Container weight requirements - FAQs
The VGM requirement comes from the International Convention for the Safety of Life at Sea (SOLAS) and is given effect in New Zealand in Maritime Rules Part 24B – Carriage of cargoes, stowage and securing.
Who is this information for?
Everyone in the transport chain needs to understand VGM requirements and their individual responsibilities. These parties include:
- shippers: people or organisations that offer goods for carriage by sea, including those who arrange carriage on behalf of another person
- packers and consolidators: organisations that pack shipping containers and consolidate consignments from individual shippers into containers
- carriers and carters: organisations that transport containers from the shipper or packer/consolidator to container terminals (ports and inland terminals)
- freight forwarders or forwarding agents: organisations that arrange transport from the shipper to the final destination, sometimes called non‑vessel‑operating common carriers (NVOCCs)
- container terminal and port operators
- shipping lines.
Responsibilities depend on the commercial arrangements the shipper has with each party. In the questions below, “freight company” is used as a general term for packers, carriers, freight forwarders, and other parties that help deliver the shipper’s goods to the port or container terminal for export.
This is about the safety of ships and seafarers. Mis declared weights make it difficult to plan safe stowage of cargo on a ship. This can lead to:
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collapse of container stacks
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overstressing of the ship’s structure
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instability of the ship itself.
Under SOLAS, shippers are already required to declare the gross mass of cargo to be shipped.
From 1 July 2016, the shipper must confirm that the declared gross mass for all containers shipped internationally is accurate and sign it off. The master must not load any container that does not have a VGM.
Signed declarations are already required for consignments of dangerous goods so they can be correctly and safely stowed. VGM uses a similar system to ensure containers have a known and reliable weight for safe stowage.
The shipper is any person who offers goods for carriage by sea, including any person who arranges carriage on behalf of another person.
Whether you are the shipper depends on the commercial contract you enter into with your freight company or other parties carrying your goods. Your freight company should tell you whether you need to provide a VGM for your consignment.
The VGM is the combined weight of the container and its contents.
You can determine VGM in two ways:
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method one – weigh the packed container using calibrated and certified weighing equipment
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method two – weigh the contents of the container (including packing material and dunnage) and add this to the tare weight (empty weight) of the container, using a method that meets Maritime NZ guidance.
No. The rule only applies to containers on an international voyage. It does not apply to containers carried on rail wagons or road vehicles aboard a roll‑on roll‑off (ro‑ro) ship to another New Zealand destination.
However, if the container is being transhipped to another New Zealand port for export, it will need a VGM before it can be loaded for export at that port. The freight company cannot present your container at a port for export without a VGM, so they may require you to provide one before they accept the container for domestic shipment. Confirm this with your freight company.
The maritime rule only applies to containers carried on an international voyage. Domestic shipping lines may choose to require a VGM, but that is their decision.
New Zealand port companies require a VGM for any container shipped through their terminals, whether for domestic or international voyages. Check with your shipping line or freight company to confirm their requirements.
Your freight company can tell you which ship and voyage your container is booked on so you can provide the VGM if needed or ensure they provide it on your behalf.
If it does not have a VGM, it may not be accepted for loading in Nelson. Check with the domestic shipping operator or your freight company to confirm their requirements.
The organisation responsible for final packing of the container – the last person to close the doors – is generally responsible for determining the VGM. They may:
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weigh the container once it is packed, or
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use method two and ask you to provide weight information for your consignment so they can calculate the final VGM.
They should tell you how and in what form to provide this information. Contact the packer or consolidator.
The International Maritime Organisation (IMO) agreed that maritime administrations should take a practical approach in the first 3 months after 1 July 2016, to allow containers loaded before that date to be transhipped without a VGM. Refer to the IMO guidance below.
No. New Zealand rules apply to containers exported from New Zealand.
Because VGM is an international requirement, each SOLAS State has its own legislation. If a problem with declared VGM is found in a container landed in New Zealand, Maritime NZ can raise this with both the ship’s flag State and the State where the container was loaded.
No. The rules apply only where cargo is carried in a container. An empty export container does not need a VGM. However, check with your freight company or shipping line to confirm their requirements.
Calibrated and certified equipment is trade‑approved weighing equipment. This means the weighing instrument is approved under the Weights and Measures Act 1987 and Weights and Measures Regulations 1999.
Trade‑approved equipment used to determine VGM must:
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comply with legal tolerances
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have a current certificate of accuracy.
Weighing instruments approved as Class III or IIII must have a scale interval of no more than 50kg. Instruments approved as Class Y(b) must have a scale interval of no more than 100kg. Scale intervals for other classes will be considered on a case‑by‑case basis.
