Fake CSC plates on shipping containers advisory

We are seeing an alarming new trend of shipping containers that have fake CSC plates. We have heard odd stories of similar issues in the past, it appears this issue is happening more often right now.

What is a CSC plate on a shipping container

CSC is Short for ‘Convention for Safe Containers’ and is governed by articles of the International Maritime Organisation (IMO) which is part of the United Nations. As such this is universally recognized.  A CSC plate is applied to all ISO standard shipping containers that are used for sea transport globally, and these CSC plates act a little bit like a license to allow the shipping container to be shipped internationally. The CSC plate includes lots of important data such as the maximum stacking weight (the max safe weight to stack on a shipping container) the max gross weight (the maximum weight it’s safe to be lifted with when loaded), any timber component treatment ( showing that it meets certain countries requirements for wood treatments on entry into the country), its date of manufacture, the factory that built it, and at times the owner and / or who is responsible for its repair condition via the ACEP scheme number (more technical info on that to follow!)

Shipping Containers with Fake CSC plates landing in the UK

Here is one extreme example we had in recently of a fake CSC plate. We were contacted by an occasional supplier of ours offering this specific shipping container pictured below. Without seeing the CSC pate image, this looks like a reasonably typical, perhaps a bit uglier than standard used shipping container, likely 15+ years old. (we’re guessing nearer 20 years old from its cosmetic wear and overall condition)

Of course we know this, we work with shipping containers every day. We can look at typical wear on a shipping container and have a reasonable idea of the age range.  This may not be as evident to people who don’t work with shipping containers day in, day out.

But the image of the CSC plate on the container doors got us worried. Why would a rough looking shipping container have an immaculate looking CSC plate? Why would a shipping container that looks rough for a 15 year old unit, be built late 2016 (younger than 8 years old)? This just doesn’t stack up.

This is a worrying new trend and not the only example we have seen.

Why are shipping containers appearing with fake plates? 

It’s worth saying, whilst this specific container as shown had a fake plate. It was perfectly sound for use as a shipping container despite its age and rough appearance.

We’re suggesting that these shipping containers are slipping through some loopholes in the system. The issue we want to highlight is that we believe at least one of these examples has been in circulation and used again for maritime not rail movements for up to 3 years after having the CSC plate swapped. This suggests to us that numerous yards have seen this, they will have noticed it (any experienced container yard inspector will be way better at spotting a fake plate than us) and they have let it go.

From advice taken, the cause of these fake CSC plates appears to the China to Europe rail service, which we understand has its own requirements for shipping containers to be 7 years old or younger.

Rail services have their own unique safety worries, the major issue being that the containers do undergo a fair bit of force when passing another train at speed. There is a large force applied to both sets of carriages on both rails as the air gap between the 2 passing trains undergoes extreme pressure changes. if there are any small bit of debris on the container, or any bits that can flake or otherwise come off the shipping container – then this can cause major issues to a train that may be half a mile long with a lot of shipping containers on its carriages.

This is obviously very different from a shipping container travelling by sea and if our advice is correct this is a very understandable reason why the railway imposes such a rule. In essence the railway operator is free to impose whatever rules for use of its service in the same way that any logistics carrier would be expected to impose their own rules and requirements for safe transport.

Unfortunately as best as we understand, the system is being cheated, and we worry this is happening a lot, possibly routinely.

Some over-simplified background.

• Shipping Container repair standards are uniform globally.  CSC provisions are dependent upon the governmental administration where the container is registered. This means that the degree to which they are implemented and monitored varies from country to country.
• Containers not used for sea transport are not required to display a CSC plate – so by IMO standards, a shipping container travelling on a train is not bound by the same regulations. The requirement for CSC plates on the rail service is a rule applied by the rail operator and not by maritime conventions or law.
• The rail operator is the only person liable for not following their own rules in this scenario.

We believe that some bad actors are swapping the CSC plates to meet train regulations. It’s obviously cheaper to buy a 15-20 year old shipping container than it is a 7 year or younger container for your shipment. We assume there is either a lack or training within the train operator, or a lack of checking, or perhaps a degree of complicity in this process is allowing these shipping containers with fake plates through.

Whilst on the train maritime laws are not being broken if these ship with a fake CSC plate. This issue is when they reach destination, get sold off and may then re-enter circulation. They are sold on as ‘CSC plated’ and suitable for re-use as an export shipping container.’ In many cases the owner may not know they have brought a shipping container with a fake CSC plate on it.  It’s here when major problem can get realized if anyone then figures out the container has a fake CSC plate on it.

