USCG 5-Year Certificate of Documentation

It is finally a reality, a small change for the better, and we renewed and got ours - the United States Coast Guard (USCG) Certificate of Documentation (COD) valid for 5-years.

Delivery Time and Cost

• 26 days - Time from COD Renewal request to US delivery.
• 41 days - Time from COD Renewal request to delivery in Philippines
• $200.05 - Total cost. COD Renewal Fee of $130.00. United States Postal Service (USPS) Express Mail International Fee of $67.85. Philippines Presentation to Customs Charge of 112 pesos (US $2.20).

Timeline of USCG COD Renewal and Delivery

• 13 March 2019 - COD Renewal Request Submitted to NVDC by Email.
• 27 March 2019 - COD Renewal Fee of $130.00 Posted to Credit Card
• 3 April 2019 - Official Issue Date As Printed On COD
• 5 April 2019 - COD Renewal Indicates Finished on NVDC website
• 9 April 2019 - COD Renewal Received at Mail Forwarder, St. Brendan's Isle, Florida
• 10 April 2019 - Sent To Philippines By USPS Express Mail International
• 14 April 2019 - Arrives in Manila, Philippines
• 24 April 2019 - Physical Receipt of COD Renewal in Naga City, Cebu, Philippines

What is a USCG COD? In its most simplest form, a USCG COD serves as both a registration document and functions as a title of ownership of a vessel.  Per the National Vessel Documentation Center (NVDC) website FAQs: "Vessel documentation is a national form of registration. It is one of the oldest functions of Government, dating back to the 11th Act of the First Congress. Documentation provides conclusive evidence of nationality for international purposes, provides for unhindered commerce between the states, and admits vessels to certain restricted trades, such as coastwise trade and the fisheries."

Is a USCG COD mandatory? No. As a recreational vessel there are multiple registration options available to freely choose from - state registration, USCG registration, or foreign country international registration. Each form of registration has its advantages and disadvantages, so one needs to compare and make a choice. We choose USCG registration, but seriously considered foreign international registration to avoid the US based bureaucracy and regulatory annoyances.  Barring the hassles of initial USCG registration that we experienced, having to renew it annually each year is another big inconvenience - especially if your located outside of the US.

USCG COD Legalities. With USCG COD registration comes the requirement to be in-compliance with "ALL" the legally, enforceable by law, US regulations. Owning a recreational vessel is not that much different than other forms of transportation, as each form of transportation has its own plethora of legal requirements; and ignorance of the law is not an excuse for noncompliance.

In regards to the USCG COD, a notable legal requirement listed in the Electronic Code of Federal Regulations (e-CFR) is section 46 CFR 67.313 - "Requirement to have Certificate of Documentation on board. (a) The person in command of a documented vessel must have on board that vessel the original Certificate of Documentation currently in effect for that vessel."  This legal requirement means if you do not have a VALID and ORIGINAL COD on board your vessel, you are prohibited by law from operating your vessel. So prior to the passage of the Coast Guard Authorization Act of 2018 (Section 512), signed into law Tuesday, Dec. 4, 2018 which authorized the 5-year validity of the COD, a documented vessel owner had to renew the COD annually every year. What makes this inconvenient, especially for a vessel outside of the US, is the amount of time for the NVDC to issue it, postal delivery time to a US address, and then the amount of time and cost for the delivery to a foreign country.

Our 2019 USCG COD Renewal Process.

We first went to the National Vessel Documentation Center (NVDC) website and downloaded and reviewed the new submission requirements contained in a PDF file titled, Certificate Of Documentation Application For Renewal (NVDCINST 16713).  The instructions were pretty clear - the online Pay.gov website was to be used ONLY for a 1-year COD renewal; the 5-year COD renewal required the submission of approved USCG forms available on their website.

We downloaded the following PDF files from the NVDC Instructions and Forms webpage.

