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SOLAS – VGM – FAQ

When is the regulation effective?

  • July 01, 2016

What is VGM?

  • The Verified Gross Mass – total weight of goods, packing and ocean container combined.

How is VGM Determined?

  • There are 2 methods:
    1. Weigh the entire loaded/sealed container.
    2. Weigh goods to include packing materials, skids, etc. on certified scales, then add that weight to the tare weight of the ocean container

How do I obtain a container’s tare weight?

  • The tare weight is available on the door-side of each container. However, it is also available at most steamship lines websites or by inquiring upon request.

What if the VGM is higher than the maximum payload?

  • Under IMO’s International Convention for Safe Containers (CSC), containers with weight higher than the maximum payload will be prohibited from being loaded on board vessels.

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; therefore, no further weighing is needed at the transshipment port.

Who is responsible for VGM?

  • The Shipper in the respective origin country where the cargo is physically loaded is responsible. However, if the VGM at origin is not properly documented, the shipment may be left off the vessel and affect the destination party.

 Can the shipper hire a third party to weigh their goods?

  • Yes. However, 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.

 Does the Incoterm dictate the responsibility of VGM?

  • No, the incoterms govern the sale of the goods, not the transport of the goods. The shipper is responsible regardless of incoterm agreed upon.

Does a calibrated scale need to be utilized?

  • Yes, based on each respective origin country weights and measures requirements, where the container is loaded and sealed.

Are there specific VGM data elements (information) that must be communicated?

  • Yes, the data elements include:
    • Certified Verified gross mass (VGM)
    • Method that has been used for the weight (method 1 or 2)
    • Party that has verified the weight – the shipper or if shipper arranges a third party
    • Date/time of the weighing
    • Reference of the VGM declaration (especially in the case it’s a separate message) – shipper must communicate on their documents that the weight is the VGM.
    • Shipper’s authorized person – any document communicating the VGM must be accompanied by a shipper signature, or if typed, must be in all capital letters.

How is VGM communicated?

  • The regulation does not stipulate how the VGM is communicated; therefore, there are multiple ways of communicating based on the steamship line, the freight forwarder, etc.  At RIM, the ways to communicate are as follows:
    • Complete the RIM VGM Weight Verification form
    • Insert the above VGM data elements on the shipping documents clearly visible
    • Communicate via electronic format – work with your local RIM office
    • Email the verification with the required data elements to include the shipment number.

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. The default data flow will be shipper > RIM (or RIM partner)>SSL > terminal. Upon successfully receiving your declared VGM data, SSL will transmit it to terminal operator on your behalf.

What if my shipment is LCL? How do I get the VGM?

  • If the shipment is not a full container load, please supply the certified weight of the goods. Since the goods will be loaded in a container with other cargo, the loading party (such as RIM) will supply the VGM to the steamship line.

What if the VGM is not supplied? What happens?

  • If the VGM is not supplied, then the vessel may put a ‘no-load’ on the container and leave it behind. Please note that if this occurs, then additional charges could be incurred such as demurrage, reweigh fees, transport fees, etc.  These costs will not be absorbed by the steamship line, nor by RIM but will be passed on to the responsible party.  The regulation for VGM leaves the shipper responsible for the actual regulation; however, charges may be incurred upon the paying party.

How do I know if my supplier overseas can supply the VGM?

  • It is imperative that all importers communicate with their suppliers overseas and inquire if they have the capability to supply certified weights that abide by VGM requirements. If they are not, then make alternate plans to have the shipment VGM obtained by the freight forwarder.  There will be a cost to have these goods weighed.

Who is enforcing this regulation?

  • Each country must enforce their own VGM. In the U.S. the U.S. Coast Guard is the enforcement agency.

Is the VGM process the same worldwide since this is a global regulation?

  • No. While the regulation is global, each origin country can dictate their own processes.

Has RIM communicated with their overseas partners on the VGM regulation?

  • Yes, RIM has communicated the requirement and required that each partner acknowledge they are ready to manage the VGM requirement.

Mass information is provided already for bill of lading and customs declaration purposes; how does that information relate to what is now required under SOLAS?

  • The verified gross mass that is required under SOLAS relates to the packed container, including dunnage and securing, together with the tare mass of the container. VGM reflects the mass of the entirety of the consignment presented for loading on board a ship and is distinct from other trade mass values such as used for bills lading (relating to contractual liability) or customs declarations (for tariff filing and customs duties). SOLAS requires the verified gross mass to ensure that the correct value is used for ship stowage planning purposes; this safety requirement necessarily differs from other values used in trade.

Is it permissible for a shipper (particularly a cargo seller) to issue a blanket certification stating that all weights submitted are based on the use of certified scales using the methodology required by SOLAS?

  • The SOLAS VGM requirements are clear that the obligation of the shipper to obtain and communicate the verified gross mass applies to individual containerized shipments; no blanket certification is allowed under the SOLAS regulations.

Where a container or its contents become damaged during transit and, as a consequence, have to be repacked, what responsibility rests with the shipper under the maritime carrier’s bill of lading?

  • The maritime carrier concerned will need to have internal procedures in place to ensure that an accurate gross mass value is used for any further stow planning necessary for the repacked container to reach its destination.

What records are required and for how long should they be retained?

  • The commercial parties should retain VGM evidence (which may include underlying weight certificates and other documentation) at least until the conclusion of the carriage by sea. Retention for a longer period may also be advisable. There may be national regulations in place that should be taken into consideration.

Containers loaded as ro-ro are exempt; does this also apply where two containers are loaded on top of each other on a chassis?

  • For the purpose of the VGM regulations, there are exemptions for packed containers on chassis driven onto ships engaged in short ro-ro voyages of less than 600 nautical miles and no more than 200 miles from a port of refuge at any time. However, if such a container is on such a ro-ro ship for transshipment to a SOLAS containership (lift on-lift off), it will require a VGM in the transshipment port. In some situations, it may be that two containers are loaded vertically on to a chassis for carriage on a ro-ro ship. Where this occurs, it is strongly recommended that the VGM is obtained in advance, since one or both will be lifted at the transshipment port. However, for the short ro-ro voyage there is not strictly any requirement for VGM.

Whichever stakeholder faces a pecuniary penalty, can recovery actions be pursued against the cargo interests?

  • Breach of these regulations will be subject to national law. The SOLAS regulations do not address penalties or recovery of pecuniary penalties. It is likely that counterparties will establish contractual terms that seek to facilitate recovery or indemnity in certain circumstances, which will be subject to contractual rules in the particular jurisdiction concerned.

Do empty containers needs to be weighed?

  • Empty containers are not required to be weighed, although stakeholders are encouraged to have processes to ensure that containers declared as empty are indeed empty.

Who is responsible for tare mass of containers?

  • In relation to the Method 2 process, shippers are required to use the tare mass of the container as marked on the container door or provided by the container operator. However, the responsibility for the tare mass remains solely with the container owner/operator, in accordance with the International Convention for Safe Containers, 1972 (CSC) as amended.

More questions?  Contact your local RIM representative.