198 
U. MIAMI INT'L & COMP. L. REV. 
V. 23 
While it is not uncommon to refer to the Passenger Liability 
Regulation ("PLR") Annex I as the "Athens Convention," 
there are some differences between the actual text of the 
Athens Convention as amended by the 2002 protocol and the 
PLR Annex I, which will be addressed in more detail in Part 
III. C. Not only due to textual differences, but also because of 
the different legal natures of the PAL 2002 and PLR Annex I, 
it is imperative that these two texts, which are almost 
identical, be referred to in a manner that distinguishes them. 
Besides the substantive rules of the regulation itself, 
Regulation (EC) 392/2009 contains, as binding annexes, 
large parts of the 2002 Athens Convention, as well as related 
IMO Guidelines. 23 These annexes are integral parts of the 
regulation and therefore, have taken immediate effect. 24 
Further, the PLR goes beyond the Athens Convention. 
Additional rules have been included (such as mobility 
equipment), 25 while some rules of the Athens Convention 
(e.g. regarding the scope of application, liability limitation 
rules, and jurisdiction issues) have been omitted from the 
PLR. 26 The PLR Annex I is almost identical to the Athens 
Convention as amended in 2002 (PAL 2002) while PLR 
Annex II transfers IMO Guidelines, which have also been 
established in EU law in the context of the PAL 2002. These 
annexes to the PLR are legally binding as well. They are 
based on Article 12, sentence 3 and Article 3 of the PLR. 
Furthermore, the EU ratified the PAL in 2002, making it the 
first convention concluded under the auspices of the IMO to 
23 See Beate Czerwenka, Neue Haftungs- und Entschädigungsregelungen in 
der Personenschifffahrt - Harmonisierung durch Europarecht, 5 
Transportrecht 165,167 (2010). 
24 Id. 
23 Id. 
26 See generally id.