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continues. 42 In particular, due to the multimodal nature of 
many passenger transports, it has been important for the EU 
to strengthen passenger rights across the board. 43 However, 
as expressed by the Attorney General at the European Court 
of Justice, while there are similarities between different 
liability regimes for different modes of transportation, the 
comparability is limited. 44 It is against this background of 
diverse rules that, in 2009, the European Union decided to 
take action on behalf of passengers aboard ships. 
While cruise ships gain the lion's share of media 
attention, the EU's new rules are by no means limited to 
cruise ships. Rather, these rules cover all ships that are 
permitted to carry passengers. 45 With that being said, for the 
time being, the EU regulates only ships within international 
transport, 46 although the member states are free to expand 
the rules to ships within national transport as well. 47 The EU 
has ratified the Athens Convention, and the PLR was meant 
to take effect the moment the Athens Convention became 
binding on the EU, 48 but no later than on December 31, 
42 Jens Karsten, Im Fahrwasser der Athener Verordnung zu Seereisenden: 
Neuere Entwicklungen des europäischen Passagierrechts, 24 Verbraucher 
und Recht 213,214 (2009). 
43 Otmar Philipp, Verbraucherrecht: Rechte von Benutzern verschiedener 
Verkehrsmittel, 23 Europaucherrecht: Rechte von Benutzern versc 
884 (2012). 
44 Case C-509/11, ÖBB-Personenverkeher AG, 2013 (Mar. 14, 2013) 
(http://curia.europa.eu). 
45 While the insurance requirement under PLR Annex I, art. 4bis only 
applies to ships, which are licensed to carry twelve or more passengers, 
the PLR and PAL 2002 apply to all commercial transports of persons by 
sea. 
46 PLR at art. 2. 
47 Id. 
43 PLR at art. 12.