Container Weight FAQ
Q: What if a container is delivered to a port for shipment prior to 1 July, for which VGM is not required, but only loaded on board a ship after 1 July? Similarly, containers may be loaded at the initial export port prior to 1 July, but transhipped later.
A: Strictly, under the SOLAS VGM regulation, it is the date of the loading of the packed container aboard ship that determines whether a VGM is required. Equally, a packed container to be transhipped for loading aboard another ship on or after 1 July, where no VGM is communicated by the arriving ship to the transhipment terminal, a VGM must be obtained before the container may be loaded aboard the departing ship.
Recognizing these kinds of potential issues, IMO has issued MSC.1/Circ.1548 on 25 May 2016 urging governments to adopt a ‘pragmatic and practical’ approach to enforcement for the first three months, until 1 October 2016. The Circular specifically suggests that enforcement flexibility should apply to transhipped containers, which may begin movement (without a VGM) prior to 1 July 2016, but which are subsequently loaded onto a SOLAS ship after that date. Nevertheless, IMO stressed the safety importance of this and similar regulations, and the expectation should be that all stakeholders take all reasonable steps to be in compliance from 1 July 2016. The MSC Circular is not to be interpreted as a delay or postponement of the SOLAS VGM requirements.