"EU Operators" - Reporting Requirements

This in relation to the notification requirement of “EU operators” for excepted cargoes under the 16^th package, namely;

Operators shall inform the competent authority of the Member State where they are incorporated or under whose law they are constituted of any transaction concluded pursuant to paragraph 3 or 4 within 2 weeks of its conclusion

(paragraph 5 of Article 5ae of Council Regulation (EU) 833/2014).

The term EU operator is not defined in the Regulations.

Basis however other references in FAQs an EU operator would include;

all EU vessels, i.e. EU flagged vessels, and also vessels that are owned, chartered and/or operated by EU companies or nationals. This would also cover agents acting on their behalf

In the event of an EU Member/vessel/operator being involved in an incident at a Russian port listed in the Regulation, the EU Member would need to show to the Club that the underlying Article 5ae(3) activity has been reported to their State Authority.