Volume III, Part B, provides guidance on applicable manning requirements.

Because manning levels approved by the previous flag Administration may not satisfy U.S. requirements, the vessel owner/operator should submit proposed manning levels to the OCMI before the inspection. The proposal is evaluated against comparable U.S.-flagged vessels, considering vessel design, service and operating routes.

A suggested template is available here: Minimum Safe Manning Proposal.

Machinery space attendance is determined in accordance with applicable U.S. requirement NVIC 01-13, which refers to SOLAS Chapter II-1/Part E and 46 CFR Part 62. Vessels seeking operation with minimally attended machinery spaces (MAMS) or periodically unattended machinery spaces (PUMS) must meet the applicable automation requirements. Alternative arrangements may be accepted when they provide an equivalent level of safety and reliability.

The U.S. Coast Guard will accept the following as a general alternative to the requirements in 46 CFR 62.50-20(a)–(g) and 62.50-30(a)–(i) and (k):

1. The vessel meets SOLAS II-1/Part E (as applicable) and was authorized for MAMS/PUMS by the previous flag Administration.
2. The vessel meets 46 CFR 62.50-20(h) and/or 62.50-30(j), as appropriate; and
3. The vessel and its machinery installation are approved by ABS or have been assigned the MAMS/PUMS class notation (as appropriate), and the following additional provisions are met:
   1. the fail-safe requirements of SOLAS are met (SOLAS Chapter II-1/Reg. 31.2.7; and Reg. 49.5 - PUMS.
   2. Propulsion safety trip control systems must not operate as a result of failure of the normal electric power source unless it is determined to be the fail-safe state.
   3. Sensors for the primary speed, pitch or direction of rotation control in closed loop propulsion control systems must be independent and physically separate from required safety, alarm or instrumentation sensors.
   4. An alarm to indicate starting capability of less than 50% of the required total starting capacity must be provided. (SOLAS Chapter II-1, Reg. 31.2.9; and Reg. 49.7 - PUMS).
   5. Propulsion control from the Navigating Bridge must be provided. (SOLAS Chapter II-1, Reg. 31.2 – MAMS; and Reg. 49.1 – PUMS).
   6. A personnel alarm must be provided and must annunciate on the Navigating Bridge if not routinely acknowledged at the centralized control station or in the machinery space.
   7. All required alarms must annunciate throughout the Centralized Control Station and the machinery space. (SOLAS Chapter II-1, Reg. 51 - PUMS).
   8. Continuity of electrical power must be maintained. (SOLAS Chapter II-1, Reg. 53.2 – PUMS).
   9. The fire detection and alarm system must activate all alarms at the Centralized Control Station, the Navigating Bridge and throughout the machinery spaces and engineer’s accommodations.
   10. The Centralized Control Station must include control of the main machinery space fire pumps. Where one or more fire pumps are required to be independent of the main machinery space, at least one of such pumps must be controlled from the Navigating Bridge. (See SOLAS II-2/10.2.2.3.1.2). All required fire pump control locations must include the controls necessary to charge the fire main and have (1) a fire main pressure indicator or (2) a fire main low-pressure alarm.

Automation test procedures must demonstrate compliance before approval and during subsequent validations. Major automation alterations or failures must be reported to the OCMI. During transition to U.S. registry, interim MAMS/PUMS endorsements may be considered, with increased manning required where necessary until identified deficiencies are resolved. Additional guidance is provided in NVIC 01-13 CH-2, Enclosure (2), Section 3.2.1.

A reduction in manning requires compliance with the applicable standards, a successful trial period demonstrating reliable operation and USCG review. The trial period is typically 3,000 hours but may be reduced to 2,000 or 1,000 hours based on operating history and OCMI discretion. Following satisfactory review of the vessel's automation and operating records, the OCMI may issue an amended Certificate of Inspection (COI) authorizing reduced manning.

Periodic Safety Test Procedures (PSTPs)

• Submit the PSTPs for review by the USCG or ABS, whichever is responsible for the reflagging inspection.

