Marine Winch TCO Analysis: Why CCS Certification Reduces Long-Term Costs for Offshore Projects

 

FJ series marine hydraulic winch with CCS certification

Marine Winch TCO Analysis: Why CCS Certification Reduces Long-Term Costs for Offshore Projects

Ningbo Flag-up Hydraulic has produced hydraulic components for the marine and offshore sector since April 2010, with a 20,000 m² production footprint in Haishu district, Ningbo. The marine winch product family that bears China Classification Society (CCS) type approval sits inside that footprint and is the focus of this analysis.

The article is written for offshore-procurement engineers, vessel-newbuilding project managers at shipyards, technical superintendents at OSV owners, and OEM winch buyers who already know they need a marine hydraulic winch and are now trying to decide whether CCS certification matters enough to justify specifying it as a hard requirement. It also speaks to marine-equipment brand owners who currently source un-certified winches and want to understand the multi-year cost gap between the two paths.

The reference product family is the FJ series marine winches with CCS certification range, which spans light-duty fishing-vessel applications up to 150 kN (15-ton) mooring-class units with A2FE / A6VM piston motors. The product naming convention encodes the working load, drum size, line speed, motor variant, and certification status, and is one of the few marine winch lines globally where CCS approval is built into the part number rather than carried as an optional accessory.

For buyers evaluating the wider marine winch portfolio, the winch solutions and after-sales support page covers the documentation flow, the installation drawing review, and the commissioning-test attendance that closes the buyer’s side of the TCO calculation. The technical support team can be reached through the contact page for vessel-specific TCO requests.

The TCO framework below is not a price comparison between Chinese and European suppliers, and it is not a warranty-cost ranking. It is a 12-year cost-of-ownership model that traces every cost component a CCS-certified marine winch incurs over the typical offshore service life, against the same cost components for a functionally equivalent but non-certified winch operating in the same service profile. Where a number cannot be traced to a published source, it is left as a relative weighting rather than a fabricated figure.

Quick Read

  • What changes at acquisition. A CCS-certified FJ-series winch has a meaningful price premium over an un-certified marine winch of the same pulling class. The premium is recovered through three documented channels: lower port-state inspection findings, faster flag-state survey turnaround, and predictable spare-parts compatibility with the type-approved drawing set.
  • What changes over the service life. Annual operating cost is dominated by maintenance intervals, certification-driven documentation overhead, and drydock survey cost. CCS certification changes the documentation flow and the drydock outcome, both of which scale into the multi-year TCO.
  • What changes at exit. Resale value on a vessel that retires from offshore service is materially higher when the deck machinery list includes certified winches, because the next operator is typically a more regulated jurisdiction or a flagged state that requires type approval as a precondition of vessel re-registration.
  • What does not change. Hydraulic efficiency, working-load envelope, line-speed envelope, drum capacity, and basic wear rates are not certification-dependent. The certified and un-certified units perform the same physical work.

Why Total Cost of Ownership, Not Purchase Price, Drives the Right Marine Winch Specification

Most marine winch specifications are written as a purchase-price decision because the shipyard or the OEM winch buyer is the only party whose P&L line item is touched. The vessel owner, the technical superintendent, the flag-state surveyor, the port-state control officer, and the next buyer are all downstream of that initial PO. The first owner pays the acquisition premium; the other four pay the certification gap.

The 12-year service envelope. Offshore service winches are typically specified for a vessel operating life of 12 to 25 years, with one or two mid-life drydock surveys in that window. The 12-year envelope is the minimum horizon at which certification-related savings actually accumulate to a meaningful amount. Anything shorter than the first mid-life survey (typically 5 years) understates the TCO advantage of certified gear.

Why the TCO is a maintenance-cost calculation, not an acquisition-cost calculation. Acquisition cost is a single line item at year zero. Maintenance cost accumulates every year for the vessel life. Survey cost recurs at every drydock. Documentation cost is a per-event overhead at every port-state inspection. Resale-value impact is realized at year 12-25. The certified-units’ higher acquisition cost is paid back inside the first drydock cycle when the certified winch passes survey with no remediation work.

