Before Submitting the VGM

1. As a company, can we use different weighing methods for the same shipment?

Yes, you can choose the appropriate weighing method for different containers in the same shipment. You are not limited to using just one weighing method.

2. Do I have to select my weighing method based on my specific type of cargo?

No, it is not necessary. You are free to decide the weighing method on your own. However, there is a guideline from SOLAS that types of cargo items that do not easily lend themselves to individual weighing of the items prior to packing in a container should be reported following Method 1. The key is to select a weighing method that can provide an accurate gross weight of the container.

3. How can I find out which countries require shippers to register for VGM verification?

You can find out whether VGM registration is required and the details in each specific country’s implementation guidelines. As soon as the country guidelines or updates to the guidelines are made available, the World Shipping Council posts them on its website: http://www.worldshipping.org/industry-issues/safety/global-container-weight-verification-rule-effective-july-1-2016.

You can also refer to CargoSmart’s compiled information shared through a series of webinars. Watch the archived webinars and download the presentation slides at http://form.cargosmart.com/en/solas-webinar-archive/.

4. In what way is Method 2 subject to certification? Who needs to register?

The method used for weighing the container’s contents under Method 2 is subject to certification and approval as determined by the competent authority of the State in which the packing and sealing of the container was completed. How the certification is to be done will be up to the State concerned.

This certification and approval actually refers to the registration procedures that some countries have already announced for Method 2. The shipper named on the ocean bill of lading is required to register if he is exporting cargo from those countries.

Some countries only require shippers using Method 2 for registration, while some may require all shippers to do the registration. Please refer to the country guidelines to make sure you are an eligible party for VGM registration.

Several European organizations representing shippers, freight forwarders, and terminal operators issued a press release in April to call on national authorities to avoid any disruption in the logistics chain and take action in coordination to preserve a level playing field. It mentions the cooperation in drafting guidelines on the shipper certification using Method 2 based upon common standards and programs (such as AEO, ISO 9001, ISO 28000). AEO is Authorized Economic Operator, a party involved in the international trade approved by a national Customs administration as complying with certain security standards. Therefore, for some European countries, such as Belgium and Italy, if you are a certified AEO, you do not need to do additional registration.

5. My country does not issue any guidelines on SOLAS VGM. Does it mean that I do not need to submit the VGM for my export containers?

SOLAS itself has international legal status so there need not be any further implementing legislation for the contracting countries. If your country is one of the SOLAS contracting countries, you still need to submit the VGM for your export containers.

Also, carriers may require you to submit the VGM no matter which port you are loading the containers since it is a safety issue. In addition, carriers may change the transshipment port later so you should submit your VGM no matter what the loading port is.

When to Submit the VGM

6. When should shippers start to submit the VGM?

Shippers that have containers that are expected to be loaded onto a vessel after midnight of July 1, 2016, should submit the VGM.

7. When is the cutoff time of the VGM?

The VGM cutoff varies by carrier and port and is not mandated by the SOLAS requirement. However, in practical terms, the shipper must submit it early enough for the carrier to use the VGM figure in its stowage plan, which is a requirement the SOLAS rule puts specifically on the terminal and carrier.

Carriers will advise the VGM cutoff time in online schedules or in the booking confirmation. The VGM cutoff will likely be before the CY cutoff.

8. For shipments that are via rail, is the VGM due prior to container in-gating at the rail depot or in-gating at the loading port?

In principle, the VGM should be due prior to container in-gating at the loading port since the VGM is used for stowage planning at the loading port. However, the VGM cutoff is set by the carrier. You may need to check with your local carrier contact to confirm the VGM submission deadline in this case.

9. Do containers being transshipped have to be weighed again at the transshipment port?

No. Further weighing at the transshipment port will not be necessary. VGM is required before loading the packed container on board a ship covered by the SOLAS requirement at its initial port of loading, unless driven onto a ro-ro ship on a chassis or trailer. Therefore, all packed containers discharged from a SOLAS vessel at the transshipment port should already have a VGM.

