The UK Maritime and Coastguard Agency (MCA) has stated it would enforce the new SOLAS regulations with a “light touch” for a period of three months from July 1, 2016.

That is the date when new rules go on the books requiring that shippers provide carriers with a verified gross mass (VGM), in other words, the weight, of loaded ocean containers.

Why cut shippers slack? Let’s say an ocean shipping container was packed with an intended loading date prior to July 1, but, for whatever reason, did not make the intended sailing. It was then loaded aboard a vessel after July 1. Would the shipper be out of compliance of the VGM was missing?

“Strictly speaking, the regulation would apply,” said MCA, in a recently released SOLAS document. But that is where the “light touch” comes in, “in order to permit any such containers to be shipped and allow a smooth transition.” The same approach would also apply to transhipped containers, the document said.

However, shippers cannot expect the same treatment outside of the UK. The MCA document made clear that “this was solely the UK position.”

Might that state of affairs create complications if a container which received dispensation from the UK authorities was aboard a vessel bound for Japan which then called on a port in Germany? Could a German port inspector, discovering that the container loaded in the UK was non-compliant, hold the container in Germany?

The MCA’s answer: “Since this regulation relates to export containers only, there would be no direct requirement for the German inspector to make such enquiries.” However, the issue is not all that clear and it has been raised as an agenda item for future international discussions.

Another interesting wrinkle that emerges from the MCA document: containers that are driven onboard a vessel are exempt from the SOLAS requirements. What if a terminal tractor carried two containers on top of each other? Would both be considered to be ro/ro containers that fall outside of the SOLAS regulation?

The answer: an unequivocal Yes.