Direct Request (CEACR) - adopted 2025, published 114th ILC session (2026)

Maritime Labour Convention, 2006 (MLC, 2006) - Liberia (Ratification: 2006)

The Committee notes the Government’s fourth report on the application of the Maritime Labour Convention, 2006, as amended (MLC, 2006). It also notes that the amendments to the Code of the Convention approved by the International Labour Conference in 2022 entered into force for Liberia on 23 December 2024.

Article I of the Convention. General questions on application. Implementing measures. In reply to its previous comments concerning the limited progress made regarding several issues of compliance with the Convention previously raised, the Committee welcomes the fact that the Government has taken a number of measures to address them. The Committee notes with interest that Liberia has adopted Marine Notice MLC-004 REV. 08/24 to give effect to the 2022 amendments to the Convention. In this regard, the Committee draws the Government’s attention to the questions included in the revised report form and requests the Government to reply to such questions in its next report. Noting however that some important issues are still pending, the Committee requests the Government to adopt the necessary measures without delay to fully implement the provisions of the Convention, taking into account the points raised below.

Article II, paragraphs 1(f), 2, 3 and 7. Definitions and scope of application. Seafarers. National determination. 1. Legislative amendments. The Committee requested the Government to ensure that: (i) guest entertainers who regularly work on board are not excluded from the definition of seafarers; and (ii) section 320 of Liberian Maritime Law (RLM-107) - which states that before the master of any Liberian vessel of 75 tons or more shall sail from any port, there shall be in force shipping articles with every seaman on board except with persons who are apprenticed to, or servants of himself or the vessel’s owner, who are not deemed to be seafarers – is amended to ensure conformity with the Convention. The Committee notes the Government’s indication that Marine Notice MLC-001 will be revised in the near future to replace the reference to guest entertainers with “Guest entertainers for special appearances during a single voyage, whose principal place of work is ashore”. The Committee further notes the Government’s information that it is proposed to amend section 320 of the RLM-107 as follows: “Before the master of any Liberian vessel sails from any port, there shall be in force: a seafarer’s employment agreement between the shipowner and every seafarer on board such vessel; and Shipping Articles (sometimes referred to as Articles) with every seafarer on board the vessel …”. The Committee welcomes this information and requests the Government to ensure that the necessary measures are adopted to fully comply with the Convention by ensuring that any person who is employed or engaged or works in any capacity on board a ship is covered by the Convention, and to provide updated information on the amendments to the relevant legislation.

2. Cadets. The Committee notes that, in reply to its comments, the Government indicates that, as regards the consideration of cadets vis-à-vis the criteria of Resolution VII concerning information on occupational groups (adopted in 2006 by the 94th Session (maritime) of the International Labour Conference): (i) cadets, trainees and operations assistants typically spend from six months to one year on board, before they graduate or may be eligible for licensing; (ii) the frequency of periods of work on board ranges from one-to-two times during their training in order to obtain the necessary sea time; (iii) they are exclusively on board to train in activities recorded in the trainee record book and/or university curriculum; (iv) they are not assigned to any independent marine, navigation or emergency duties on board and strictly undergo training necessary to obtain certification in accordance with the International Convention on Standards of Training, Certification and Watchkeeping for Seafarers, 1978 (STCW); (v) they are affiliated to a university or a training programme ashore (the university usually has a MOU with various shipping companies or shipowners’ associations to provide a berth on board); (vi) their contractual or similar arrangements are reviewed for decent working and living conditions including health and social protection; and (vii) they are not paid a wage as provided for in Regulation 2.2, but may be provided with a stipend to enable them to continue with their training programme and thereby graduate. The Government further indicates that, since cadets are seafarers and considering the criteria in Resolution VII, they will be allowed – where applicable – to serve on board with a limited seafarers’ employment agreement and exemptions from certain provisions of the Convention. The Government clarifies that cadets are covered by the MLC, 2006 provisions on minimum age, medical certificate, training and qualifications, working time, repatriation, accommodation and recreation facilities, food and catering, medical care on board and ashore, health and safety protection and accident prevention, shipowners’ P&I insurance for occupational accidents, injuries and illnesses occurring while on board, and shipowners’ financial security obligations under Regulations 2.5 and 4.2. The Government finally indicates that cadets, trainees and operations assistants enrolled in a maritime university and sent on board to complete the sea time required for graduation, may, upon application and satisfactory review of their contractual or similar arrangements, be exempted from Regulation 1.4;Standard A2.1, paragraph 4 (e) and (f); Standard A2.4; Standard A2.5.1, paragraph 2(b), and Regulation 4.5. Normal working hours of cadets and trainees shall be based on an eight-hour day with two days of rest per week and rest on public holidays. The Government indicates that Marine Notice MLC-001 will be revised in December 2025 to incorporate the relevant substantial equivalences for cadets. The Committee takes note of this information and requests the Government to: (i) adopt the necessary measures without delay to ensure that cadets, trainees and operations assistants enjoy the protection provided for by the Convention; and (ii) provide detailed information on each substantial equivalent measure applicable to those categories of seafarers adopted in relation to the relevant Part A of the Code, including explanations on how such measures are conducive to the full achievement of the general object and purpose of the relevant Part A, as well as on the consultations held with social partners.