Accredited persons, authorised under the Weights and Measures Act to examine and test trade‑approved equipment, can issue a certificate of accuracy. A list of accredited persons is available on the Trading Standards website.
Ports have generally indicated they will not provide container‑weighing services, but some have information on weighing services elsewhere. Your container must have a VGM before it arrives at the port or the port may not accept it into the terminal. Your freight company or packer should tell you what is required.
The container’s tare weight is marked on the container. The container owner is responsible for ensuring that:
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the tare weight is marked, and
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the marked tare weight is accurate.
The maximum operating gross mass is stamped on the container’s Convention for Safe Containers (CSC) approval plate. The VGM must not exceed the maximum operating gross mass.
Method two allows alternative procedures for calculating VGM that meet Maritime NZ guidance. This provides flexibility for cargoes that are sold by volume rather than mass, such as pulp, lumber, and produce.
These procedures must provide an accurate and reliable VGM, comparable to method one. They should be based on methods of known accuracy and supported by a quality‑control system to ensure:
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a consistent process
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verifiable weights.
For example, volume‑to‑mass conversion factors may be acceptable if:
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the process for establishing and verifying factors is robust
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factors are reviewed through sampling and weighing using calibrated and certified equipment.
The shipper must be able to demonstrate that their process produces a reliable and accurate VGM
No. We are not planning to run a formal approval system for shippers using Method Two.
Guidance will be provided on what are considered to be acceptable methods for determining the VGM using Method Two.
There is no tolerance specified in the rule. The requirement to use trade approved equipment means that the VGM should have an accuracy as specified in the Weights and Measures Act 1987 and supporting Regulations.
Shippers must state the VGM in the shipping documents. These may be transmitted electronically.
The rule does not specify:
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a particular form of shipping document
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where VGM must appear on the document.
However, the shipping documents must:
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clearly state the VGM, and
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be signed by a person authorised by the shipper to make the declaration.
No. There are many forms of shipping documentation and no international standard format. Maritime NZ does not specify a format for documenting VGM.
A person authorised by the shipper must sign the VGM declaration.
Because shippers vary in size and structure, Maritime NZ does not specify who within an organisation must sign. Each shipper must decide who is authorised and ensure those people have appropriate authority.
No. The rule requires that VGM be provided to the port in time to allow safe planning of cargo loading and stowage. Ports and shipping lines:
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set their own cut‑off times for receiving VGM documentation
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advise customers of their requirements.
If:
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the shipping documents do not include a VGM, or
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the master or terminal representative does not have VGM information,
the container must not be loaded on the ship.
The master must not accept cargo on board if they are not satisfied it can be transported safely. In practice, a container without a VGM will not be loaded.
Port companies have set their own requirements for receiving VGM information and procedures if a container is presented without VGM. Any economic impact from failure to provide a VGM is a commercial matter between the parties involved.
There is an element of self‑enforcement because ports and shipping lines will not accept export containers for loading that do not have a VGM.
Maritime NZ does not currently plan to carry out on‑the‑spot checks or random weighing of containers, and most other maritime administrations do not plan to either. However, enforcement will still occur.
Maritime NZ will monitor implementation of the rules, which may include audits of shippers’ systems for determining VGM.
Where concerns arise about grossly inaccurate weights, consistent misdeclaration, or no VGM, Maritime NZ will follow up with the shipper.
If a lack of verified weight, or obviously incorrect weight, creates a safety issue or there are serious breaches of VGM obligations, Maritime NZ may be notified. Actions taken will depend on the nature of the breach.
Maritime NZ took a practical and pragmatic approach to enforcement in the first 3 months from 1 July 2016 to help parties refine processes for documenting, communicating, and sharing VGM information. This reflected IMO guidance and Maritime NZ’s compliance model, which supports parties making genuine efforts to comply.
This did not remove the requirement to determine VGM for all exported containers or to provide VGM and an authorised signature to terminal representatives and masters.
The Maritime Transport Act 1994 provides penalties for actions involving a ship that cause unnecessary danger or risk to people or property.
There are also penalties for providing safety‑related information about a ship that is known to be false, or provided recklessly as to whether it is false.
Trading Standards regulates trade‑approved equipment and is responsible for enforcing requirements for weighing instruments. See the Trading Standards website for more information.
Land‑transport rules focus on axle loads and ensuring a vehicle does not exceed safe highway loads. This is what Police check, along with other vehicle safety matters.
The actual container weight is not of direct interest on the road, provided land‑transport maximum limits are not exceeded. VGM may help demonstrate compliance with land‑transport rules, but compliance with road‑weight limits does not guarantee compliance with VGM requirements for carriage by sea.