8) Sexual Assault and Sexual Harassment (SASH) Requirements

To enhance crew safety and to prevent and respond to sexual assault and sexual harassment in the maritime industry, Title 46 of the United States Code (U.S.C.) includes the following requirements:

1. Master key control system (46 U.S.C. § 3106)
   Applicable vessels must maintain a master key control system limiting access to authorized crewmembers identified by position. The list of authorized personnel and a log of all master key access and use must be maintained onboard and incorporated into the vessel’s Safety Management System (SMS).
2. Accommodations for seamen (46 U.S.C. § 11101)
   Applicable vessels must display, in visible locations within crew berthing and washing areas, information on company policies prohibiting sexual assault and sexual harassment, including available reporting procedures and resources.
3. Surveillance requirements (46 U.S.C. § 4901)
   Applicable vessels must maintain video and audio surveillance covering passageways serving stateroom doors and post signs notifying the crew of the surveillance. Recordings must be retained for the required period, and crewmembers must be trained to respond to and report sexual assault and sexual harassment.
4. Requirement to report sexual offenses (46 U.S.C. § 10104)
   The responsible entity must report applicable complaints or incidents of sexual harassment or sexual assault to the Coast Guard and submit a follow-up after-action summary within 10 days of the initial report.
5. Safety management system (46 U.S.C. § 3203)
   The SMS should include policies and procedures addressing applicable reporting and after-action requirements under 46 U.S.C. § 10104 and master key control requirements under 46 U.S.C. § 3106. The Coast Guard or Recognized Organizations (ROs) may conduct audits or reviews and may suspend or revoke a Document of Compliance (DOC) or Safety Management Certificate (SMC) for noncompliance.

For additional information, refer to marine safety bullet in (MSIB 13-23).

9) Every Mariner Builds a Respectful Culture (EMBARC) Requirements

Commercial operators of U.S. Flag vessels must adopt and follow the EMBARC Standards before embarking United States Merchant Marine Academy (USMMA) cadets on board. These consist of policies, programs, procedures and practices to help strengthen a culture of SASH prevention and support appropriate responses to related incidents. Requirements include, among others:

1. Establish SASH policies within the Safety Management System, including transparent reporting procedures and mechanisms.
2. Complete and submit the EMBARC Accession checklist to MARAD along with the SASH policies.
3. Conduct annual self-assessments and submit confirmation of such self-assessments and any resultant changes to MARAD.
4. Participate in MARAD recurring assessments.
5. Designate a trained shoreside SASH Contact.
6. Ensure a meeting between the cadet and the SASH Contact before or shortly after embarkation and establish communication measures to maintain continuous communication between them.
7. Ensure all officers and crew complete the SOCP Maritime SASH Prevention Training before a cadet embarks and repeat it annually. Conduct quarterly shipboard training on bystander intervention and response.

For additional information, refer to the EMBARC Standards.

10) Additional Documentation Applications

1. Registry Documentation: Apply to the National Vessel Documentation Center (NVDC) for U.S. certificate of documentation.
2. Continuous Synopsis Record (CSR): Complete and submit an application for the CSR through the USCG CSR Desk. The CSR tracks the vessel’s history and supports compliance with SOLAS requirements.
3. EPA Certification: Obtain the Engine International Air Pollution Prevention (EIAPP) certificate from the Environmental Protection Agency (EPA) to confirm compliance with emission limits under Annex VI of MARPOL.
4. Ship Station License: Apply to the Federal Communications Commission (FCC) to secure a Ship Station License for radio communications equipment on board.

11) Final Preparations for the Initial Inspection

Before the initial inspection, vessel owners/operators should complete the following steps to facilitate an efficient inspection process:
1. Request ABS attendance: arrange for an ABS Surveyor:

• arrange for an ABS surveyor to support the reflagging process on behalf of the U.S. Coast Guard.

2. Provide Survey Information:

• Submit relevant previous survey and inspection records to ABS and the USCG, including applicable certificates and drydocking reports.

3. Submit the Gap Analysis:

•  Provide the completed gap analysis.
• (ACP vessels only) Obtain USCG acceptance of proposed equivalencies sought through the gap analysis before the initial inspection.

4. Pre-Inspection Survey (Highly Encouraged):

• Have ABS conduct a preliminary survey before the USCG inspection to identify potential compliance issues and minimize delays.