10. What about transshipment cargoes loading at the port of origin before July 1 but with transshipment movement after that date?

This is subject to the respective country’s implementation. So far, a few countries have specifically address this issue, including UK and Denmark. UK would seek to enforce the SOLAS regulations with a “light touch” for a 3-month period from July 1 in order to allow a smooth transition. Denmark’s guidelines note that packed containers which have started their transportation by sea before July 1 may be transported to their final destination without being furnished with a verified weight.

11. Will there be different VGM cutoff times for manual and electronic submissions?”

According to the best practices for VGM transmission published by the Ocean Carrier Equipment Management Association, shippers should submit the VGM via an electronic channel or EDI. It is likely that the VGM cutoff using alternative methods will have an earlier cutoff time.

12. The IMO recently stated that authorities should take a ‘practical and pragmatic approach’ when enforcing the new SOLAS rules for the first 3 months. Does this mean that we do not need to submit the VGM for the first 3 months?

Actually it does not mean to delay the implementation of the SOLAS requirements and no authorities or carriers have announced a grace period yet. Once again, since loading the container on board is subject to a carrier’s final decision, we recommend you to try your best to fulfill the SOLAS requirements in order to have your cargo delivered on time.

Who Should Submit the VGM

13. I’m a freight forwarder. Can I submit the VGM on behalf of the shipper?

The SOLAS VGM requirement defines “shipper” as the person named on the ocean bill of lading. If you are named as “shipper” on the ocean bill of lading, you are responsible for the VGM submission.

However, if you are only providing a service to the shipper to make bookings and submit shipping instructions, you will be considered a third party. The shipper will need to authorize you to do the VGM submission and will need to submit a Letter of Authorization (LOA) to their carriers if they are using an electronic portal for VGM submission such as CargoSmart. CargoSmart provides solutions for third parties to help shippers submit the VGM.

14. For LCL shipments, who will be responsible for VGM submission?

In principle, the “shipper”, who is named on the ocean bill of lading is responsible for VGM submission. For LCL shipments, the NVOCC, who consolidates all cargoes, issues house bills of lading to its co-loaders and has contractual agreement with the carriers should be responsible for the VGM submission after receiving the cargo weight information from the co-loaders.

15. We are noted as the shipper on the ocean bill of lading. However, the actual shipper will provide us with the cargo weight information for VGM submission. How can we rely on their submission?

As a shipper named on the ocean bill of lading, you are responsible for VGM submission. It is very important for you to establish your VGM process and best practices before July 1 with related parties, including the actual shipper.

CargoSmart provides customers with a collaborative platform to work with multiple parties to manage the VGM submission. For example, you can assign the task to third parties to submit the VGM. After they have entered the VGM, you can approve it before it is submitted to carriers. You can also authorize third parties to directly submit the VGM on your behalf. CargoSmart serves as a central hub to help you manage the VGM submission in line with your business processes.

16. We are a freight forwarder noted as the shipper on the ocean bill of lading. Does the actual shipper need to provide us with a certificate for the VGM? Or can they input the VGM information on the packing list?

If you are responsible for verifying the container weight while the shipper is just providing the weight information to you, it is not necessary to obtain a certificate for your VGM submission and they can provide the information in the packing list. Whether you need a certificate or a document which the shipper states the weight information is subject to the business practice between you and the shipper.

17. For triangle or foreign-to-foreign cargo, who has to verify the weight?

In principle, the shipper who is named on the ocean bill of lading will be responsible for verifying the weight. For triangle or foreign-to-foreign cargo, since the actual shipper at the origin may not appear on the ocean bill of lading, the shipper in another country may need to collect the weight information from the actual shipper for VGM submission. Alternatively, the shipper on the bill of lading can authorize the actual shipper to submit it on their behalf. However, the shipper named on the ocean bill of lading will have the ultimate responsibility and liability of the VGM.

