The Nitty Gritty of Registering Tenders
By Josh Richardson, managing director, Superyacht Tenders & Toys
Registering a tender not a complicated matter, but it should be taken as seriously as any yacht documentation. The type of registration required for a tender may vary but, generally, if a vessel is used independently of the mothership or is towed or delivered on its own bottom, it requires its own registration. Tenders solely transporting guests between the mothership and the shore can be registered under the same registration as the mothership and be called “tender to” motoryacht. When cruising in certain countries, a local registration may also be required (e.g. United States, Croatia, Turkey). This is only required when a tender is not transporting guests to and from the mothership and the shore, or is out of line of sight of the mothership.
Local registration is common in the US and it is recommended that all large tenders be locally registered (if they do not have their own full registration already) so that they can cruise independently as required. Local registration is an inexpensive and easy process only taking between one and two weeks and it lasts for up to three years, whereas full registration is a more complex and expensive procedure.
If a vessel is a chase boat or a towed tender and cruises on its own bottom it is required to have its own registration at all times (usually with the same flag as the mothership’s registration). The registration is a separate closing transaction requiring the following documents:
• Bill of sale
• Builders Certificate, Certificate of Origin or Manufacturer’s Certificate of Origin
• Certificate of Survey
• Tonnage Certificate
• Carving and Marking note
• Corporate resolutions
• Certificate of Incumbency
• Certificate of Good Standing
• Radio License
Registering the vessel can take up to four weeks from application depending upon availability of documents. The cost for this varies with each flag state. With the Cayman Islands Shipping Registry, it costs €738 ($998) for registration plus €328 ($435) tonnage tax for any vessel under 24m (79ft) length overall. Once this is complete, the vessel will be registered as a separate entity requiring entry and cruising permits and other regulatory compliance for any port state of entry.
When under full registration, the vessel has its own MMSI, and AIS tracking can be achieved. When it is separated from the mothership, the vessel can legally operate independently. When clearing customs, agents will require a separate cruising permit. Time with customs will most likely be increased, as you will be clearing in more than just the mother ship when arriving at a new destination. All documents must always be carried on the vessel in case of customs inspection.
Local Registration (using the example of the US and Delaware)
US Customs Cruising Permits cover only a single vessel, not all vessels aboard a mothership. Though your homeport might consider your tender complement as an extension of the yacht, within US waters, the only vessels recognized as tenders and therefore authorized for operation without a separate registration are those being used for emergency evacuation.
Small boats fall under local jurisdiction and local legislation, which require separate registrations in order for them to be used legally while in the US. Regardless of your yacht’s flag and your cruising permit, tenders and toys must be registered with the state agency in the area of principal use once you have entered US waters unless they fall into the following categories:
• The tender is ferrying guests to and from the mothership
• The tender is in line of sight of the mothership
When using tenders and PWC, when berthed or cruising in Florida in particular, it is hard to ensure that they comply at all times with the “line of sight” and “ferrying to and from the yacht to shore” restrictions. Due to this, it is strongly recommended that local registration for all tenders and toys be completed prior to the yacht’s arrival. If the yacht is only staying for a few days, then a decision based on the exposure and risk involved should be carried out by the captain and/or manager. It is recommended that all powered watercraft are registered outside of Florida, more specifically in Delaware, to legally avoid paying sales and/or use tax in Florida (current rate is 6 percent). The amount of time in Florida must be monitored carefully to avoid violation of Florida use tax laws. Stays of under 30 days are recommended. All documentation must be carried on each tender and PWC at all times. This can simply be sealed in a waterproof bag or put in a document key ring. To Register:
• Time taken to complete registration: 9-14 days
• Documents required: Bill of sale, HIN (hull identification number) and Certificate of Origin . Tenders not made in the U.S. are often not built with an HIN and registration can be more lengthy if not provided.
The cost is an annual or three-year registration fee that is dependent upon the size of vessel. Examples given below of Delaware registration costs:
(Class/Size Range/Annual Cost/Three-Year Cost)
A/ > 16 feet/ $10/$30
I/16-26 feet/ $20/$60
Superyacht Tenders and Toys recommends that large tenders that are going to be used independently of the mothership gain their own full registration from the beginning to give them flexibility for owner or guest cruising. For any vessel with accommodation on board this would be highly recommended. All other tenders should be registered under the banner of the mothership and no separate registration is required initially. When the vessel cruises to countries requiring local registration, all tenders and toys that do not have their own registration should gain local registration if they are going to be used independently.
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