Article II, paragraphs 1(i), 4, 5 and 7. Definitions and scope of application. Ships. National determination. The Committee notes the Government’s information in reply to its comments, that there are 10 Mobile Offshore Accommodation Units, 166 Mobile Offshore Drilling units and 75 Mobile Offshore Units. Considering that the MLC, 2006, applies to all ships ordinarily engaged in commercial activities, the Committee requests the Government to clarify whether mobile offshore units are engaged in navigation in areas not excluded by the scope of the MLC, 2006, and if so, to specify how the MLC, 2006, is applied to such units.

Article VI, paragraphs 3 and 4. Substantial equivalence. 1. Signing of addendum to the SEA. The Committee notes that, in reply to its previous comments related to the adoption of substantial equivalence provisions regarding Standard A2.1, paragraph 1 (a), the Government indicates that: (i) Marine Notice MLC-003/3.1.15 provides for a substantially equivalent arrangement for Standard A2.1, paragraph 4(b) in the form of a legally binding addendum signed by the shipowner and the seafarer; and (ii) the substantial equivalence is recorded in the Declaration of Maritime Labour Compliance (DMLC), Part I. The Committee notes the copies provided by the Government of the engagement of services’ form; an example of SEA with Addendum; and the DMLC, Part I recording the substantial equivalence. The Committee takes note of this information.

2. Substantial equivalent provisions under Marine Notice MLC-004. The Committee requested the Government to ensure that any substantial equivalent provisions adopted pursuant to section 3.1.2 and 3.4 of Marine Notice MLC-004 strictly comply with Article VI, paragraphs 3 and 4. The Committee notes that, in relation to section 3.1.2 of MLC-004, the Government’s indicates that, as regards the location of sleeping rooms on non-SOLAS ships of less than 500 gross tonnage not engaged in international voyages, these are small ships and for reasons of stability and lack of deck space, all sleeping rooms cannot be constructed above the loadline; there may be a sleeping room located below the loadline to accommodate a maximum of two seafarers. In this context, the Government indicates that it is proposed to amend paragraph 3.1.2 of MLC-004 as follows: “Taking into consideration the functionality, stability and safety on ships of less than 500 gross tonnage, the Administration may permit the location of sleeping rooms below the load line. In such cases, seafarers shall be provided with short periods on board and/or longer leave periods; and the sleeping rooms shall be fitted with: (a) water detection systems and high-capacity pumping arrangements; (b) escape arrangements provide direct access to open deck; and (c) adequate arrangements for lighting and ventilation. The Committee further notes the Government’s information that, with regard to paragraph 3.4 of MLC-004 – under which the Administration may “accept private or semi-private sanitary facilities which do not add effectively to the space available for free movement as a substantially equivalent provision to reduced floor area in the sleeping room. The Government indicates that such sleeping rooms shall be provided with en-suite sanitary facilities providing extra comfort. The Committee takes note of this information. It requests the Government to provide updated information on the proposed amendment to section 3.1.2 of MLC-004, and to ensure that all substantial equivalence measures are recorded in the DMLC, part I.

