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TECHNICAL NOTE No. TECH-007-2026, MMC-302xemption Certificate and Dispensation Letter. Title 3, Regulation 3.1, Standard A3.1 and Part B of the Code, Regarding accommodation and Recreational Facilities

The purpose of this technical note is to provide information
Panama ratified the Maritime Labour Convention, 2006 (MLC) through Law No. 2 of January 6,
2009, regulated by Executive Decree No. 86 of February 2013. Under Article VI of the MLC,
Regulations and Part A Standards are mandatory, while Part B Guidelines are not mandatory.
Due to the large number of Panama-flagged vessels built or with keel laid after 20 August 2013 that do
not comply with Regulation 3.1, the Administration clarifies the following procedures
Exemption Certificate (Mandatory Standards – Part A)
If a vessel does not comply with Decree 86/2013, Title IV, Chapter I (MLC Title 3, Standard A3.1,
Part A): The ship must apply for an Exemption Certificate through SEGUMAR 2.0.
Required documents:
• Patent or statutory navigation certificate
• Maritime Labour Certificate (if applicable)
• Two updated financial securities
• Official payment receipt (USD 300, per MMC-162)
➢ Dispensation Letter (Non-mandatory Guidelines – Part B)
If the vessel does not comply with MLC Part B Guidelines: It must request a Dispensation Letter
by emailing:
• mlc@segumar.com
• mlcassist@segumar.com
The request must include:
• Technical justification
• Vessel’s plan
• Patent, MLC certificate (if applicable), and financial securities The dispensation is free of charge
and issued by Segumar Panama or any International Segumar Office.
➢ 2.3 Vessels Under Construction

Requests must be submitted by the shipyard or the Recognized Organization, including their
technical comments.
The Exemption Certificate number will be included in the DMLC Part I.
The Dispensation Letter must be attached to the DMLC, the Maritime Labour Certificate, and kept
available for competent authorities. If the vessel changes name, owner, RO, manager, GT, or other
key particulars, the Exemption Certificate becomes invalid and the process must be restarted,
including payment.
Scope of MLC Requirements
• The MLC regulates seafarers’ accommodations and recreational facilities, not passenger
facilities.
• Vessels constructed before the MLC entered into force are not subject to construction and
equipment requirements.
o “Equipment” refers to fixed items that cannot be easily modified.
• All other MLC requirements, including those in Standard A3.1 not related to construction,
still apply to older vessels.
This Administration will evaluate the new designs of accommodations and recreational facilities of a novel
kind to the MLC.