Discrepancy between the declared and actual gross mass of a packed container can lead to incorrect vessel stowage decisions and major accidents. To ensure the safety of seafarers and shore-side workers, International Maritime Organization (IMO) will start enforcing the Safety of Life at Sea(SOLAS) amendments to require a packed container to have shipper-verified weight as a condition for loading onto a ship for export.
Effecting SOLAS Worldwide
1. When is the enforcement date?
The new SOLAS amendments go into effect from 1 July 2016. From this date, carriers will only be allowed to load a packed container on board their ships after its VGM has been received (refer to Question 1 in Determining VGM for definition of VGM).
Local authorities may apply different enforcement approaches with regards to transshipment and other in-transit cargoes due for loading onto a vessel on or after 1 July 2016
2. What does the SOLAS regulation apply to?
The regulation applies to all packed containers to which the International Convention for Safe Containers (CSC) applies and which are to be loaded onto a ship subject to SOLAS Chapter VI. All packed export containers will legally need VGM declaration, including all standard sea freight containers, tank containers, flat racks and bulk containers. Effectively, 99% of all global shipping volume will be subjected to this new SOLAS regulation.
3. What is the geographical scope of effect?
The regulation is globally legal-binding. All IMO member countries have undertaken to implement regulation’s amendments, including those in relation to verified gross mass (VGM), in their respective jurisdictions.
4. Will different local authorities enforce SOLAS differently?
It is up to an individual country’s authorities to enforce SOLAS requirements along their own guidelines. For example, certain country’s authorities can decide their own policies on:
- Certification of weighing service providers
- Calibration of weighing scales and methods
- Allowance for VGM versus actual mass variance
5. Is WICE’s policy different from terminals’?
Globally, carriers are not allowed to load a packed container for which VGM has not been provided by the shipper in time, on board its vessels. To comply with the global regulation, from 1 July 2016, WICE will follow a “No VGM, No Load” policy across all countries.
In addition, it is important to note that selected terminals may adopt a “No VGM, No Gate-in” policy at their premises. A packed container without VGM declared may be denied gate entry into these terminals by their operators.
Implications on Shippers
1. As the Responsible Party
The new SOLAS amendments spell out clearly that it is the shipper’s responsibility to provide the VGM to carriers sufficiently in advance to be used in the preparation of the ship stowage plan.
As a result, even in the instance where the shipper engages a third party to obtain the VGM, the shipper will still remain the responsible party. In the case of a missing VGM that causes the shipper’s container not being loaded, the shipper will remain liable for any associated costs.
2. What is the definition of shipper?
The shipper is defined as a legal entity or person named on the bill of lading or sea waybill as shipper and/or who a contract of carriage has been concluded with a shipping company. Hence, depending on the contractual agreement, the shipper can be either the cargo ex/importer or a logistic service provider (NVOCC/consolidator/coloader).
3. Implication on booking process
As a shipper, you will need to ensure that your booking & shipment lead times factor in container weighing time (if any) and your relevant VGM submission cut-offs. With regards to documentation, you will need to submit additional VGM data to WICE, either separately or as part of shipping instructions, depending on the submission channel.
4. Implication on costs
In addition to any costs associated with weighing the containers and submitting the VGM data, you will need to factor in possible costs that might arise when you fail to submit your VGM in time.
5. What will I need to do as a shipper?
As a shipper, you will need to be mindful and ensure to:
- Look at your internal processes to determine who is the legally defined shipper (yourself or a logistics provider)
- Evaluate your weighing options – factoring in relevant costings and procedures
- Decide if you will need to engage a weighing service provider
- Obtain your containers’ VGM data
- Submit your containers’ VGM data to WICE
- Be aware of each terminal’s VGM submission cut-off requirements
- Be aware of local authorities’ SOLAS VGM implementation guidelines, including auditing and penalty rules (if any)
- Seek more information from your local shipper community here necessary
- Contact your WICE representative if you have questions
As your carrier of choice, WICE will do our best to assist you along the process by providing necessary information and timely notifications in case of missing VGM or late submission, and designing a smooth and friendly VGM submission process.