• CG-1280 Renewal of Certificate of Documentation
• CG-7042 Credit Card Form
• Filing of Instruments via .pdf/Fax/Mail

We easily filled out the CG-1280 Renewal of Certificate of Documentation form in a few minutes - it has detailed instructions printed right on the form.

When we filled out the CG-7042 Credit Card Form, we followed the requirements identified in the PDF file titled, Certificate Of Documentation Application For Renewal (NVDCINST 16713).  On the CG-7042 form, in section L. INDICATE SERVICE REQUIRED, we checked the block "Application for Renewal $26.00". We also checked the block "Other" and filled in the entry fields as follows: Other __2-5 YEAR RENEW__ Amount $ 104.00_.  This results in block I. AMOUNT OF CHARGE being filled in as $130.00. The rest of the form CG-7042 was filled out as required.

Both filled out forms, CG-1280 and CG-7042, were scanned and made into an single PDF file. This PDF file was attached to an email and sent to the NVDC at email address NVDC.PDF.FILING@uscg.mil per the instructions in PDF file, Filing of Instruments via .pdf/Fax/Mail.

The COD renewal was submitted by email on Wednesday, 13 March 2019 2:57 PM local Philippine time.

Selection of the NVDC Case Processing Report, available on the bottom of the home page of the NVDC website revealed about a 3-4 week back log existed on renewal submissions before ours might be acted upon - we checked the updates to this report weekly.  The next day we also verified NVDC receipt of our submission by selecting from their main webpage the Paperwork Status Inquiry, then Work Packet Search, which displays the NVDC Work Packet Search Page. On this webpage, we entered our Official Number: 600692 and selected the Search option which displayed confirmation our renewal submission was received on 13 March 2019 as indicated in picture below.

The next progress indication we had on our COD renewal was the posting of the $130.00 fee on our credit card which occurred on 27 March 2019.  On 5 April 2019, we checked the NVDC Work Packet Search Page and the status had changed and stated, "No Pending Work Items", which we assumed meant our COD renewal was completed and was in the mail headed to our US address.

On 9 April 2019, the letter from NVDC containing our new USCG COD was received at our mail forwarder, St. Brendan's Isle, Florida. The picture of the NVDC letter below is a copy of how it is displayed in our St. Brendan's Isle online, web-based mailbox.

The same day, 9 April 2019, by website access, we requested that the letter from NVDC containing our new USCG COD and a few other mail items be sent to our location in Naga City, Cebu, Philippines. The folks at St. Brendan's Isle are always very responsive and had it mailed out the very next day by United States Postal Service (USPS) Express Mail International at a cost of $67.85. They also notified us by email that it was sent and provided the tracking number to monitor its progress.

Monitored the progress of tracking number EP850401652US daily on the USPS Tracking website. The USPS tracking status indicated it arrived in Manila, Philippines on 14 April 2019. Once in the Philippines, the USPS statues are not reflective of reality and tracking it on the Philippine PHLPOST website is also needed. Twice on the PHLPOST status it indicates "Unsuccessful delivery" or  "Attempted Delivery" on the USPS tracking status - this is an outright fabrication (LIE) by the Philippine Postal system to manipulate delivery statuses to make it appear they are compliant with the sending host countries postal agreements and standards.  It took the US postal system 4 days to deliver the Express parcel to Manila, Philippines, over 9,000 miles.  It took the Philippine postal system 10 days to deliver the Express parcel from Manila, Philippines to Naga City, Cebu, just over 550 miles - their stated standard for Express mail delivery to our location is within 1-2 working days.  Delivery in the Philippines does not mean delivery to your place of residence, it means you have to go in person and pick it up at a local Philippine post office - we have never had a delivery to our residence in the Philippines by PHLPOST.  The following two tables document the tracking status of tracking number EP850401652US in both the PHLPOST and USPS systems.

