Containers

Verification of the weight of packed containers (VGM)
– What do the regulations say?

From 1 July 2016, all export containers to be loaded on board a ship must be fitted with a so-called "verified weight" – VGM (Verified Gross Mass). The requirement is global and has been introduced out of consideration for maritime safety. The regulations are stipulated in the so-called SOLAS Convention and have been adopted by United Nations' International Maritime Organization (IMO).

The Danish Maritime Authority is the authority responsible for the implementation of the regulations in Denmark. In early May 2016, a separate Danish order hereon was issued.

The Danish regulations apply to all Danish ships and all containers intended, in a Danish port, to be loaded onto a ship (irrespective of flag) engaged in international trade. However, containers on chassis frames, trailers, mafi trailers and the like on ro-ro voyages of less than 600 nautical miles are exempted.

The Danish regulations also apply to all containers for which the packing is finalised in Denmark (and Greenland). The regulations on the VGM of a container always follow the country in which the packing of the container is finalised.

The VGM is to be established by the shipper or its shipping agent. The VGM differs from the current indication of the container weight in the transport documents since the VGM can be established only in two ways.

1. Weighing by means of a suitable weight. The shipper/shipping agent can have the container weighed by means of a suitable weight, which means an approved weight of at least class IV for nonautomatic weights or at least class Y(b) for automatic weights. See a separate fact sheet on method 1.
2. Calculation according to a certified method. The shipper/shipping agent can weigh all packages and cargo elements, including pallets, etc. to be packed in the container and add the container tare mass to the sum. The method requires that the shipper/shipping agent has a quality management system, for example of ISO standard. See a separate fact sheet on method 2.

According to the regulations, the shipper/shipping agent must inform the master/its representative and the port terminal operator about the VGM. The container must not be loaded onto the ship until the master and terminal operator has a VGM. Please observe that the container must not be loaded onto the ship if no VGM is available.

It is, as a general rule, the shipper's responsibility to establish the VGM, but the terminal operator can offer to do this according to method 1. See a separate fact sheet on this.

It is not the responsibility of the terminal operator or the master to verify a VGM. When a VGM is given in a transport document, the actors in the transport chain must assume that it is correct.

The individual shipowners and terminal operators can set a deadline for receiving a VGM. In practice, it will therefore depend on local conditions when and how the shipper/shipping agent is to inform about the VGM prior to the arrival in port and/or loading of the ship

Verification of the weight of packed containers
– Method 1, weighing of the packed container by means of a suitable weight

From 1 July 2016, all export containers to be loaded on board a ship must be fitted with a so-called "verified weight" – VGM (Verified Gross Mass).

It is possible to establish the VGM by means of two methods: 1) Weighing by means of "a suitable weight" or 2) calculation according to a "certified method".

This fact sheet describes method 1 – "a suitable weight". See a separate fact sheet for method 2.

What: Method 1. The shipper can use a "suitable weight" to weigh the entire container. This can be either a weighbridge or handling equipment with a built-in weighing function. The weighing equipment must be approved in at least class IV for non-automatic weights or at least class Y(b) for automatic weights.

Please observe that, unless the shipper owns a suitable weight, weighing in accordance with method 1 will typically be a commercial service to be offered by a third party. If this is the case, communication of the VGM and any fee for the weighing will be agreed by the parties.

How: The method depends on the specific equipment. In the following, two alternatives are described: A) Weighing by means of a weighbridge and B) weighing by means of handling equipment at the arrival at the port terminal. These two alternatives are, however, hardly the only ones available.

1. Weighing by means of a weighbridge:
   A container on a chassis frame or a trailer can be weighed together with the vehicle. Subsequently, a calculation will be made whereby the vehicle's registered weight as well as its fuel tank contents, etc. will be deducted. When two twenty-feet containers are being transported by the same tractor, this method can be carried out only if two weighings take place, at least one of which is (only) with one container.
2. Weighing by means of handling equipment upon arrival in the port terminal:
   A container can be weighed at the arrival in the terminal by means of the relevant handling equipment (for example a reach stacker or straddle carrier with approved weighing equipment), which is to lift the container of the means of transport in all circumstances.

A loading crane in the port cannot be used as a suitable weight in connection with the loading of the ship since the terminal operator must not initiate the loading until a VGM is available.

The regulations contain an interim arrangement. From 1 July 2016 and one year onwards, it is possible to use weighing equipment that is not certified or which is less accurate. It must, however, be ensured that it is possible to establish the VGM at +/- one tonne from the actual weight. This can provide some flexibility. 2

Of what must you be especially aware?

If the weighing is not carried out by the shipper/shipping agent, the possibility is of course first and foremost dependent on whether the service can be offered. All communication must be agreed by the parties. In practice, it will therefore depend on the local conditions when and how the shipper/shipping agent is to report the VGM prior to the arrival in the port and/or the loading of the ship.

For additional information, please contact the Danish Maritime Authority by telephone +45 72 19 60 00, or by e-mail: sfs@dma.dk, or visit our webpage: www.dma.dk.

Verification of the weight of packed containers (VGM)
– Method 2, calculation of the weight according to a certified method

From 1 July 2016, all export containers to be loaded on board a ship must be fitted with a so-called "verified weight" – VGM (Verified Gross Mass).

It is possible to establish the VGM by means of two methods: 1) Weighing by means of "a suitable weight" or 2) calculation according to a "certified method".

This fact sheet describes method 2, which is a calculated weight according to "a certified method".

See a separate fact sheet for method 1.

What: Method 2. The shipper/shipping agent can calculate the total VGM on the basis of the contents of the packed container. Below, you can see how.