18. My carrier asked me to submit the VGM to the booking agent rather than submitting it to the carrier. What should I do?

Some carriers may request shippers to submit the VGM to booking agents for specific regions, such as North China. The requirements are subject to carriers’ local guidelines. If you have any questions, you may check with your local carrier contact and booking agent for details.

How to Collect the VGM

19. How can I find out the tare weight of each container?

According to SOLAS guidelines published by the World Shipping Council and The Ocean Carrier Equipment Management Association (OCEMA), if using Method 2, shippers may use the container tare weight marked on the container.

Checking the tare weight printed on the container is just one of three ways to collect the container tare weight. Besides checking with your trucker or warehouse, you can also directly contact your carrier’s customer service department. Also, most carriers have published the container tare weight information on their website.

It can be very time-consuming to check with carriers or their websites one by one to get the container tare weight. A centralized platform or database for collecting this information can help make the process more efficient. CargoSmart’s platform provides a tare weight reference link from corresponding carriers’ websites. The centralized platform allows you to source the container tare weight more easily and efficiently.

20. Among the three ways to collect the container tare weight, which one do you think is the most reliable option?

Actually, we cannot determine which collection method is the most reliable option. The best case would be to get the tare weight from carriers directly, and then have your trucker or logistics service provider check it against the tare weight printed on the container.

CargoSmart has a centralized platform so that you can have access to the respective carriers’ databases easily. Its mobile platform provides a handy solution for you to collect the tare weight information from any third party.

21. Will the tare weight of each container be different? Or does the same size and type of container always have the same weight?

Most carriers have published the container tare weight information on their website based on the container size and type. However, please note that for the same size and type of container, the tare weight of different carriers’ containers may vary.

22. If there is discrepancy found between the tare weight provided by carrier and printed on the container, what can I do?

According to the SOLAS guidelines from the World Shipping Council, you should refer to the tare weight printed on the container. If there is a discrepancy between what has been provided by the carrier and what is printed on the container, you should contact your carrier’s local office for clarification.

23. Is it acceptable if the trucker weighs the empty container and the loaded container to get the cargo weight and then add the container tare weight to get the VGM?

As long as you add up the cargo weight and the container tare weight, it will be considered as Method 2 no matter how you get the cargo weight. However, using this method, you may need to pay attention to the VGM cutoff and check if the trucker can get the cargo weight to you before the VGM cutoff time.

During VGM Submission Process

24. Do I have to submit the shipping instructions and VGM through the same channel?

If you use CargoSmart, you can use different platforms to submit the shipping instructions and VERMAS. However, it will save you time for data entry and provide better visibility to your shipment status if you manage both shipping instructions and VGM through the same platform.

25. Do we need to submit any other information in addition to the VGM?

The required information for the VGM submission varies by carriers. Most carriers require a booking number, container number, unit of measurement, shipper’s name (listed on the bill of lading), authorized person, and the VGM. Please note that some carriers may require more information. If you use CargoSmart’s centralized platform, each carrier’s specific data requirements will be indicated on the screen and in the detailed integration guides.

26. Do I have to submit a hard copy of the VGM information with handwritten signature?

A hard copy VGM submission may be required. However, this is subject to each country’s implementation guidelines as well as individual carriers’ practices. Please check with your local carrier contacts.

27. What is the authorized person signature and is it compulsory?

The document declaring the verified gross mass of the packed container should be signed by a person duly authorized by the shipper. The information and signature may be transmitted electronically, and the signature may consist of the last name of the responsible person in capital letters.

28. We are submitting the VGM for the shipper. Can we use our name for the authorized person signature or does it need to be someone from the shipper company listed on the ocean bill of lading?

If the shipper has authorized you to submit the VGM, you can use your name for the authorized person signature.

