Circular 18/11:US Pollution California - Changes in Certificates of Financial Responsibility [COFRs] Requirements

  • Californian Code of Regulations relating to financial security now requires owners to submit their Certificate of Entry (CoE) to apply for a COFR within three working days of entering local waters.
  • Members calling at Californian ports around 20th February are recommended to renew their P&I cover in advance to ensure a new CoE can be issued in time for submission in the COFR application. 
  • This circular is only published electronically.  Members requiring a hard copy should download and print a pdf from the Circulars section of the Club website (

Dear Sirs

USPollution California  - Changes in Certificates of Financial Responsibility [COFRs] Requirements

Members are requested to note that the Californian (CA) Office of Spill Prevention and Response (OSPR) has recently amended the relevant provisions in the CA Code of Regulations (CCR) on evidence of financial security and renewal procedures for CA Certificates of Financial Responsibility (COFRs).

The amendments include a requirement for tank and non-tank vessels entering CA marine waters during the 30 day post renewal period from 20


February to submit their Certificate of Entry (CoE) for the new policy year within three working days prior to entering these waters in order to apply for a CA COFR.

The IG has expressed strong concerns to CA OSPR, since this amendment wrongly assumes that all owners complete their renewal negotiations well in advance of 20


February each year and will be in possession of their new CoE either immediately before, or on, 20


February when applying for their CA COFR.

However, CA OSPR has maintained this requirement in the amendments to the CCR. The amended CCR is now in force.

Members with vessels calling at CA ports on or around 20


February each year are therefore recommended to renew their P&I cover for the following policy year well in advance of this date in order to ensure that the new CoE can be issued and submitted to CA OSPR for the new COFRs and compliance with the CCR.

Members should contact the Managers should they have any queries regarding the above.

All Clubs in the International Group of P&I Clubs have issued similar circulars.

Yours Faithfully,


  • Members with any questions regarding this circular should contact their usual underwriting contact.


Staff Author