ABSTRACT
Reflecting the relative maturity of the Japanese shipbuilding sector, the SAJ Form assumes that the seller and builder of the vessel will be the same company, defined as the ‘‘Builder’’.
However, in other jurisdictions, in particular in China, and especially where the shipbuilder is a company of limited size or international reputation, it is not unusual for the export shipbuilding contract to be concluded on the builder’s side by two companies, who will be jointly liable to the buyer for its performance. The two companies, which will be legally and economically distinct, will normally comprise (i) the shipbuilder and (ii) an
provided construction financing for the project.1