On 23 April 2019, we went and talked to a lady that works at the Naga City post office and inquired about the status of our Express mail parcel. She stated they had not received it yet and she would text the wife's cell phone when it arrives - the wife and her are friends. The next day,  24 April 2019, we received a cell phone text message from her stating it had arrived.  We walked to the Naga City post office, paid the Presentation to Customs Charge of 112 pesos (US $2.20), and took possession of our Express mail envelope.

We stopped at a copy shop after the post office and had twenty color copies, both sides, of the new USCG COD made at a cost of 80 pesos (US $1.57)

We placed the original and the twenty copies of the USCG COD in our Master Ship Log book. Lastly, we updated our Due Date tracking list for the USCG COD entry to its next expiration date of 31 March 2024.

Update: When reviewing the reverse side of our new 5-year USCG COD, noticed something a little strange in the "fine print.  It states, " This certificate is valid for one year." While the USCG COD is a legal document and I'm no lawyer, wonder which statement takes legal precedent, the front side which has dates indicating valid for 5 years or the reverse side which states it valid for one year? As a result of this discrepancy sent an email inquiry to the USCG NVDC - response below.

Update: Received by email the following response:

From: Campbell, Laura C CIV [mailto:Laura.C.Campbell@uscg.mil]
Sent: Wednesday, July 31, 2019 11:33 PM
To: jodieabbott@sailingindra.com
Subject: DOVE, on 600692
Importance: High

Dear Mr. Abbott,

As a vessel owner, you are aware, the expiration date for the COD is on the front left corner and for the DOVE, ON 600692, expires March 31, 2024.  All law enforcement personnel are educated and trained on our documents and should there be a question, the NVDC will be engaged to make a determination of validity.  If you explore our website, you will see under Latest News that we have information regarding the multi-year renewal. https://www.dco.uscg.mil/Our-Organization/Deputy-for-Operations-Policy-and-Capabilities-DCO-D/National-Vessel-Documentation-Center/

The Coast Guard Authorization Act of 2018, signed into law Tuesday, Dec. 4, 2018 includes a provision which allows recreational Certificate of Documentation (COD) holders the ability to select a multi-year document (1-5 years) during an implementation period designated as January 1, 2019-December 31, 2021, after which a five-year document (recreational vessels only) will become automatic.  Establishing a change of this proportion is a complex request that cannot be performed instantaneously.  It requires multiple changes in all areas of work to including the computer system, forms, regulations, and other requirements.  Most of these changes have not been made because of lack of funding, working with other Agencies or complications to the computer programming required.  We also have approximately a 3 year supply of forms and we have made the decision to continue to use in order to use taxpayer money wisely, and the one year requirement still applies to all commercial vessels.  Most of the changes required to execute this are still outstanding and are being addressed during the implementation period outlined above.

This is a recreational vessel, carrying no passengers, engaging in no trade.  You should experience no complications on this minor annoyance as long as you follow the laws in your area.  The Coast Guard and local law enforcement agencies, including state, are well versed in our laws and regulations (46 CFR 67) and knowing what to look for on the COD.  As I said before, the NVDC is the authority should any questions of the validity of the COD arise.

Please be assured your COD is valid until March 31, 2024, as long as there are no changes regarding the vessel, name tonnage, dimensions, propulsion, ownership, hailing port, restrictions, entitlements, remarks and endorsements.  Address changes must be reported to the NVDC immediately.  Although you will not be required to certify to that fact on an annual basis for renewal, you are still bound to that requirement to insure your COD remains valid.  The informational paragraphs on the back of the COD are not a barrier to the validity nor contain information regarding the specifics of the vessel.

Laura C. Campbell

Chief, Data Management & Administration Division

National Vessel Documentation Center

U.S. Coast Guard

Department of Homeland Security

Phone: 304-271-2400

Fax: 304-271-2405

Our guidance/advice is predicated only upon the information as submitted.  If that information proves imprecise or incorrect or changes materially, our guidance/advice may change.  We provide definitive guidance relative to vessel documentation only upon the presentation of materials in accordance with the regulations found in 46 CFR Subpart 67.