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Treaty, 16 had taken action with regard to liability for 
damages incurred by passengers onboard ships by enacting 
Regulation (EC) No. 392/2009. 17 This regulation aims at 
implementing the Athens Convention, which was ratified by 
the EU. 18 Since December 31, 2012, the EU has required this 
passenger liability regulation to be implemented by EU 
member states. 19 This has been a significant step forward in 
the improvement of passenger rights. However, it certainly 
should not be the last step in this development. 20 
Regulation (EC) No. 392/2009 is based on the 1974 
Athens Convention, 21 which was also amended in 2002. 22 
16 Treaty of Lisbon amending the Treaty on European Union and the 
Treaty establishing the European Community, signed at Lisbon, 
December 13, 2007, http://eur-lex.europa.eu/legal- 
content/ EL / TXT / PDF / ?uri=CELEX:12007L / TXT&from=EN. 
17 See generally Commission Regulation 392/2009, 2009 O.J. (L131) 24. 
18 See generally Council Decision 2012 O.J. (L8) 1; see also id. at (L8) 13. 
19 The Shipowners' Club, Entry into force of the Regulation (EC) No 
392/2009 of the European Parliament and of the Council of 23rd April 
2009 on the Liability of Carriers of Passengers by Sea in the Event of 
Accidents, 8 December 2012, http://www.shipownersclub.com/12839/; 
see also PLR Preambular, at para. 2. 
20 On Dec. 18, 2012, Regulation (EU) No 1177/2010 entered into force, 
which regulates passenger rights more widely. See Fahrgastrechte im See- 
und Binnenschiffsverkehr, 1 Recht der Transportwirtschaft at v (2013). 
21 Int'l Mar. Org., Athens Convention Relating to the Carriage of 
Passengers and their Luggage by Sea (PAL), available at 
http://www.imo.org/en/ About/Conventions/ ListOfConventions/Pag 
es/ Athens-Convention-relating-to-the-Carriage-of-Passengers-and-their- 
Luggage-by-Sea-(PAL).aspx (last visited Nov. 4, 2015); see Tsimplis, supra 
note 9, at 126 (explaining more about the 1974 Athens Convention). 
22 Int'l Mar. Org., Athens Convention Relating to the Carriage of 
Passengers and their Luggage by Sea (PAL), 
http://www.imo.org/en/ About/Conventions/ ListOfConventions/Pag 
es/ Athens-Convention-relating-to-the-Carriage-of-Passengers-and-their- 
Luggage-by-Sea-(PAL).aspx (last visited Nov. 4, 2015).