Why this matters for offshore projects specifically. Offshore vessels (OSVs, PSVs, AHTS, drilling rigs, dredgers, cable layers, wind-farm installation vessels) face stricter survey regimes than coastal or harbour-service vessels. They are routinely inspected by CCS, ABS, DNV, LR, BV, RINA, ClassNK, and KR depending on the flag and the operating area. A non-certified winch on an offshore vessel is a survey-risk item that surfaces in the drydock report and follows the vessel for its whole life.

The reference envelope. For this analysis the reference working envelope is a 6 to 15-ton pulling class marine hydraulic winch used in mooring and anchor-handling service on offshore support vessels, with intermittent deck-crane-davit duty. Smaller fishing-vessel units and larger mooring-class units both follow the same TCO pattern with different numerical weightings, and the structural argument generalizes to both ends of the pulling-class spectrum.

The 5 Cost Components of a Marine Winch’s 12-Year TCO

The TCO of a marine winch over a 12-year service life resolves into five cost components. Each component is certification-sensitive; the certified and un-certified units differ in how much each component contributes to the total.

1. Acquisition cost. The purchase price paid by the shipyard or OEM buyer, including any engineering change orders and the certification surcharge if applicable. CCS-certified winches carry a meaningful per-unit premium because the type-approval process is a one-time engineering exercise amortized into the production line.

2. Maintenance cost. Annual preventive-maintenance cost including wear-part replacement (brake pads, seals, hydraulic hoses, motor-overhaul kits), condition-monitoring labour, and the cost of unscheduled downtime when the winch fails mid-operation. CCS type-approval constrains the manufacturer to publish a maintenance schedule aligned with the type-approved drawing set, which makes planned-maintenance cost more predictable and reduces the unscheduled-downtime probability.

3. Certification documentation cost. The recurring overhead of producing, archiving, and presenting the winch’s certificate of type approval, the factory test report, the material certificates for the drum and the gearbox, and the welding procedure qualification records at every port-state inspection. Certified units ship with this documentation complete; un-certified units must reconstruct it for each survey event.

4. Survey cost. The cost of the drydock survey itself, including the time the vessel is off-hire, the surveyor’s fee, and any remediation work triggered by survey findings. Surveyors have discretion to request additional testing or remediation when the equipment list includes non-certified components, and this discretion is the source of the certified-units’ survey-cost advantage.

5. Resale-value impact. The price differential when the vessel is sold, scrapped, or re-flagged, attributable to whether the deck machinery is certified or un-certified. Buyers in regulated offshore markets pay a premium for type-approved equipment, and that premium is realized only once but at a meaningful magnitude because the deck-machinery list follows the vessel.

The 4 Routes Through Which CCS Certification Lowers Each TCO Component

The TCO advantage of a CCS-certified winch is not a single mechanism. It operates through four documented routes, each touching a different TCO component and a different stakeholder.

Route 1: Acquisition-cost discipline. CCS-certified marine winches are produced under a factory audit regime that requires documented incoming-material inspection, in-process inspection, and final-load-test records. The audit regime forces the manufacturer to control variation at the production line, which compresses the engineering-change-order rate over the production run and reduces the per-unit cost of non-conformance remediation. The buyer sees a cleaner first-article inspection outcome and a more stable delivery schedule.

Route 2: Survey-cycle discipline. Flag-state surveyors (the class society surveyor acting on behalf of the flag state administration) treat type-approved equipment as a closed case during the annual and renewal surveys. They verify the certificate is current, confirm the equipment matches the type-approved drawing set, and move to the next item. Non-certified equipment triggers the discretionary survey clause, which gives the surveyor latitude to request additional testing, hold the vessel, or impose operational limitations until the equipment is brought into compliance.

Route 3: Documentation-cost discipline. Every CCS-certified winch ships with a standardized document package: the type approval certificate, the factory test report, the material certificates for the load-bearing components, the welding procedure qualification records for the drum and frame, and the operational-and-maintenance manual aligned with the class-society format. This package is delivered once and reused for every survey event for the life of the vessel. Un-certified units must reconstruct equivalent documentation for each survey event, often with incomplete records because the original equipment manufacturer did not retain the test data.

Route 4: Resale-value discipline. When a vessel is sold or re-flagged, the deck-machinery list is part of the technical due diligence. A certified winch list shortens the buyer’s qualification process and broadens the pool of eligible buyers because the next operator does not have to absorb the re-certification cost. Un-certified deck machinery narrows the eligible buyer pool to those willing to undertake a re-certification project on their own account.