Regulation 1.1 and Standard A1.1. Minimum age. The Committee requested the Government to adopt the necessary measures without delay to give full effect to Standard A1.1, paragraphs 1 and 4. The Committee notes the Government’s information that it is proposed to amend section 326 of the RLM-107 to provide that: (1) persons under the age of 16 years shall not be employed or engaged on Liberian vessels; (2) a ship’s cook shall be at least 18 years old; (3) night work is prohibited for seafarers under the age of 18, except when the seafarer is engaged in a training programme accepted by the Commissioner or the Deputy Commissioner; and (4) persons under the age of 18 years shall not be engaged or employed in any hazardous work on board a Liberian vessel which is likely to jeopardize their health or safety. The Committee requests the Government to adopt the necessary measures without delay to fully comply with Standard A1.1, paragraphs 1and4, including the amendment of section 326 of the RLM-107. Concerning safety and health of young seafarers, the Committee notes with interest the Government’s reference to section 3.3.5 of the MLC-005, as revised in 2024 (Rev. 08/24) according to which the Administration has determined after consultation with the shipowners’ and seafarers’ organizations, a list of types of work (corresponding to those provided under Guideline B4.3.10, paragraph 2), which are potentially hazardous and likely to jeopardize the health and safety of young seafarers under the age of 18 years. When assigning potentially hazardous work to young seafarers under the age of 18 years, the shipowner should consider, in particular, work involving, but not limited to, such activities. The Committee also notes that, under section 3.3.3 of the MLC-005, shipowners shall adopt, effectively implement and promote an occupational health and safety programmes on potentially hazardous work for young seafarers under the age of 18 years undertaken only under appropriate supervision and instruction. The Committee recalls that the Convention, under Standard A1.1, paragraph 4, requires the absolute prohibition for young seafarers of the types of work considered hazardous but allows, under Guideline B4.3.10, the determination of types of work which young seafarers cannot undertake without adequate supervision and instruction. The Committee accordingly requests the Government to the determine, after consultation with the shipowners’ and the seafarers’ organizations the types of work that shall be prohibited, without exception, for seafarers under the age of 18, as required by Standard A1.1, paragraph 4.

Regulation 1.4 and Standard A1.4, paragraphs 2-7. Recruitment and placement. Private services. The Committee notes that, in reply to its previous comments, the Government indicates that currently, there are no seafarers’ recruitment and placement services operating in Liberia. Recently, Liberia established the ’Liberian Maritime Training Institute’ (LMTI). LMTI has a manning office that only facilitates the employment of its cadets/trainees with shipowners globally. The Committee takes note of this information.It requests the Government to report on any future developments regarding the existence of recruitment and placement services in Liberia.

Regulation 2.1 and Standard A2.1, paragraph 1. Seafarers’ employment agreements. Requirements. The Committee requested the Government to indicate: (i) the measures taken to ensure that masters have a seafarers’ employment agreement (SEA) in conformity with Standard A2.1, paragraph 1; and (ii) the relevant national provisions authorizing the master to act as a representative of the shipowner when signing the shipping articles. The Committee notes with interest that the MLC-003 has been amended to provide that any signatory other than a shipowner shall produce a signed ‘power of attorney’ or other document showing that he/she is authorized to represent the shipowner. With regard to measures taken to ensure that masters have a SEA in conformity with the Convention, the Committee notes that, while RLM-108 section 10.320(2) states that every seafarer, including the master, joining a vessel to commence employment on board shall sign the Shipping Articles prior to the vessel’s departure from the port, there appears to be no requirement for a SEA to be signed between the shipowner and the master. The Committee requests again the Government to take the necessary measures to ensure that masters have a seafarers’ employment agreement in conformity with Standard A2.1, paragraph 1(a).

Regulation 2.1 and Standard A2.1, paragraphs 1(e) and 3. Seafarers’ employment agreements. Record of employment. Following its previous comments, the Committee notes with interest that section 10.325(2)(a) of RLM-108 has been amended (RLM-108, series 11/2024) to provide that requirements for the seafarer’s identification and record books (SIRB) apply to all seafarers covered by the Convention. Moreover, paragraph 3.1.9 of MLC-003, amended in 2025 (rev.04/2025), provides that each seafarer with a SIRB shall have their record of employment entered in this document. The SIRB or other document shall not contain any statement as to the quality of the seafarers’ work or as to their wages. The Committee takes note of this information, which addresses its previous request.

