Shipper Owned Containers (SOC): Compliance Guide for UK Exporters

What Is the Difference Between an SOC and a COC?

A Carrier Owned Container, or COC, is supplied from the shipping line’s owned or leased equipment fleet. The customer normally collects, loads and returns it within the carrier’s agreed free time. An SOC remains under the shipper's ownership or control and does not have to be returned to the shipping line as carrier equipment.

CSC Plates and Container Safety Approval

The International Convention for Safe Containers 1972, known as CSC 1972, establishes internationally accepted safety requirements for containers used in international transport. The International Maritime Organisation states that the Convention provides procedures through which containers are approved for safety by a contracting administration or an authorised organisation.

Official source: International Maritime Organisation: International Convention for Safe Containers

What Information Is Shown on a CSC Plate?

The UK Health and Safety Executive states that freight containers covered by the Convention must have a Safety Approval Plate permanently affixed. The plate records information about the container’s approval, identification, maximum operating gross weight and examination arrangements.

The maximum operating gross weight displayed on the plate is a structural limit. It is not the actual Verified Gross Mass of a particular packed shipment.

Official source: Health and Safety Executive: Freight container safety

Periodic Examination and ACEP

A CSC-approved container must be maintained and examined under an approved system. The IMO explains that owners may use a periodic examination scheme or an Approved Continuous Examination Programme, commonly marked as ACEP.

The joint IMO, International Labour Organisation and United Nations Economic Commission for Europe Code of Practice for Packing of Cargo Transport Units states that a container should undergo its first thorough examination within five years of manufacture. Subsequent examinations are required at intervals of no more than 30 months. An approved ACEP system provides an alternative method of recording and managing those examinations.

Official sources: IMO: CSC container approval and examination and IMO, ILO and UNECE: CTU Code

A CSC plate should never be treated as proof that a visibly damaged container is safe to ship. Doors, corner castings, structural rails, roof panels, walls, flooring and locking gear should be checked before loading. Suspected structural damage should be assessed by a competent container inspector.

Verified Gross Mass Requirements

SOLAS Chapter VI requires the gross mass of a packed container to be verified before it is loaded onto a ship covered by the regulations. The shipper is responsible for obtaining, documenting and communicating the Verified Gross Mass, or VGM, to the carrier and terminal in sufficient time for vessel stowage planning.

The IMO states that a packed container should not be loaded aboard a vessel when its VGM has not been supplied, subject only to the limited arrangements described in the applicable regulations and guidance.

Official sources: IMO: Verification of the gross mass of a packed container and Maritime and Coastguard Agency: MGN 699

The Two Permitted VGM Methods

Official sources: GOV.UK: Verification of packed container gross mass and Maritime and Coastguard Agency: Method 2 approved weighing

A haulier, warehouse or weighing contractor may perform the physical weighing, but contracting out the task does not automatically transfer the shipper's regulatory responsibility. VGM procedures should therefore be agreed in writing before the container reaches the export terminal.

BIFA also provides industry guidance on accurate container weights, cargo securing and communication through the freight chain.

Industry guidance: British International Freight Association: Safety in the maritime containerised world

UK Customs Procedures for SOC Shipments

Owning the container does not remove customs requirements for the cargo. A business exporting commercial goods from England, Scotland or Wales will generally need a GB Economic Operators Registration and Identification number. Different requirements may apply to movements involving Northern Ireland.

Official source: HM Revenue and Customs: Get an EORI number

The exporter or its appointed representative must submit the required export declaration and obtain customs clearance before the goods leave the UK. Declaration deadlines depend on the mode of transport, destination and type of movement, so the current HMRC instructions should be checked for each shipment.

Official source: HM Revenue and Customs: Making a full export declaration

Import and export declarations are processed through the Customs Declaration Service. Businesses that make declarations themselves require appropriate access and compatible customs software. Many exporters appoint a freight forwarder or customs agent instead.

Official source: HM Revenue and Customs: Customs Declaration Service

A written customs-agent appointment should specify whether the agent is acting directly or indirectly and should set out the responsibilities of each party. The exporter must provide accurate commodity codes, descriptions, values, origin information, weights, licences and supporting documents where required.

Industry guidance: BIFA: Appointment and responsibilities of a customs agent

SOC Compliance Checklist

1. Confirm that the shipping line accepts SOC equipment on the proposed route.
2. Select a suitable 20ft, 40ft or special container.
3. Verify the container identification number and ownership records.
4. Check that the CSC Safety Approval Plate is present and legible.
5. Confirm a valid next examination date or approved ACEP marking.
6. Inspect the unit for structural damage before loading.
7. Pack and secure the cargo according to its weight and transport risks.
8. Determine VGM using Method 1 or an approved Method 2 process.
9. Submit the VGM to the carrier within its documented cut-off time.
10. Complete export declarations and obtain customs clearance.
11. Confirm import requirements with the consignee or destination customs agent.
12. Retain purchase, inspection, weighing and shipping records.

SOC Container Supply Across the North West

Shipping Containers of Liverpool supports exporters, manufacturers, freight operators and project logistics companies throughout the region. Delivery is available to locations including Bootle, Birkenhead, Ellesmere Port, Warrington, Preston and Wrexham.

Customers should provide the intended cargo, route, required container size and expected shipping date when requesting a quotation. This allows the available equipment and documentation requirements to be considered before delivery.