1. What exactly is Verified Gross Mass?
VGM policy requires that the total weight of each packed container must be measured and declared. This total weight not only consists of the weight of all packaging and cargo items, but also the container tare and all additional loading equipment (e.g. lashing material) too. Please refer to Chapter 2.1 of the IMO SOLAS Guidelines for the exact definition of such.
It is important to note that VGM does NOT have the same meaning with the estimated weight declared in the Booking nor with the cargo weight declared on the Bill of Lading.
2. How to determine VGM?
There are two methods for weighing (refer to Chapter 5 of the IMO SOLAS Guidelines)
Weighing the whole container after it has been packed (e.g. weighing the whole truck and containers at certified weighbridge and subtracting truck and chassis weight).
Weighing all the cargo and contents of the container individually, and adding those weights to the container’s tare weight. Factor in additional loading equipment weight, if any.
3. Who can provide the weighing service?
The shipper can do the weighing themselves, or engage a third party certified for such service. However, according to Chapter 2 of the IMO SOLAS Guidelines, any weighing equipment used to weigh the contents of the container must meet the applicable accuracy standards and requirements of the country or state in which the equipment is being used.
In addition, the method used for weighing the container’s content is subject to the certification and approval as determined by the competent authority of the state in which the packing and sealing of the container are completed.
4. Which weighing method is recommended for bulk cargo?
As it is not practical to measure bulk cargo (e.g. scrap or unbagged grain) individually and add up the weight, therefore Method 1 may be more applicable. When you wish to have such bulk cargo weighed at the loading site, please be mindful to verify with the respective terminal on whether they provide certified VGM weighing service for Method 1.
5. In Method 2, can I just submit the cargo gross mass to WICE and you help us add in the tare weight?
The SOLAS regulation puts the responsibility on the shippers to provide VGM, therefore shippers are required to submit the total packed container mass data. But we endeavour to let you have the tare weight data in the most convenient manner possible.
6. Do I need to weigh my containers at a transshipment port?
No. Your containers will already have been VGM-declared at the port of origin, hence no further weighing is needed at the transshipment port.
1. What is the flow of VGM submission?
Under the SOLAS requirements, the shipper named on the bill of lading is the party responsible for providing the VGM data. When shipping with WICE, your default data flow will be shipper > WICE > Carrier > terminal. Upon successfully receiving your declared VGM data, WICE will transmit it to terminal operator on your behalf.
In cases where the shipper uses a terminal’s weighing service to obtain VGM data, the flow will then be terminal > shipper > WICE > terminal. In such situations, note that WICE will still be transmitting shipper-submitted VGM data to the terminal.
2. When do I need to submit VGM?
As specific requirements across governments, ports and terminals can differ, WICE’s VGM submission cut-off deadlines will vary from terminal to terminal. While addressing these external factors, we endeavour to keep each VGM submission cut-off as close to the respective Container Yard cut-off as it is operationally feasible.
In addition, to better assist you in coping up with the varied cut-off deadlines, we will convey shipment-specific cut-offs during your booking process.
3. How do I submit VGM?
Shippers may submit VGM data to WICE via email of your WICE representatives.
4. What information is needed in VGM submission?
Below are the mandatory/optional fields to be filled during submission via any of the above method:
- Booking / Bill of Lading (BL) No. (Mandatory)
- Container No. (Mandatory)
- Verified Gross Mass (VGM) (Mandatory)
- Unit of Measurement (KG or LB) (Mandatory)
- Authorized Person’s Signatory (in CAPITAL) (Mandatory)
- Responsible Party Name (Optional)
- Date of Declaration (Optional)
- Method of Weighing (1 or 2) (Optional)
- Weighing Party Name (Optional)
- Any additional mandatory/optional information as requested by local authorities (e.g. for UK, Weighing Party Certification No.)
It is worth noting that WICE only requires the VGM information as stated above, not actual VGM supporting documents.
5. What if I need to submit VGM prior to Gate-In?
Certain terminals will adopt a “No VGM, No Gate-In” policy, which will require shippers to submit VGM prior to gate-in. It is therefore important to submit your VGM data early, to prevent truckers from being rejected at gate and thus incurring unnecessary costs.
6. Will I be able to amend my VGM after submission?
Yes. We will advise the process for amendment in due course.