In this example, it’s showing a 2012 build, which if we are right about the train and this 7 year rule, suggests that it’s been in circulation in the industry for approx. 3 years AFTER having the CSC plate swapped over. This has landed into a supplier’s depot in the UK after shipping into the UK by sea, we have made clear that we won’t help them sell this for an export job even though we know the container is still structurally sound and came into depot needing no repairs (a depot we know well has inspected it).

The worry is that these shipping containers with fake plates are going back into circulation and being used for shipment by sea. This appears to be the case with this specific example.

In this example, as well as a pristine brand-new plate on a supposedly 10 year old shipping container, you can also see the markings on the right-hand side where the old CSC plate was removed, but the sealer not cleaned off the metal surface of the shipping container. You can also see at the top new sealer applied that has gone over the CSC plate (a genuine shipping container factory would never fit a CSC plate this poorly)

In our industry we are used to working with regular, reliable and trustworthy suppliers. Container traders generally trade between each other a lot. As soon as one bad shipping container gets ‘into the system’ it can be traded multiple times before its seen or inspected by someone.

No Repair issue, no problem surely?

Fake CSC plates can cause a wide range of issues, even if the repair standard on the container itself are OK.

Firstly, if the plate is fake, what else isn’t right? Can you trust the person who did this to properly maintain and repair the shipping container as well, or will they be cutting corners with repair standards here too?

The physical CSC plate also has a lot of important information on it, including a unique batch number for this production run which helps traceability, and details on floor treatment that may or may not allow the shipping container into certain countries (e.g. Australia and New Zealand). One assumes that the batch numbers on a fake CSC plate will not correlate or trace correctly. The information on construction, design, tolerances and floor treatments may also not be accurate.

As such we cannot knowingly renew the CSC plate on a shipping container that has a false or fake CSC plate on it. If the plate is False, we can’t renew the validity on a false plate that was never valid in the first place. (For comparison, would you expect a car garage give you a MOT for a car that they knew had fake number plates? of course not. It’s much the same issue for us – even if the shipping container is good, if the registration information isn’t correct then we can’t apply our approval)

If the max stacking and max load weights are inaccurate, this may also lead to major industrial incidents and loss of life. If a stack collapses at a port or on a boat because the max stacking weight is not correct this can cause any port operation or boat owner / operator many millions on costs and lost earnings whilst the issue is resolved. If the wood treatment information isn’t correct it would be treated as a major bio-hazard risk for island nations globally for fear of importing various new bugs, mites or similar pests into a region.

Obviously if you buy a 7 year old container you will expect to pay a premium versus a 15+ year old used shipping container, so you don’t want to find out you’ve been duped or effectively scammed if buying a younger shipping container.

The other major issue arises when the perpetrators start ‘pushing the limit’ of what they can do. Here we have an extreme example of a shipping container that is well over 20 year old, potentially over 30 years old with a plate saying its 9 years old. Anyone in the industry will recognize this container as having a door design that was phased out approx. 20 years ago (i.e. approx. 20 years ago, all the old shipping containers with this door design were no longer in common circulation). The bottom of the doors has had serious repairs at the bottom suggesting the door was rotting away, and on the bottom right-hand side of the doors are you can see an area where the original CSC plate was mounted.

This is a prime example of where things can get dangerous. A shipping container this old should not in our mind be used for carrying freight. If the bottom of the doors has rusted away, what does the underside look like we wonder? (We are getting a picture of this from our yard shortly) .

Its highly likely this shipping container has at best been ‘bodged’ to meet shipping standards regardless of country of origin. There is a fair chance this was shipped with repairs way short of accepted minimum repair standards. There comes a point where the ‘saving’ realized by the scammers doing this, and their greed for bigger mark-up starts to knock on and cause major safety risks for the industry at large and for the shippers of any cargo that moves.

Another major worry is the use of ACEP numbers on these CSC plates, in short, the ACEP number means that the registered owner of that ACEP number is the owner of the shipping container, and that they are responsible for the repair condition of the unit. If this unit has had a fake CSC plate adding with someone’s ACEP number on, this plate will indicate that a major fleet owner is taking care of this shipping container (ensuring it is regularity checked and repaired), when that not the case. (This is a slight over-simplification of how ACEP plates work and in reality, the ‘other’ system is just as easy to forge or falsify)

How to avoid buying a shipping container with a fake CSC plate on it.

This is one area where a bit of a ‘classic’ approach may help. Our main tip here:

Buy from an experienced, reputable and established supplier. Ensure your supplier checks all shipping containers in their UK yards before sale (or in the country you are buying if outside of the UK).