29. Does the VGM provided by the shipper need to be verified by a third party?

According to the SOLAS requirements, the shipper should be the responsible party to verify the gross weight of the packed container. Therefore, once the shipper has submitted the VGM and declared it is verified, it is not necessary for a third party to verify again.

30. I’m currently submitting bookings and shipping instructions to carriers through email. What should I be aware of if I plan to submit the VGM through email?

For manual VGM submission, you need to check with your carriers about the VGM cutoff since the cutoff for manual submission will be earlier than electronic submission. You will need to plan to submit it earlier. Also, you may need to check with your carriers whether there is dedicated process to submit the VGM through email.

In order to submit timely VGMs, we highly recommend that you to submit it through an electronic channel. This will allow more time for you to prepare. Also, you can have visibility to the submission status through an electronic channel such as CargoSmart.

31. When a container is weighed at the terminal, how is the information flow? Will the terminal transmit the VGM to carriers directly? Who is the authorized party?

Normally, terminals are connected with carriers. If you assign a terminal as the weighing party, you can authorize them to be the submission party and they can transmit the VGM directly to the carriers.

In the US, some ports have announced that they will weigh containers and submit the VGM to carriers on behalf of shippers.

32. What is the difference between using a carrier’s web submission and using CargoSmart?

CargoSmart offers a consolidated platform for you to manage multiple carrier shipments. You can also leverage the platform to collaborate with other parties and gain visibility to VGM submission status.

After Submitting the VGM

33. What can I do if there is an amendment to the VGM submitted? Is there a deadline?

We recommend that you submit your updated VGM data to your carriers as soon as you receive it and before the VGM cut-off time. Whether amendments after the cutoff time will be accepted depends on the decision of the respective carrier’s local office.

34. Who will check the accuracy of the VGM?

According to the SOLAS guidelines from the World Shipping Council, there is no legal obligation for carriers and terminals to check the VGM. However, some countries’ enforcement agencies may perform the weight checking. For example, China’s marine management agencies will perform random checks on the VGM. You can find more details in the guidelines, which are translated by CargoSmart and posted on the World Shipping Council’s website.

Therefore, whether there is weight checking is subject to each country’s implementation guidelines and also the respective terminal’s and carrier’s operations.

35. What is the percentage of VGM tolerance error limit?

The tolerance level is subject to each individual country’s implementation guidelines. For example, Belgium and Singapore indicate a tolerance of plus or minus 5% of the container weight while Canada indicates a tolerance of plus or minus 5% but not more than 500 kilograms.

CargoSmart has shared a list of the tolerance levels by country in its webinar series. You can watch the archived May 31 webinar and download the presentation slides that include the tolerance levels as of May 31, 2016 at http://form.cargosmart.com/en/solas-webinar-archive/.

36. If there is a discrepancy found in the submitted VGM, what will happen?

According to the SOLAS guidelines from the World Shipping Council, the ship’s master should accept the cargo on board his ship only if he is satisfied that it can be safely transported. The ship master retains ultimate discretion in deciding whether to accept a packed container for loading onto his ship.

If your container is on hold due to a discrepancy, you should supplement an accurate VGM or contact your local carrier contact as soon as possible.

37. Beyond a “do not load” order, are there any other penalties if the VGM is not submitted?

Penalties are subject to each country’s specific guidelines. Several countries have indicated there will be a fine for incorrect reporting. Also, several terminals have indicated that there will be additional charges if the container has to be weighed again or unloaded from the vessel due to a weight discrepancy.

38. I am a freight forwarder. If the shipper provides me an incorrect cargo weight and I submit the wrong information to the carrier, will I receive penalties?

It depends on whether you are the named shipper on the ocean bill of lading or if you are helping the shipper to submit the VGM. If you are the shipper on the ocean bill, you will be responsible for verifying the container weight of the packed container according to the SOLAS requirements. Therefore, in case of any penalties due to mis-declaration, you will be liable for it.

39. If I use EDI to submit VGM to carriers, how do I know the carrier has received the data and are there any email notifications?

