The Countdown to SOLAS Implementation is Underway
While some things regarding the IMO's Verified Gross Mass (VGM) requirement have become clearer many things remain vague with less than 100 days to go to the July 01, 2016 implementation date. Let's take a moment to review what we do know.
1. What is Verified Gross Mass (VGM)?
VGM means the weight of each packed container must be confirmed. This VGM must consider the masses of all packages, packing materials, the container tare weight and all additional loading materials. Please refer to Chapter 2.1 of the SOLAS guideline. The VGM is independent of the weight declared in the booking or on the Bill of Lading.
2. How can VGM be determined?
Two ways to determine a VGM in accordance with the new SOLAS regulation:
a) Method 1: Weighing
The container can be weighed upon completion of packing and sealing. Weighing can be performed by the shipper or by a third party contracted by the shipper (See Chapter 5.11 of the SOLAS guideline).Any scale, weighbridge, lifting equipment or other devices used to verify the gross mass of the container must meet the applicable accuracy standards and requirements of the state in which the equipment is being used (See Chapter 2.1 of the SOLAS guideline).
b) Method 2: Calculating
All packages and cargo items may be weighed individually (including the mass of any / all packing materials) and must be added to the container tare weight visible on the exterior of the container (See Chapter 5.1.2 of the SOLAS guideline).
The method used for weighing the container's content is subject to the certification an approval as determined by the competent authority of the state in which the packing and sealing of the container were completed (See Chapter 18.104.22.168 of the SOLAS guideline). Any weighing equipment used to weigh the contents of the container must meet the applicable accuracy standards and requirements of the state in which the equipment is being used.
3. What is the scope of this new regulation?
The new 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.
4. When will the VGM requirement enter into force?
The new SOLAS requirement is valid from 1 July 2016.
5. Weighing Date
The Date of Weighing is not mandatory information as per SOLAS guideline. However, the SOLAS regulation states that a VGM submitted to the Terminal Operator prevails and must therefore be used for stow planning.
6. Authorized Person
Although the shipper named in the carrier's bill of lading remains responsible for VGM as per SOLAS requirements, the authorized Person may not necessarily always be employed by the Shipper but must be duly authorized by the Shipper.
7. Who is responsible for submitting the VGM to the carrier?
The shipper is always responsible for the verification of the gross mass of a container as well as for ensuring the VGM is communicated to the carrier. The carrier itself is not obliged to cross-check the VGM received.
Independent of the party verifying the VGM, and the party that submits the VGM on the Shipper's behalf it remains in the responsibility of the shipper that the carrier and terminal operator receive the information by the Carrier / Terminal Operator advertised deadline.
8. When must the VGM be submitted at the latest?
An industry standard has yet to be developed and may vary from carrier to carrier / terminal operator to terminal operator. J.W. Allen & Company will continue to monitor and provide updates as this situation develops.
9. What are the consequences or penalties when a VGM is not available, not submitted, or misses the designated submission deadline?
Carriers and terminal operators have taken the stance that missing VGM information would require a 'no-load' of the container in compliance with the SOLAS rule as published by the IMO. Shippers will be responsible for any costs that arise (e.g. but not limited to weighing costs, repacking, storage, demurrage and administrative costs) assessed by either / or carriers or terminal operators. Regulatory penalties will be defined by the individual national legislations.
10. Is container weighing in a transshipment port necessary?
No, all packed containers discharged from a SOLAS vessel in the transshipment port should already have a VGM and therefore further weighing in the transshipment port facility is not required.
11. Where can relevant documents be found?
a) Status of national legislations:
b) Guidelines regarding the verified gross mass of a container carrying cargo:
FAQs - New SOLAS regulation February 2016
c) Guidelines for improving safety and implementing the SOLAS container weight
d) The IMO/ILO/UNECE Code of Practice for Packing of Cargo Transport Units (CTU)
and CTU Code informative materials can be found at:
e) OCEMA VGM Best Practices: