Understanding container weight misdeclaration

Recently, ONE (Ocean Network Express), the 7th largest container shipping line in the world by capacity, implemented a penalty fee in the form of a Weight Discrepancy Charge (WDS) of USD 2,000/- per container from the 1st of July, 2022..

The penalty fee is applicable if there is a misdeclaration of cargo weight details at the time of submission of booking submission and if the weight deviates +/- 3 tons/TEU from the weight on the final Bill of Lading Instruction details and Verified Gross Mass (VGM) documentation..

In the supply chain disruption medley caused by COVID-19, many may have forgotten the issues faced by the industry (and the environment) due to overweight containers and various weight misdeclarations..

Let me refresh you on “When is a container considered as Overweight..??” and about container weight misdeclarations..

Overweight containers 

Every shipping container has and should have, a valid safety approval plate called CSC (Container Safety Convention) plate in order for it to be used in international trade in accordance with the provisions of the International Convention on Safe Containers of 1972..

As per BIC, In-service CSC safety examinations of containers must be done at intervals appropriate to operating conditions following one of two approved schemes – PES and ACEP..

The role of this CSC plate is to confirm that the container has been inspected and found to be in a condition suitable for transportation on board a ship.. This plate has several key details including allowed maximum gross weight as per below example..

Using the above plate as an example, a container that has been loaded more than the allowed weight – in this case, 32,500 kgs including the tare weight of the container, will be considered as OVERWEIGHT..

Cargo weight misdeclaration

Cargo weight misdeclaration is nothing new to shipping.. It has been continuing for years especially in containerised shipments either to escape additional charges, product price, hide the valuable or illegal nature of the cargo or just plain old laziness, buoyed by the fact that there was no mechanism to verify the cargo weight in an FCL container..

Misdeclaration in weight or misdeclaration of hazardous content has been the bane of the shipping industry and carriers and customers alike have suffered several consequences due to misdeclarations..

Few examples below..

June 2011: Container ship Deneb in Algeciras: The ship in this picture suffered a significant stability incident and an investigation found that out of the 168 containers on the load list had actual weights far in excess of the declared weights.. The total, actual weight of these 16 containers was more than 278 tons above their total, declared weight of about 93 tons, or 4 times higher than their declared weight..

January 2007: MSC Napoli: “About 660 containers stowed on deck, which had remained dry, were also weighed. The weights of 137 (20%) of these containers were more than 3 tonnes different from their declared weights. The largest difference was 20 tonnes, and the total weight of the 137 containers was 312 tonnes heavier than on the cargo manifest” (Source: “Report on the investigation of the structural failure of MSC Napoli”, U.K. Marine Accident Investigation Branch, Report 9/208, April 2008, p.28).

February 25, 2011: Longshore & Shipping News – ‘Near miss’ at Australia wharf as 28-ton container falls

“The container that fell 12 meters and narrowly missed two workers was severely overloaded and the third accident this month at Darwin Port. Two workers at the Darwin Port had to run to avoid a shipping container crashing onto East Arm Wharf at the weekend,” the Maritime Union of Australia says. The container was listed as 4 tonnes, but the Maritime Union says it weighed 28 tonnes and exceeded the crane’s load limit.

February 2007: Container ship MV Limari in Damietta: Container stack collapsed due to stack overweight.. The master’s incident report to the authorities notes that: “Excessively heavy units loaded in the upper tiers and that the maximum stack weight had been exceeded considerably in some rows. The effect of the overweight units was to impose excessive forces on the lashings. Further, exceeding permissible weight distribution and/or exceeding the maximum stack weight in any stack, results in overstressed stowage/securing elements and overstressed containers”..

The actual container weights were established by the devices on the gantry crane when lifting and shifting the collapsed containers., The actual container weights exceeded the declared weights by 362% (Row 08), 393% (Row 06), 407% (Row 04) and 209% (Row 02) in Bay 52 where the collapse occurred.,

March 2011: Excerpt from the publication “Container carriage. A selection of articles previously published by Gard AS”:

“Two recent cases which Gard Services has been involved with have certain similarities. Both cases involved heavy weather and the collapse of an on-deck container stack in way of the bottom container. In each case, the bottom container was of questionable fitness in terms of structural integrity. However, that was not the only factor. In each case the weight of certain containers within the stack was found to be in excess of the manifested weight. In one case, four containers in the collapsed stack were found to have 18 MT or more undeclared cargo, which even resulted in the maximum operating gross weight for each container being exceeded”..

January 2006: P & O Nedlloyd Genoa: Overweight containers contributed to this incident.

“The declared weight of a container provided by the shipper and used for all stow planning and onboard stability purposes can, if inaccurate, cause major discrepancies between actual and declared weights. Furthermore, incorrect weight can result in stack overload and the application of excessive compression and racking forces on containers and their lashings. Although there are no financial gains to be made by the shipper who declares less than the actual weight, the industry acknowledges that over-weight containers are a problem. However, as yet this has not justified a requirement for compulsory weighing of containers prior to loading” (Source: “Report on the investigation of the loss of containers overboard from P&O Nedlloyd Genoa”, U.K. Marine Accident Investigation Branch, Report 20/2006, August 2006, pages 19, 30 and 31)

2011: Mariners’ Alerting and Reporting Scheme (MARS): Hazards of underdeclared cargo weights: “A large container vessel was loading at the final load port before commencing a trans-ocean voyage. The exit channel from the terminal had a draught restriction and sailing was subject to a narrow tidal window.

Pre-arrival loading information listed some 350 containers, most of them going on the deck stacks. Being a regular vessel at the port, the terminal’s computer system provided a departure stability condition with the sailing draughts allowing for adequate under keel clearance (UKC) as per the company’s SMS.

However, during the latter half of the 12-hour loading period, the chief officer realised that there was substantial under-declaration in the manifested container weights (later estimated to be an average of 12 percent).

This meant that after loading the manifested boxes, the ship was in serious danger of grounding in the channel. Thanks to quick thinking by the master, a total of about 850 tonnes of ballast was discharged before sailing from the twin auto heeling tanks, which due to their high location and narrow width resulted in a safe even-keel trim and an acceptable stability condition. The ballast was restored in the heeling tanks after reaching deep waters but unfortunately, it was realised after sailing that stack-weight limits had been exceeded in many deck stacks.”

If you have been following the misdeclaration chronicles on this site, you will see that there have been many cases where container weights declared vs actual has been quite different..

How does weight misdeclaration affect operations

The weight of the container affects many areas.. Primary among these are the lives of innocent seafarers and/or dock workers..

Onboard the ship, the containers are generally stowed with the heavy containers at the bottom either on deck or underdeck of the ship, and the lighter containers on top of these containers..

This is done in order to maintain the stability of the ship and achieve an even spread on board.. The stability of the ship is a VERY vital factor that is taken into consideration while planning the loading of the ship..

For example, a client has some containers that weigh 27.5 tons each but in order to save costs on overweight surcharges or weight additionals, he declares the weights as 17.5 tons..

Or there is a typo error and the weight is captured as 17.5 instead of 27.5 tons..

Based on the declarations, the shipping line will plan these containers as 17.5 tons each..

When the ship’s planner does the planning, following the weight categories, he is going to place the 17.5 ton containers on top of 20 ton containers..

Now if these 20 ton contrs are actually the right weight, we now have the 27.5 ton containers (misdeclared as 17.5 tons) sitting on top of a 20 ton container..

Imagine MANY containers with misdeclarations such as this on the ULCVs capable of carrying thousands of containers..

The chief officer of the ship will have a problem to try and adjust the stability because according to his/her calculations the ship should be stable when the cargo is planned and loaded a certain way based on the weight declarations, but in reality, because of the misdeclared weights, he/she is not able to get the stability right..

If the weight distribution in the stack is not adhered to as prescribed in the Cargo Securing Manual due to this misdeclaration, it may result in:

– failure in container stowage and securing devices due to overstress
– damage to containers or loss of containers overboard

Movement by Road

If you consider the movement of cargo by road, there are several forces acting on the cargo during transport caused by the movement of the truck, the gradient of the road, the camber of the vehicle, the speed of movement, unexpected stops etc..

Your cargo can experience

• Gravitational force
• Frictional force
• Random Deceleration
• Random Acceleration
• Centrifugal force
• Vibratory force

These forces may cause the sliding, tipping, and wandering of cargo which could seriously damage the cargo and/or other assets or human beings especially if it is heavy but misdeclared cargo weights..

Movement by Rail

If you consider the movement of cargo by rail, there are several forces acting on the cargo during transport caused by the movement of the rail wagon, vibration of the rails, the speed of movement, unexpected stops etc..

Your cargo can experience

• Longitudinal and horizontal forces
  • During braking
  • Acceleration
• Transverse horizontal forces
  • Wagon oscillation (yaw) during transport
• Gravitational force
• Frictional force
• Random Deceleration
• Random Acceleration
• Centrifugal force
• Vibratory force

These forces may cause the sliding, tipping, and wandering of cargo which could seriously damage the cargo and/or other assets or human beings especially if it is heavy but misdeclared cargo weights..

Enter SOLAS VGM

In November 2014 the International Maritime Organisation (IMO) amended SOLAS (Safety of Life At Sea convention) Chapter VI Regulation 2 to tighten up the process of weighing containerised cargoes and declaring the correct weights after verification..

The new container weight verification regulation came into effect from July 2016.. Below infographic explains

• What is SOLAS VGM (Verified Gross Mass) / Container Weight Verification..??
• How this verification process is expected to work..??
• Why is this so IMPORTANT..??
• How SOLAS VGM affects day-to-day shipping but at the same time make shipping safer for everyone..

I thought it would be worth reiterating the importance of being accurate in the declaration of the weights.. Although SOLAS VGM is in place and life after SOLAS VGM seems to have helped, many people may still be using some loopholes to circumvent these protocols..

C.S. Lewis said “Integrity is doing the right thing even when no one is watching“.. Declaring the correct weights is something like that..

It boils down to people taking “personal” responsibility to be honest and correct in the declaration of weights whether it is verified by someone else or not..