If a Contracting State makes no Article 39 declarations, then under Article 29 in that
State all NCRIs in an aircraft object that may arise under its laws will be subordinate to any registered international interest no matter when made. While NCRIs have priority even over unregistered international interests a question can be asked whether it would betrue in reverse that undeclared NCRIs would be subordinate to unregistered international interests since they are subordinate to registered interests
However, Article 29 ‘does not regulate priority between competing unregistered interests’, and Article 39 only applies to NCRI categories which have been
declared under Article 39 so that non-declared rights or interests come under Article 29 as set forth above in Section 3(b)(ii).