The CCS Type-Approval Process and What It Actually Tests

The China Classification Society type-approval scheme for marine winches is administered under the CCS “Rules for Classification of Sea-Going Steel Ships” and the related type-approval guidelines. The process that produces a CCS type approval certificate is a documented engineering exercise with a specific scope.

Stage 1: Design review. The manufacturer submits the winch’s design documentation to CCS for review against the relevant CCS rules and standards. The submission includes the general arrangement, the load-bearing calculation package, the hydraulic schematic, the material specifications for the drum, frame, gearbox, and braking system, and the planned test program. CCS reviews the package against the rules and issues comments that the manufacturer must close before proceeding to the next stage.

Stage 2: Prototype test. A representative production-prototype winch is tested at the manufacturer’s facility under CCS surveyor attendance. The test program includes the rated-load static test, the overload test (typically 1.5x the rated load), the dynamic-cycle test, the brake-holding test, the hydraulic-function test, and the environmental test where applicable (temperature, salt-spray, vibration depending on the equipment category). CCS witnesses the test, records the results, and either passes the prototype to stage 3 or requires re-test after corrective action.

Stage 3: Factory audit. CCS audits the manufacturer’s production line to verify that the certified winches will be built to the same standard as the tested prototype. The audit covers incoming-material inspection records, in-process inspection records, final-load-test records, calibration of test equipment, and the qualification of welding and assembly personnel. The audit findings are documented and any non-conformances must be closed before the type approval certificate is issued.

Stage 4: Certificate issuance and surveillance. CCS issues the type approval certificate, which is valid for a defined period (typically 5 years) subject to annual surveillance audits. The surveillance audit confirms that the production line is still in conformance with the type-approved design, and the certificate is renewed at the end of each cycle. Loss of surveillance (e.g. a manufacturer that stops paying the audit fee or refuses the audit access) invalidates the certificate, and downstream vessel operators must then re-qualify the equipment.

What type approval does not cover. CCS type approval certifies that the winch, as designed and built, meets the CCS rules for the intended service category. It does not certify the vessel, it does not certify the installation, and it does not substitute for the class society’s survey of the installed equipment. The vessel’s classification survey and the equipment’s type approval are separate compliance paths that both have to be closed.

For independent confirmation, the China Classification Society publishes its type-approval scheme and the rules framework at ccs.org.cn, and the IACS (International Association of Classification Societies) framework that CCS operates within is published at iacs.org.uk. The other major class societies publish comparable type-approval schemes that follow the same general pattern: Bureau Veritas, DNV, Lloyd’s Register, American Bureau of Shipping (ABS), RINA, ClassNK, and Korean Register. The international maritime regulatory framework that governs vessel survey regimes is published by the International Maritime Organization and the equipment-classification standards are coordinated through the ISO and IEC standards bodies.

The Survey-Cost Channel: How Flag-State Surveyors Treat Type-Approved vs Un-Certified Winches

The survey-cost channel is the largest certification-driven TCO saving over the 12-year service life, and it is the channel most often underestimated in acquisition-stage cost models. The channel is governed by the interaction between the acquisition-cost premium and the per-event survey-outcome gap.

Closed-case survey for type-approved equipment. When a flag-state surveyor inspects a CCS-certified marine winch during the annual survey or the renewal survey, the surveyor’s task is procedural: verify the certificate is current, verify the equipment serial number matches the type-approved record, verify the on-board maintenance log shows the manufacturer-specified maintenance schedule has been followed, and confirm the equipment is in operational condition. The survey then closes on the deck-machinery list. Time on board: a small fraction of a day.

Discretionary survey for non-certified equipment. When a flag-state surveyor inspects an un-certified marine winch, the surveyor’s task expands to a discretionary review: confirm the equipment’s basic suitability for the vessel’s service category, assess the condition of the load-bearing components, request additional testing where the surveyor judges the evidence base is insufficient, and potentially impose operational limitations (e.g. reduced line-pull envelope, restricted service area, or hold the vessel until the equipment is re-qualified). Time on board: a full day, often longer if testing is requested.

The off-hire cost driver. The surveyor’s time on board is not the dominant survey cost. The dominant cost is the vessel’s off-hire position during the survey: a vessel waiting at the dock for the surveyor is a vessel not earning its operating day rate. For an OSV at a multi-thousand-dollar-per-day operating rate, a survey that takes an extra day because of discretionary review on un-certified equipment is a meaningful TCO component that does not appear on the winch’s own purchase order.

