October 5, 2022

Volume XII, Number 278


October 04, 2022

Subscribe to Latest Legal News and Analysis

October 03, 2022

Subscribe to Latest Legal News and Analysis

SOLAS Convention Container Weight Verification Requirements Arrive Sooner Than You Think

Beginning July 1, 2016, the SOLAS Convention will require the shipper of a packed export container to verify the container’s weight before it is loaded aboard a ship.

In November 2014, the International Maritime Organization (IMO) adopted amendments to the Safety of Life at Sea (SOLAS) Convention. The amendments, which enter into force on July 1, 2016, will require a shipper of a packed container to verify the container’s gross weight and provide the verified weight to the ocean carrier and port terminal representative before it is loaded onto a ship. Parties in the container supply chain should implement the necessary process and documentation changes now to ensure that they are in compliance with the new requirement when it becomes effective.

The SOLAS Convention

The SOLAS Convention is an international treaty with 162 Contracting States (including the United States) that was created with the goal of ensuring the safety of merchant ships. The Convention seeks to specify minimum standards for the construction, equipment, and operation of ships to maximize their safety. Each Contracting State must ensure that ships sailing under its flag comply with the requirements of the Convention.

The SOLAS Amendments

The World Shipping Council has been advocating for these changes for years. Misdeclared cargo weights have caused such problems as collapsed container stacks, stability and stress to ships, and personal injury to shoreside workers. The purpose of the new amendments to the SOLAS Convention is to obtain the accurate gross weight of packed containers that are moved through a supply chain prior to loading them onto a ship, so that vessel operators can make correct and safe vessel stowage decisions.

The shipper named on the ocean carrier’s bill of lading is the party responsible for obtaining and documenting the verified gross weight of a packed container. The shipper must provide the verified weight to the carrier and terminal operator in a timely fashion, who then must use the verified container weight in ship stowage planning.

The SOLAS amendments provide two methods for the shipper to obtain the verified gross weight of a packed container. Either method described below is acceptable:

  1. After packing and sealing the container, the shipper weighs the packed container using calibrated and certified equipment.

  2. The shipper weighs all packages and cargo items, including the mass of pallets, dunnage, and other packing and securing material to be packed in the container, and adds the tare mass of the container to the sum of the individual masses of the container’s contents.

The SOLAS amendments require a shipper to verify the gross weight of the packed container using one of the above-described methods and to communicate the verified gross weight in writing—either as part of the shipping instructions to the shipping company or via a separate communication. The document declaring the verified gross weight of the packed container must be signed by a person duly authorized by the shipper. The shipper’s container weight verification must then be made available to the terminal operator, the ship’s master, and appropriate government officials upon request.


The amendments will take effect in less than six months. Parties in the container supply chain should implement the necessary processes now to ensure for the timely transmission and exchange of verified container weight information.

Copyright © 2022 by Morgan, Lewis & Bockius LLP. All Rights Reserved.National Law Review, Volume VI, Number 7

About this Author

Margaret Gatti, Securities Lawyer, Morgan Lewis

Margaret Gatti represents US and non-US companies, universities, and financial institutions in matters involving economic sanctions, export controls under the International Traffic in Arms Regulations (ITAR) and the Export Administration Regulations (EAR), customs and import regulations, free trade agreements, antiboycott regulations (EAR and IRS), anticorruption laws (FCPA and UKBA), anti-money laundering legislation, international commercial sales terms (INCOTERMS), international e-commerce, and Bureau of Economic Analysis (BEA) reporting, as well as national security...

Katelyn Hilferty, investments management attorney, Morgan Lewis

Katelyn M. Hilferty helps clients navigate US export controls and customs laws, sanctioned country regulations, anti-money laundering regulations, and national security issues. She has experience with classification/jurisdiction analyses, license applications, compliance counseling, investigations, and voluntary disclosures under the International Traffic in Arms Regulations (ITAR), Export Administration Regulations (EAR), and Office of Foreign Assets Control (OFAC) regulations. Additionally, she has counseled clients on transactions before the Committee on Foreign...