5. Payment of User Fees:

• Pay applicable USCG user and overseas inspection fees before the initial inspection. The vessel owner/operator is responsible for USCG travel and per diem costs for overseas inspections.
• If advance payment is not possible due to scheduling constraints, contact Commandant (CG-CVC) to determine whether payment may be deferred until after the inspection begins.

12) Conduct Initial Inspection

The initial inspection verifies the vessel’s compliance with applicable U.S. Flag requirements, international conventions, USCG standards and MSP/CSF/TSP/VISA/VTA requirements, where applicable.

1. Inspection Duration:

• The onboard inspection typically takes about three days, depending on vessel complexity, condition, weather and pre-inspection preparation. For overseas reflagging, the USCG recommends planning for five days to accommodate potential delays.

2. LRIT Conformance Test:

• Complete the Long-Range Identification and Tracking (LRIT) Conformance Test to verify compliance with applicable international requirements.

3. Initial Safety Radio Survey

• An FCC-licensed technician conducts the safety radio survey to verify compliance and proper operation of the vessel’s radio equipment.

4. USCG Attendance:

• USCG Traveling Inspection Staff (CG-5P-TI) and Marine Inspectors from the cognizant OCMI attend the inspection to verify compliance with certification requirements.

5. Issuance of Certificates (As Applicable):

• Upon successful completion of the inspection, the USCG may issue: 
  • Certificate of Inspection (COI): Confirms compliance with U.S. safety and operational requirements and establishes the vessel’s safe manning.
  • Continuous Synopsis Record (CSR): Documents the vessel’s operational and registration history.
  • International Ship Security Certificate (ISSC): Confirms compliance with the ISPS Code.

Drydock examinations are generally not required for initial COI issuance unless identified deficiencies require drydocking. Cargo Tank and Internal Structural Examinations (CTIE/ISE) are also generally not required, although the OCMI may inspect areas subject to high stress or corrosion. Existing hull examination schedules established by the previous flag Administration or ABS generally remain in effect.

For hull examinations conducted during ownership transfer or before reflagging, owners/operators are encouraged to request USCG attendance. At least 14 days’ notice should be provided for examinations within the U.S. and 30 days for examinations outside the U.S.

If the first required intermediate hull examination after COI issuance is an Underwater Survey in Lieu of Drydocking (UWILD), it may receive credit when conducted under ABS requirements, with USCG attendance and a sample Internal Structural Examination (ISE) satisfactory to the OCMI. The same 14-day or 30-day notification periods apply.

13) Issuance of Certificates upon Satisfactory Initial Inspection

Before completing the initial inspection, the USCG Marine Inspector must verify that key vessel systems, documents and markings have been updated to reflect the change of flag, including:

1. Emergency Position Indicating Radio Beacon (EPIRB).
2. Voyage Data Recorder (VDR) or Simplified Voyage Data Recorder (S-VDR).
3. Automatic Identification System (AIS).
4. Long-Range Identification and Tracking (LRIT), including a new U.S. Coast Guard Conformance Test Report. See LRIT Conformance Test Scheduling Request (Navigation Center).
5. Updated markings for lifesaving equipment.
6. New hull markings.
7. Permanently marked Official Number (O.N.).
8. Updated GMDSS markings.
9. Revised bunk cards, station bill, muster list and watchkeeping schedule.

New statutory certificates must also be issued, as applicable, including SLC, SLE, SLR, ILLC, ITC, IOPP, IAPP, IEEC, ISPP, IAFS, SMC and DOC Copy.

Upon successful completion of the inspection, the USCG will issue the Certificate of Inspection (COI) based on the vessel's approved route and service. At the owner/operator's request, the COI expiration date may be harmonized with the ABS certificate dates, up to a maximum of five years.

International Convention Certificates: ABS issues applicable statutory certificates on behalf of the USCG within the scope of its authorization, including SOLAS, MARPOL, Load Line, Tonnage, Anti-Fouling and SOVC-MLC certificates. Where ABS is not authorized, the USCG conducts the applicable inspections and issues the certificates.

ISM Code Certificates: The vessel's Safety Management System must incorporate changes associated with reflagging. ABS issues the Safety Management Certificate (SMC), with any significant deficiencies reported to the OCMI and certificate issuer.