Survey findings that follow the vessel. A non-conformance finding in a drydock survey is recorded against the vessel and follows the vessel for the rest of its classification life. Repeated findings on the same equipment can trigger escalation to the flag-state administration, which has authority to detain the vessel or restrict its operating area. The certified-units’ closed-case survey outcome does not produce this escalating record.

The acquisition-cost premium that funds the survey advantage. The certified-units’ higher acquisition cost is what funds the engineering work, the prototype build and test, the factory audit, and the ongoing quality-system overhead that produces the type-approved drawing set and the published maintenance schedule. The premium is recovered through the survey channel faster than most acquisition-stage decision models predict: the survey-cost saving begins at the first drydock survey (typically the 5-year renewal) and accumulates over the vessel life. The premium is most expensive to skip on vessels that operate in multiple jurisdictions, where the discretionary survey clause is exercised in every port-state inspection rather than only at the flag-state renewal survey.

The Maintenance-Cost Channel: Type Approval Constrains the Manufacturer’s Documentation Discipline

The maintenance-cost channel is the TCO component most directly controlled by the manufacturer, and it is the channel where the type-approved drawing set has the largest operational impact.

Planned-maintenance predictability. CCS-certified marine winches are produced against a type-approved drawing set that includes the manufacturer’s published maintenance schedule. The schedule defines the inspection intervals, the wear-part replacement intervals, the condition-monitoring procedure, and the consumables list. The vessel’s technical superintendent can plan the maintenance program around the published schedule and order the wear-part kits in advance. Un-certified winches do not have an equivalent published schedule because the manufacturer has no obligation to publish one, and the vessel’s superintendent must develop the schedule from first principles or rely on the un-certified winch supplier’s ad-hoc recommendations.

Wear-part compatibility. A CCS-certified winch ships with a parts list keyed to the type-approved drawing set, and the part numbers correspond to the as-built configuration. Spare-parts ordering is unambiguous. An un-certified winch, especially one sourced from a manufacturer that has changed its model number scheme or its internal part numbering since delivery, can produce parts-ordering ambiguity that delays the maintenance event and forces the vessel to operate with a degraded unit until the correct parts arrive.

Brake-system overhaul. The brake system on a marine winch is a safety-critical component that requires periodic overhaul. The overhaul interval on a certified winch is a published, type-approved parameter that the surveyor expects to see in the maintenance log. The overhaul interval on an un-certified winch is an open question that the superintendent has to negotiate with the manufacturer, often under survey pressure.

Motor-overhaul discipline. The hydraulic motor on a CCS-certified winch is matched to the type-approved drive package, and the motor’s overhaul interval and overhaul-kit part numbers are published. The motor’s overhaul on an un-certified winch is a manufacturer-specific decision that may not align with the class society’s expectations for the vessel’s survey cycle.

The Documentation-Cost Channel: Why Every Survey Event Reuses the Same Certificate

The documentation-cost channel is the most-overlooked TCO component because it does not appear on any single invoice. It is a per-event overhead at every port-state inspection, and it accumulates with every survey event for the vessel life.

One-time delivery, multi-year reuse. A CCS-certified marine winch ships with the documentation package described in the section above: type approval certificate, factory test report, material certificates, welding procedure qualification records, and operational-and-maintenance manual. This package is delivered once at vessel commissioning. It is then reused for every annual survey, every renewal survey, every port-state control inspection, every charterer’s technical due diligence, and every future sale event. The per-event cost of presenting the documentation is trivial; the cumulative saving over the vessel life is meaningful.

Reconstruction cost on un-certified units. An un-certified winch that is delivered without a complete documentation package must have equivalent documentation reconstructed at each survey event. The reconstruction requires the manufacturer to retrieve the original test data, the material certificates, and the welding records from its own archive; in many cases the records are incomplete because the original production run was not under a quality-system audit regime. The reconstruction is a billable engineering service that the manufacturer passes through, and the bill repeats at every survey event.

Port-state control documentation. Port-state control officers (PSCOs) under the regional maritime authority have authority to inspect the documentation package on a foreign-flagged vessel calling at the port. A complete CCS-certified documentation package is accepted at face value; an incomplete package can trigger a more detailed inspection, a recorded deficiency, or a port-state detention in the most serious cases.