For us, a reputation for anything like this will likely put us out of business, so we feel this is extremely important to check and get right going forward. If you are not experienced with shipping containers this can be extremely difficult to identify and confirm. The examples we list here are some of the more extreme and obvious ones we have seen.

We can assure you that every seaworthy CSC plated shipping container we sell will not come with a fake CSC plate, we are aware of these issues and putting in additional checks to ensure this doesn’t happen to our customers. In the very unlikely event it does, let us know at the earliest opportunity and we will offer a full replacement at our cost, also covering delivery costs if we have delivered this to your site for you. (We will not cover additional 3rd party costs under any circumstances). We are taking the unusual step of issuing this advisory to try and make others within the industry aware of this issue. We take this issue very seriously.

We have it relatively easily. We know what we are looking out for, and we can hold our suppliers to account. Generally we only pay for shipping containers after they arrive in our depots, and  we can raise a breach of contract issue with our suppliers in the event we are sold a shipping container with a fake plate and either refuse the goods, or renegotiate a price based on fair value for the real age of unit. We have good relationships and credit arrangements with these suppliers. A one-off customer won’t. In these instances we will ensure the shipping container can’t or won’t be re-enter circulation once it’s been sold to our customer (we can remove, or sometimes paint over the CSC plate to prevent this being used for export in future, or we will use it on a conversion job or cut it into 10fts that can’t be shipped on a boat – fortunately we have plenty of options here)

We’re not going to publish a guide on how to spot a fake plate, you will need to trust that we know what we are doing from many years of experience, but we also don’t want to give those supplying the fake plates a handy ‘how to guide’ on not getting spotted.

What to do if you have a shipping container with a suspect or fake plate.

In reality, if you are using the shipping container for storage use, and if it’s doing the job well, there is likely very little you can do. You’ve accepted the shipping container, it is doing it’s job, and if it was sold as used you likely had little promise of age or lifespan or cosmetic appearance from your supplier. As such even with a fake plate in many cases this will still be ‘as described’ at point of sale, and as the CSC plate if not relevant to shipping containers being used for static storage, we don’t know how this would materially change of cause a breach of contract to supply and deliver the container to you.

If you were sold the container with a specific date of manufacturer promised, then you may have recourse to request a partial refund or replacement from your supplier, however if you company is not based in the UK and if you have accepted the delivery, you may have issues here. Legally if you accepted delivery, you accepted the goods in their condition. You will be relying on the traders’ own morals here for any leeway offered, or the laws in your specific country. You may also like to take legal advice if in this position if your supplier is not being as helpful as you’d like.

If you are using this container for an export job we would recommend to try and return your shipping container for a refund, or preferably refuse the delivery on arrival if you can or have extreme doubts. It’s worth mentioning the owner of the shipping container will be legally responsible for its repair condition as it sails. You should not export cargo in any shipping container you knowingly know has a false plate. Any insurance you have will likely be invalid, and in the event of issues you may open yourself up to claims that could crush a sizable established company overnight.

Even if a shipping container meets correct and suitable repair standards, we cannot knowingly renew the CSC validity on a shipping container with a fake CSC plate to let you ship it out of the country.

Is this a long-term Issue?

In all likelihood, this issue has likely been exasperated by the recent shortage of shipping containers and the high prices that have accompanied the shortage. This makes it more attractive for people to sell off their old shipping containers being used for storage, effectively allowing old shipping containers to come ‘out of retirement’.

However if the train maintains these regulations without any serious checks, and if market conditions mean there is money to be made from taking off the original CSC plate and adding a new fake one, this this is likely going to continue at some level. These market conditions may have exacerbated the problem, but it is not the cause in our mind.

If and when the train operators choose to train their staff on checking CSC plates, and reject shipping containers with false plates, this issue would presumably stop overnight.

We’d like to thank external container inspector, and Colin Rubery from the Container Self Storage and traders association for some technical input into this post.

Budgetshippingcontainers.co.uk offer the UK’s largest online range of shipping containers for sale with a nationwide network of storage and conversion yards and crane equipped delivery vehicles.

If you need a shipping container feel free to browse our online range of shipping containers for sale. You can also call us on freephone 0808 1234 215 any time 9am – 5pm weekdays and our team will be happy to discuss your requirements. Alternatively, you can use our online shipping container quote form or request a telephone callback. In both cases we aim to get back to you within 1-2 working hours (may take longer for more detailed quotes).