ANNEX
NOTE COMMENTING ON MR DENHOLM'S LETTER DATED 26 APRIL 1973
As expected, the letter concentrates on the alleged disadvantages of a separate Hong Kong register for the British shipping industry.
The letter makes seven principal points, a-g, in opposition to a separate register but also sets out six condi- tions, nos. i-vi, should it nevertheless be decided to establish
This note comments on each of the points made.
one.
a. British ship-owners have difficulty in getting DTI
acceptance of safety equipment on new and second-hand tonnage transferred to the UK register. Different conditions would prevail in Hong Kong and this would put Hong Kong owners at an advantage.
b
Comment. This point relates to discussions which were held with the Chamber last week aimed at liberalising our arrangements for accepting foreign equipment, eg. lifeboats, liferafts, life jackets, compasses, lanterns, fire-fighting equipment and radio. A number of other countries, including the US and Japan, are more restrictive than we are in respect of their own ships and we have made progress in reciprocal recognition of equipment in EFTA - a process which we now hope to speed up. Apart from reference to the recent discussions, we could reply to the Chamber that, although there may be minor differences in what is accepted, we still expect the Hong Kong Marine Department to be fully satisfied that the equipment meets UK standards, and that this would, in our view, involve proper tests of the equipment concerned.
Tonnage will be attracted to Hong Kong from companies the real control of which lay outside the Colony: these would be very difficult to control and could engage in politically undesirable trading.
Comment. There is no real point here: exactly the same situation exists at present. It is true that relaxation in conditions of registry may attract some additional foreign tonnage but there is no reason to suppose that this will be particularly troublesome.
Whereas ship-owners in most countries could take advantage of a separate register of shipping for Hong Kong and transfer ships to it, UK ship-owners would be prevented from doing so under existing Inland Revenue legislation. This would place UK owners at a disadvantage.
Comment. We certainly do not regard it as a serious disadvantage that UK ship-owners should find it
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