Regulation 2.5 and Standard A2.5.1, paragraphs 1-3. Repatriation. Circumstances. Prohibition of advance payment and to recover costs from seafarers. The Committee noted that, while section 3.6.7 of Marine Notice MLC-003 indicates that the cost of repatriation may be recovered from seafarers’ wages in the circumstances where the seafarer has been discharged in accordance with section 343 of RLM-107, the latter defines the situations according to which a seafarer loses the right to repatriation altogether. The Committee requested the Government to review section 343 of RLM-107 to ensure conformity with Standard A2.5.1, paragraphs 1 and 2(a). It also requested the Government to take the necessary measures to ensure that what is considered to be “serious default of the seafarers’ employment obligations” is explicitly determined by the relevant legislation or applicable collective bargaining agreements as situations where the shipowner may recover the costs of repatriation and not forfeit the seafarer’s right to repatriation. The Committee notes that, in reply to its comments, the Government refers to sections 3.61-11 of the MLC-003 (amended in 2025, Rev. 04/25). It notes that section 3.6.1 of the MLC-003 has been amended to provide that seafarers shall be entitled to repatriation upon expiry of the period of notice given in accordance with the seafarers’ employment agreement. The Committee further notes the Government’s information that it is proposed to amend section 343 of RLM-107 to only refer to situations in which the shipowner may require that seafarers make an advance payment towards the cost of repatriation at the beginning of their employment and recover the cost of repatriation from the seafarers’ wages. The Government also indicates that paragraph 3.6.7 of MLC-003, as revised in 2025 (Rev.04/25), has been amended in line with section 343 of RLM-107 to provide that no shipowner shall require that seafarers make an advance payment towards the cost of repatriation at the beginning of their employment, and from recovering the cost of repatriation from the seafarers’ wages except where the seafarer has been discharged in accordance with section 343. The Committee observes that these provisions would not be in full conformity with the Convention as, while the shipowner may recover the cost of the repatriation under the limited circumstances provided for under Standard A2.5.1, paragraph 3, this situation does not release the shipowner from the obligation to pay for the repatriation in the first instance. The Committee requests the Government toamend the relevant legislation, including section 343 of the RLM-107 and paragraph 3.6.7 of the MLC-003, to ensure full conformity with Standard A2.5.1, paragraphs 1-3. It also requests again the Government to take the necessary measures to ensure that what is considered to be “serious default of the seafarers’ employment obligations” is explicitly determined by the relevant legislation or applicable collective bargaining agreements as situations where the shipowner may recover the costs of repatriation.

Regulation 2.5 and Standard A2.5.1, paragraph 2(c). Repatriation. Entitlements. In its previous comments, the Committee noted that the Government intended to revise section 3.6.1 of Marine Notice MLC-003, in order to reproduce Guideline B2.5.1, paragraph 7, as well as to revise sections 342 and 342B of the RLM-107 accordingly. The Committee notes the Government’s information on the amended text of section 3.6.1 of MLC-003, as well as on the proposed amendment to sections 342 and 342B of RLM-107. Observing that the amendment and proposed amendment do not give effect to Guideline B2.5, paragraph 7, the Committee requests the Government to indicate how it has given due consideration to this provision of the Convention.

Regulation 2.5 and Standard A2.5.2, paragraph 7. Repatriation. Financial security. Documentary evidence. Following its previous comments, the Committee notes with interest that Annex III to MLC-003, as amended in 2025, includes the model certificate for financial security in line with Appendix A2-I of the Convention. The Committee takes note of this information, which addresses its previous request.

Regulation 2.6 and the Code. Seafarer compensation for the ship’s loss or foundering. The Committee notes that, in reply to its comments, the Government refers to a proposed amendment to section 324 of RLM-107, that provides for two months wages’ compensation in case of termination of the SEA due to loss of vessel or abandonment, provided however that the seafarer is not employed as a seafarer during such period and that she/he has not refused substantially equivalent seagoing employment. The Committee takes note of this information and requests the Government to ensure that section 324 of RLM-107 and the relevant provisions of MLC-003 are amended to fully comply with Regulation 2.6 and the Code.

Regulation 2.7 and Standard A2.7, paragraph 3. Manning Levels. Food and catering. The Committee notes that, in reply to its comments, the Government supplied a minimum safety manning certificate that, while mentioning that ships with a manning of 10 or more shall be provided with a ship’s cook trained and certified in accordance with the STCW and Regulation 3.2 of the MLC, 2006, did not include in the actual crew a ship’s cook for a ship with a minimum manning of more than 10 seafarers. The Committee requests the Government to take the necessary measures without delay to ensure that, for ships with a crew of ten or more, the ship’s cook, is in practice, included as part of the required manning, in conformity with Standard A2.7, paragraph 3.

Regulation 4.2 and Standard A4.2.1, paragraphs 11 and 14. Shipowners’ liability. Financial security. Documentary evidence. The Committee notes with interest the Government’s reference to MLC-005, as amended in 2024, which includes in Annex I the information to be included in the certificate of financial security in line with Appendix A4-I of the Convention. The Committee takes note of this information, which addresses its previous request.

Regulation 4.5 and the Code. Social security. The Committee notes that, in reply to its comments, the Government indicates that it will shortly provide the information on social security for seafarers ordinarily resident in Liberia. The Committee requests the Government to take without further delay the necessary measures to ensure that seafarers ordinarily resident in Liberia and their dependants benefit from social security protection in the three branches specified (old-age benefit, employment injury benefit, invalidity benefit), which is not less favourable than that enjoyed by shoreworkers resident in Liberia. It also requests again the Government to provide: (i) statistical information on the number of seafarers ordinarily resident in Liberia, (ii) information on the benefits granted to the resident seafarers in the three branches mentioned above.