An acknowledgement message should be returned with each VGM submission through EDI. If you connect your carriers through CargoSmart, you can provide your email address to CargoSmart to receive an email notification when carriers receive your VGM submission.

In addition, if you are using EDI for VGM submission, we advise that you make sure you have established the VERMAS connection with your carriers or booking platforms, and completed the testing before the new SOLAS rule becomes effective on July 1. You should also confirm your contingency plans in the case of an EDI data transmission disruption. In this respect, CargoSmart has been working with its customers on VERMAS connectivity. We are offering a self-testing site for customers to trial run the submission process and test for data connectivity.

40. Does the weight declared in the VGM have to match the weight in the shipping instruction?

It is not necessary. Since the weight in the shipping instruction is not the VGM, variance between the two weights is expected.

41. Will the bill of lading show the VGM?

There is no requirement to show the VGM on the bill of lading. It is subject to individual carriers’ practices. You may check with your local carrier contacts.

42. Do I need to amend my invoice and packing list if a variance is found between the weight shown on the document and the weight measured at the port?

Since the weight shown on the invoice and packing list is not the VGM, normally it is not necessary to amend the invoice and packing list in this case. However, we recommend you to double check with your local carrier contacts.

43. How long should we keep VGM records?

The SOLAS guidelines from the World Shipping Council do not have any requirements for keeping VGM records. However, it may be subject to each specific country’s implementation. For example, Canada indicated that the shipper shall retain a copy of the shipping document providing the VGM of the packed container as well as any third-party documents related to the weighing of the container for a minimum period of three months, while Hong Kong requires record keeping for a period of not less than one year.

CargoSmart’s Solutions

44. If I submit the VGM via CargoSmart, how many carriers are on CargoSmart’s platform?

CargoSmart is working with over 30 ocean carriers to establish a seamless VGM integration. For other carriers that are not yet in CargoSmart’s carrier network, we will try to connect with them upon customers’ requests.

45. I understand that if I submit bookings or shipping instructions through CargoSmart, the VGM submission will be free of charge. What is the pricing if I submit only the VGM through CargoSmart?

CargoSmart offers solutions for submitting the VGM on its own, without the booking or shipping instructions, for a fee. For details, please contact solas@cargosmart.com.

46. Does CargoSmart’s system help users add the container tare weight and cargo weight or do users have to manually add and input the VGM on their own?

For Method 2, CargoSmart’s system will calculate the VGM value by adding the container tare weight and the cargo weight entered by users.

47. How can my truckers submit the VGM for me through CargoSmart’s platform?

CargoSmart provides customers with a collaborative platform to work with multiple parties to manage the VGM submission. For example, you can assign the task to your truckers or other parties to submit the VGM. After they have entered the VGM, you can approve it before it is submitted to carriers. You can also authorize third parties to directly submit the VGM on your behalf. CargoSmart serves as a central hub to help you manage the VGM submission in line with your business processes.

48. How do we access the dashboard to check the VGM status?

Dashboards with submission deadlines and status are available for CargoSmart’s VGM solutions. Customers can access the dashboards through CargoSmart’s online portal by signing into My CargoSmart Center on www.cargosmart.com.

49. How does CargoSmart know if a VGM is overdue?

After the user creates shipping instruction with container details, CargoSmart will know which containers do not have VGM submission. The user will have to input the submission deadline during the VGM submission and can track the VGM submission status based on the submission deadline and resolve the issues before the due date.

50. How frequently does CargoSmart transmit VGM data to carriers? How long will it take from submission to CargoSmart to the terminal receiving the VGM from the carrier?

CargoSmart transmits the VGM data to carriers through EDI in real-time. However, before transmitting the data to terminals, respective carriers may take some time to process the data. This varies with different carriers.

If you would like to use CargoSmart’s SOLAS VGM solutions, complete an online form at form.cargosmart.com/solas-get-started/ to get started today!