In spite of the name, the method does not require any separate certification or approval in Denmark. However, it is a precondition that the shipper/shipping agent has a quality management system, for example of ISO standard, in which the method can be incorporated.

A quality management system is a documented system according to a fixed framework which is audited as regards the system's implementation and efficiency. The framework can, for example, be DS/EN ISO 9001:2015: Quality management systems – Requirements, as well as DS/EN ISO 19011:2012: Guidelines for auditing management systems.

How: The VGM is found by carrying out a five-step calculation:

Step 1: The weight of the individual cargo items is added together. This is to be done on the basis of own or reliable information from the suppliers. As regards bulk products, the weight can be established via measurements by means of suitable filling equipment.

Step 2: The weight of the packaging is added together. This is to be done on the basis of the shipper's own or the manufacturer's information.

Step 3: The weight of pallets and securing devices (dunnage) is added together. This is to be done on the basis of own or the manufacturer's information.

Step 4: The tare weight of the empty container.

Step 5: Adding together the values obtained from steps 1-4

Of what must you be particularly attentive

Weight deviations can occur on, for example, the humidity of pallets and dunnage, the actual tare weight of containers, etc. Such deviations must be considered in the shipper's quality management system. It is possible to use qualified average figures.

The calculated VGM must be as accurate as possible. If the calculated VGM deviates from the actual weight of the container, the container can be rejected in the transport chain. In case of considerable deviations, it may involve persecution. In practice, "considerable" will be interpreted as a deviation of approximately 5 per cent.

For additional information, please contact the Danish Maritime Authority by telephone +45 72 19 60 00, or by e-mail: sfs@dma.dk, or visit our webpage: www.dma.dk.

Depending on whether the weight concerned is manual or automatic, it must meet the requirements for accuracy that have been stipulated in the executive orders hereon issued by the Danish Safety Technology Authority. The weight is not required to be certified, but the manufacturer of the weight must guarantee that it meets the preconditions determined. Similarly, the manufacturer of the weight must ensure on an ongoing basis that its accuracy is maintained (calibration of the weight).

The condition for using method 2 (the calculation method) is that the shipper is operating in accordance with an ISO 9001 or similar quality management system, including that the procedures described in order no. 397 from 2016 have been incorporated and verified by the accredited body. Companies that have been AEO certified within safety and security (AEOS or AEOF certification) are also presumed to be able to determine and maintain the procedures needed.

In case it is not an ISO 9001 quality management system, the shipper must ensure that the quality management system used is equal to an ISO 9001 system, including that it is a managed, documented, verifiable quality management system that has been approved by and is being controlled by an audit body accredited in the EU on an ongoing basis. The shipper can ensure this by contacting the associated accredited body, respectively by contacting an accredited body that has been recognised for performing audits of management systems in accordance with ISO 19011:2012. An overview of Danish ISO 9001 accredited companies is available from the webpage of DANAK.

No, the accredited body approves the quality management system, including the procedures that are used to establish the verified weight in accordance with method 2. It must be possible to present the approval to the Danish Maritime Authority, if and when needed.

As soon as the accredited body has vouched for the company's quality management system and the procedures incorporated in connection with the establishment of the verified weight, the company can use method 2. If the quality management system enables the company to determine, incorporate and verify the new procedures on the establishment of the VGM on its own, the company can start using method 2 when the procedures have been incorporated.

No, the shipper is required to inform only the master or his representative as well as the terminal operator about the verified weight. However, the shipper must be able to document to the Danish Maritime Authority which method has been used in connection with the indication of the VGM (Verified Gross Mass) for each individual container.

According to Danish regulations, an electronic signature is sufficient. However, the shipper must be able to document who – in the company – has stated the verified weight. A logon from the shipper's computer can, for example, be sufficient to identify the person concerned.

All containers covered by the International Convention for Safe Containers (CSC) from 1972, as amended, which are to be transported on international voyages are covered by the new regulations. However, containers carried by ro-ro ships on short international voyages are not covered.

In principle, the shipper can freely choose which method to use when forwarding the VGM of the packed container. Thus, the shipper can choose a separate document/declaration or he/she can choose to use existing transport documents. However, it must - as stipulated in the executive order - be evident who has declared the VGM and who is, in this context, the shipper of the container concerned. The intention is not that the VGM declaration is to have any (other) consequences for the transport documents used by the industry.

The shipper is to establish the verified weight in accordance with one of the two methods. It does not seem obvious for the shipper to use method 2 in this situation as he does not have the management over the weight data in the individual consignments of goods.

The shipper must establish the verified weight based on method 1 or method 2, and this company will also be sanctioned, in case of need, if the information stated is incorrect. Thus, the shipper cannot provide the VGM (Verified Gross Mass) solely based on information from another company.

A shipping agent can pass on the VGM established by the shipper to the master or his or her representative as well as the terminal operator. However, the transport document used for this purpose must state that this is the case.

In principle, there is no margin of tolerance in connection with the establishment of a VGM since it must be established as accurately as possible. However, in connection with the (suitable) weighing equipment to be used in accordance with method 1, a minor inaccuracy is acceptable within the established weighing intervals. Similarly, there may be minor variations in the pallets, securing devices, dunnage, etc. that are used to secure the goods in a container in accordance with method 2. In order to take account of these operative frames, it will be considered to sanction shippers when the VGM provided deviates from the actual VGM by more than 5 per cent. However, until 30 July 2017, suitable weighing equipment (method 1) that may have deviations of up to 1,000 kg will be accepted.

No, the Danish Maritime Authority has the definite impression that the necessary weighing equipment is available on the market, just as major shippers and container terminals have started to implement it in their operation. Consequently, there is no need to prolong this "interim period".