The Resale-Value Channel: How Certification Status Follows the Vessel

The resale-value channel is the TCO component that is realized only once at the end of the vessel’s first-owner operating period, but it is the largest single TCO item for the certified winch because the certified-units’ higher resale-value margin can exceed the total accumulated TCO saving from the other channels.

Buyer pool segmentation. A vessel with certified deck machinery has a wider eligible buyer pool because the next operator does not have to absorb a re-certification project. The wider buyer pool produces a more competitive sale process, which produces a higher sale price. A vessel with un-certified deck machinery has a narrower buyer pool, often limited to operators willing to undertake re-certification or operators in jurisdictions with less stringent survey regimes.

Re-flagging documentation. When a vessel is sold to a new operator under a new flag, the new flag-state administration typically requires a documentation package equivalent to a new-building survey. A CCS-certified equipment list is accepted as evidence; an un-certified equipment list triggers a fresh survey project.

Scrap-value differential. Even at the end of the vessel’s operating life, when the vessel is scrapped for steel value and equipment resale, the certified deck machinery commands a higher resale price in the marine-surplus market because the next user is often a smaller vessel operator in a less-regulated service where the certification still adds resale value.

What CCS Certification Does Not Do — and Why It Still Matters in the TCO

A balanced TCO analysis requires the limitations of CCS certification to be made explicit. Certification is not a warranty, not a performance upgrade, and not a substitute for proper installation and maintenance discipline — but each of those limitations is also the reason the certified-units’ higher acquisition cost is justified.

Certification is not a warranty, but it is the basis for one. The CCS type approval certificate certifies that the winch, as designed and built, meets the CCS rules for the service category. It does not extend the manufacturer’s commercial warranty, and it does not commit CCS to repair or replace the equipment in service. The commercial warranty is a separate document between the buyer and the manufacturer — but the warranty is written against the type-approved drawing set, which means the warranty scope is unambiguous in a way that un-certified-winch warranties are not.

Certification is not a performance upgrade, but it is the audit trail for one. A CCS-certified winch has the same hydraulic efficiency, the same working-load envelope, the same line-speed envelope, and the same wear-rate characteristics as an un-certified winch of the same design. Certification adds a documentation and audit regime; it does not change the physical performance of the unit — but the audit trail means that if a vessel operator claims a performance shortfall, the manufacturer has the documented test data to investigate, and the operator has the documented test data to negotiate against. The audit trail is what makes future warranty claims tractable.

Certification does not replace installation discipline, but it is the precondition for it. A CCS-certified winch installed incorrectly still fails in service. The installation has to follow the manufacturer’s installation manual, the vessel’s class-society installation rules, and the flag-state administration requirements. Certification is an equipment-level assurance, not an installation-level assurance — but without certification the installation cannot be verified against the type-approved baseline, and the surveyor has no reference point.

Certification does not replace maintenance discipline, but it is the reference schedule for it. A CCS-certified winch that is operated without following the published maintenance schedule will still fail in service. The maintenance schedule is part of the type approval package, and following it is the operator’s obligation — but the published schedule is what allows the surveyor to evaluate the vessel’s maintenance log objectively, and what allows the technical superintendent to plan the maintenance program in advance rather than under survey pressure.

How the FJ Series Maps to the TCO Framework

The FJ series marine winch line covers the working-load envelope from light-duty fishing-vessel units up to the 150 kN (15-ton) mooring-class units shown on the FJ series marine winches with CCS certification product page. Two specific configurations illustrate how the part-number scheme encodes the certification status into the equipment itself.

FJ17-45.60-140-18-313-ZP-A2FE63 — 6-ton class. This configuration pairs the FJ17 drum-and-frame package (rated for 17 kN nominal working load with the 45-60-140-18-313 gear-train ratio) with an A2FE63 axial piston motor. The “ZP” suffix in the part number is the manufacturer’s internal designation for CCS type approval. The unit is specified for mooring and anchor-handling service on offshore support vessels and on the larger fishing-vessel classes where the flag-state survey regime expects type approval.