International Ship Security Certificate (ISSC): The ISSC is issued by the USCG following satisfactory ISPS/MTSA compliance examinations.

International Air Pollution Prevention (IAPP) and Engine International Air Pollution Prevention (EIAPP) Certificates: ABS issues the IAPP Certificate, while EIAPP certification is issued by the U.S. Environmental Protection Agency (EPA) through the engine manufacturer. Owners/operators should obtain the required EPA engine certification before IAPP issuance and demonstrate compliance with engine emission regulations under 40 CFR Parts 1042 and 1039. Short-term alternatives may be considered if there are delays in EIAPP certification, provided the owner/operator applied in a timely manner and previous EIAPP certificates remain valid.

For vessels reflagging under MSP/CSF/TSP/VISA/VTA, owners/operators should prioritize obtaining required EIAPP Certificates before scheduling the reflag inspection to avoid delays. Additional guidance on MARPOL Annex VI and IAPP certification is provided in CG-543 Policy Letter 09-01.

14) Enrollment into MSP Select

MSP vessels generally follow the traditional USCG inspection and certification process, which may result in some duplication of activities between the USCG and ABS.

MSP Select more closely follows the inspection and certification approach used under the Alternative Compliance Program (ACP), reducing duplication between the USCG and ABS. USCG inspections focus primarily on activities not delegated to ABS.

In accordance with the USCG MSIB 05-26, MSP vessels may be considered eligible for MSP Select status immediately following their first Drydock Examination (DDX) or Underwater Survey in Lieu of Drydocking (UWILD) subsequent to U.S. reflag, provided they meet the following criteria:

1. Tankers are less than 10 years old (from delivery);
2. Other cargo vessels are less than 15 years old (from delivery);
3. The vessel has maintained the same Recognized Organization (RO) authorized to participate in the Alternative Compliance Program (ACP) from the time of U.S. reflag through the completion of the qualifying UWILD/DDX;
4. The vessel has received a positive OCMI) endorsement; and
5. The vessel is not subject to involuntary disenrollment under any of the criteria listed in section 1.12.2 of Enclosure (4) of NVIC 01-13 (series).

Owners/operators seeking enrollment should submit Form CG-3752, Application for Inspection, to the cognizant OCMI.

Enrollment in MSP Select requires a joint handover survey by an ABS surveyor and a USCG Marine Inspector. The survey should coincide with the next scheduled USCG annual inspection and include applicable survey and inspection items required to endorse the vessel's international certificates.

ABS can support owners and operators throughout the U.S. reflagging process, from early planning through inspection, certification and ongoing compliance. As a USCG-recognized classification society and an Authorized Classification Society under the Alternative Compliance Program (ACP), ABS is authorized to perform delegated surveys and issue statutory certificates on behalf of the USCG.

ABS support may include:

• Early-stage assessment: Review the vessel’s class status, statutory certification, survey history and suitability for reflagging to identify potential compliance issues.
• Gap analysis: Assist in identifying differences between the vessel’s existing configuration and applicable U.S. Flag, ACP and USCG requirements, including potential equivalencies or mitigation measures.
• Plan review: Review vessel plans and technical documentation against applicable ABS Rules, international conventions and U.S. requirements.
• Surveys and inspections: Conduct pre-reflag surveys and required class and statutory surveys, and coordinate with the USCG during the initial reflag inspection.
• Statutory certification: Perform delegated statutory surveys and issue applicable international certificates on behalf of the USCG within the scope of ABS authorization.
• ACP support: Support vessels entering the ACP, where delegated functions performed by authorized classification societies are accepted by the USCG within the scope of their authorization.
• MSP Select transition: Support eligible vessels transitioning to MSP Select, including participation with the USCG in the required joint handover survey and subsequent delegated survey and certification activities.
• Ongoing compliance: Provide class and statutory surveys after reflagging and support continued compliance with applicable U.S. and international requirements.

This approach allows ABS, the vessel owner/operator and the U.S. Coast Guard to coordinate early in the reflagging process, helping identify potential issues before the initial inspection and reducing unnecessary duplication and delays.