SOLAS verified gross mass effective this July

On 1 July 2016, the SOLAS verified gross mass amendments  will enter into force across 171 International Maritime Organisation (IMO) members.

This regulatory amendment requires all packed containers to have verified gross mass (VGM) submitted prior to loading or it will not be loaded for shipment. It applies to all containers moved via ocean freight. However, intermodal shipment may also need to have their containers verified, especially if it will eventually require sea freight.

With more than a month before its implementation, it is best to address some of the most questions now facing importers, exporters and freight forwarders.

• Who is responsible for the verification of packed containers?
• How is verified gross mass calculated or weighed?
• What are its implications to importers, exporters and freight forwarders of VGM?

Defining who the “shipper” is?

Under the newly amended SOLAS, the task of verifying the packed container’s weight is the responsibility of the “shipper.” But who is exactly the shipper referred to by SOLAS?

The shipper is defined as:

“… a legal entity or person named on the bill of lading or sea waybill or equivalent multimodal transport document (e.g. “through” bill of lading) as shipper and/or who (or in whose name or on whose behalf) a contract of carriage has been concluded with a shipping company (see paragraph 2.1.12 of the Guidelines regarding the verified gross mass of a container carrying cargo (MSC.1/Circ.1475)).”

This could be the importer, exporter or logistics provider/freight forwarder appearing on the bill of lading.

How is verified gross mass weighed?

Now that we have a clear definition of the shipper, we are now ready to explore how the verified gross mass is to be calculated. Here are two methods you can choose from:

Method 1 – Weigh the packed container as a whole for verified gross mass

This is the easiest way to get a container’s verified gross mass. However, it requires weighing the container and its contents on a calibrated and certified instrument such as a weighbridge or other piece of suitable equipment.

Method 2 – Weigh the packed container in parts for verified gross mass

Method 2 requires weighing all packages and cargo items including the mass of pallets, dunnage and other securing material to be packed in the container. The sum of both will then be added to the tare mass of the container (this is the weight posted at the back of the door of your container) to get the verified gross mass of the container.

Verified gross mass calculation methods

What are the implications of verified gross mass to importers, exporters and freight forwarders?

Reading through the above amendment, VGM compliance may look simple. But take a closer look at how it can impact your operation. Read the statement published at The Journal of Commerce (JOC) last December.

“Approximately 300,000 container weights will need to be certified each day globally, and roughly half of all booking requests and shipping instruction submissions each day are non-digital, in other words, in paper form, according to Inttra.

“Marine terminals may in some cases offer weighing services if it can be done without disrupting regular terminal operations, but this will not be in all cases, as some terminals, such as Maher Terminals at New York-New Jersey, in December said it does not have the capacity to offer weighing services for non-compliant containers and will not  in-gate any container without the VGM already received via EDI.

“Overall, as the first quarter of 2016 came to a close, shippers worldwide were very busy determining how they will be in compliance, but many questions remain particularly around government’s’ plans for penalties for non-compliance, or allowable tolerances from stated VGMs.”

Months have passed, yet some of these concerns remain critical to most shippers around the globe. Here are some these:

Lead Time

One thing to consider in adhering to the SOLAS VGM requirement is the lead time. You need to decide when you will have your VGM calculated. Is it after consolidation or before consolidation?

This illustration will help us better understand it:

What is the impact of the two methods of verified gross mass calculation to importers and exporters?

Method 1: Perform VGM Calculation at the terminal

Method 1 would seem simple, but this requires coordination with the terminal if they have the equipment to weigh containers and provide verified weight. But with the above statement from JOC, not all port terminals have the ability to perform VGM calculation at the terminal.

Additional questions to ask are:

• How long will it stay at the yard?
• What is the cut-off time?
• What are the incremental costs that goes with this?

Method 2 – Perform VGM Calculation during consolidation

It is ideal for a shipper to have VGM calculated during consolidation rather than at the terminal. Why? For one, you can readily know if you have exceeded the amount of cargo to load into a single container.

However, it entails carefully knowing the weight of each parcel going into the container, which means  additional manpower, time and labour cost.

Communication and documentation

The IMO has made it clear – NO CONTAINER shall be loaded on a vessel unless there has been a VGM provided. However, how will this be provided?

Port terminals around the globe may have different processes posted, but it is important for VGM information to be properly communicated to them.

Electronic Data Interchange (EDI) vs non-digital documentation

Electronic data interchange (EDI) would be very handy. Unfortunately Inttra has mentioned that roughly half of all booking requests and shipping instruction submissions each day are non-digital, in other words, in paper form.

How will you proceed?

LCL documentation for individual cargo

With an option to have the contents of the cargo weighed at their own premises prior to loading, this could potentially mean “no documents, no loading.”  This means implementing a similar procedure done via the Automated Manifest System (AMS).

This would pose no problem for full container loads (FCL) where the shipper could easily be the importer or exporter. But for LCL shipment where the shipper becomes the freight forwarder, how will documentation be implemented?

Each individual could provide their gross weight but wouldn’t that require a second check by the freight forwarder to ensure the stated weight is indeed correct? Will that mean additional cost charged to the exporters or importer?

Given this alternative, LCL cut-off time may be advanced at origin to allow time for weight certificate to be received prior for the consolidator to stuff the container and ultimately provide the required VGM to the carrier.

Answers to these questions are best discussed with your freight forwarder. Talk to us to know how we have made it simple and easy for you.

Cost of compliance

It is obvious from this point, that additional labour, time and manpower is needed to comply with this SOLAS requirement. This would generally impact the cost of both imported and exported items. Thus it is best to sit with your freight forwarder to know the additional costs needed to ensure your cargo will arrive to its destination accordingly.

What to do prior to the implementation of SOLAS VGM on 1 July 2016

The community understands that SOLAS verified gross mass amendment will:

• Minimise loss of containers from vessel
• Provide assurance to parties in the supply chain
• Improve the safety of the workforce, vessel and equipment

However importers, exporters and freight forwarders would need to adjust to these changes.

We strongly advise importers and exporters to talk to us prior to 1 July 2016, especially if their shipment will be loaded after this period. We are happy to discuss how we will ensure your goods remain in compliance with IMO regulations whilst keeping your costs at minimum.

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