2015 
Carrier Liability 
209 
only to PAL but not to the PLR have been omitted in PLR 
Annex I. 65 On the other hand, references to "this 
Convention" 66 were simply copied from PAL 2002 to PLR 
Annex I. This approach is understandable in so far as Annex 
I to the PLR is actually entitled "Provisions of the Athens 
Convention relating to the Carriage of Passengers and their 
Luggage by Sea Relevant for the Application of this 
Regulation." 67 The correct reference, though, should have 
been to 'this Annex' as PLR Annex I does not cover the 
entire text of PAL 2002, which is indicated by the 
aforementioned title of PLR Annex I. 
The EC's choice to replicate large parts of the PAL 
2002 in the PLR Annex I indicates that there was not only a 
rush in the proliferation of passenger-related legislation, but 
also a lack of understanding as to the relationship between 
EU (formerly the EC) law and international law. While the 
EU is to be lauded for its efforts, it remains to be seen 
whether the EU will do a better job at implementing 
international maritime conventions for its member states. In 
relation to its size, Europe has a disproportionately long 
coastline. A large part of the EU's citizens depend on the 
maritime industry directly or indirectly; passenger 
transportation by sea is booming, 68 despite a continued 
slump in other parts of the shipping industry. 69 
65 Cf. e.g. PLR at Annex I, art. 2(1). 
66 E.g. in PLR at Annex I, art. 2(2). 
67 PLR Annex I, Title. 
68 See e.g. Vancouver's cruise ship season extended by worldwide boom, CBC 
NEWS (Nov. 3 2015), http://www.cbc.ca/news/canada/british- 
columbia / vancouver-s-cruise-ship-season-extended-by-worldwide- 
boom-1.3301561. 
69 Jared Vineyard, Is International Shipping Returning to Pre-Recession 
Levels?, Universal Cargo Mgmt. (Sept. 16, 2014),