FJ36-75-80-24-ZP-A2FM56 — 7.5-ton class. This configuration pairs the FJ36 drum-and-frame package (rated for 36 kN nominal working load with the 75-80-24 gear-train ratio) with an A2FM56 bent-axis motor. The same “ZP” suffix applies the CCS type-approval coverage. The unit is specified for the heavier mooring-duty envelope where the surveyor’s discretionary review on un-certified equipment would have the largest cost impact.

Why the certification is built into the part number. The “ZP” suffix means the buyer cannot accidentally order an un-certified unit and assume it carries the certification. The certification status is a documented property of the part number, which simplifies the procurement specification, the vessel’s deck-machinery list, and the survey documentation flow. The same scheme is used in the FJ-ZPC series of marine man-riding winches with CCS certification, which adds the man-riding service category to the certification scope.

The after-sales documentation flow. For buyers who need to integrate the winch into a vessel’s class-society documentation package, the manufacturer provides winch solutions and after-sales support covering the technical-file preparation, the installation drawing review, and the commissioning-test attendance. This flow is what closes the documentation-cost channel on the buyer’s side of the TCO calculation.

About the Author

Oliver is a member of the Technology Department at Ningbo Flag-up Hydraulic Co.,ltd., a hydraulic system specialist established in 2010 in Ningbo, China. The company operates a 20,000 m² factory with 200+ employees, a 20-person R&D team, and US$30 million in annual sales, focused on substituting imported high-end hydraulic components with domestically engineered alternatives across engineering machinery, mining machinery, port machinery, and lifting and transportation applications. The 20-person R&D team is organized into three specialized centers covering pilot joysticks and electronic control (8 engineers), winches and gearboxes (5 engineers), and cartridge valves and manifold systems (5 engineers), with small 6-person strike teams for rapid response on custom manifold designs. Oliver supports this multi-center R&D structure with a hands-on technical perspective across the company’s eight core product categories.

Frequently Asked Questions

Q1: Does CCS certification apply to the winch only, or to the entire hydraulic system on the vessel?
A1: CCS type approval is an equipment-level certification. It applies to the winch as a self-contained assembly (drum, frame, gearbox, brake, hydraulic motor, and control block). The certification does not extend to the vessel’s hydraulic power supply, the vessel’s piping, the vessel’s control system, or the vessel’s installation. These are covered by the vessel’s classification survey, which is a separate compliance path that operates in parallel with the equipment type approval.
Q2: Can a non-certified marine winch be re-certified by the operator after delivery?
A2: In principle, a non-certified winch can be put through a class-society type-approval or unit-approval process after delivery, but the cost is materially higher than specifying a certified unit at the original purchase. The retrospective certification requires the manufacturer to retrieve or reconstruct the original design records, the material certificates, and the welding records; it requires a witness test on a representative unit; and it requires the manufacturer to bring the production line under a quality-system audit regime. Most manufacturers decline retrospective certification on a single unit, and the operator typically has to source a different manufacturer if retroactive certification is required.
Q3: How long does CCS type-approval remain valid?
A3: The CCS type-approval certificate is issued for a defined period (typically 5 years) subject to annual surveillance audits. The certificate can be renewed at the end of each cycle if the manufacturer maintains the production-line audit regime and the equipment continues to be built to the type-approved design. Loss of surveillance (e.g. manufacturer stops paying the audit fee or refuses audit access) invalidates the certificate, and downstream vessel operators must then re-qualify the equipment.
Q4: Does CCS type approval cover all offshore service categories, or only mooring?
A4: CCS type approval for marine winches is issued against the specific service category declared by the manufacturer. The categories include mooring, anchor-handling, towing, dredger auxiliaries, fishing-vessel duty, man-riding (for the FJ-ZPC series), and a small number of specialized categories. The certificate scope is defined on the certificate itself, and the operator must verify that the declared category matches the intended service. A winch approved for mooring is not automatically approved for man-riding duty.
Q5: What is the difference between CCS type approval and CE marking for marine winches?
A5: CE marking is an EU regulatory compliance mark covering health, safety, and environmental protection requirements; it is required for equipment placed on the EU market. CCS type approval is a classification-society certification covering the equipment’s suitability for the intended marine service. The two are independent compliance regimes: CE marking does not substitute for CCS type approval on a CCS-classed vessel, and CCS type approval does not substitute for CE marking on equipment placed on the EU market. Equipment that ships to both jurisdictions carries both marks.
 

Post time: Oct-20-2026