Who Does the CTU Code Apply To?
The CTU Code places responsibility on anyone involved in the packing and securing of cargo in a CTU. This includes:
- Exporters and manufacturers who pack their own cargo into containers
- Pack houses and third-party packing contractors who stuff containers on behalf of exporters
- Freight forwarders who supervise or arrange container packing
- Cargo consolidators who pack multiple shippers’ cargo into a single container
The person or company responsible for packing the CTU is required to complete a Container Packing Certificate (CPC) or Vehicle Packing Declaration confirming that the cargo has been packed and secured in accordance with the applicable regulations. This document becomes part of the shipping documentation and is the primary evidence of compliance in the event of a cargo claim.
The Six Core CTU Code Requirements
| Requirement | What It Means for South African Exporters |
|---|
| 1. Verify the CTU is fit for purpose | Inspect the container for structural damage, contamination, and serviceability before packing |
| 2. Use the CTU correctly | Do not exceed the maximum gross mass rating; distribute cargo weight evenly across the floor |
| 3. Secure cargo against dynamic forces | Apply lashing and strapping rated for the cargo weight and transport mode — using verified product specifications |
| 4. The 15cm rule | Cargo must not protrude more than 15cm beyond the container floor sill at the door end — affecting how the rear of the container is loaded |
| 5. Complete the packing certificate | Issue a Container Packing Certificate or Vehicle Packing Declaration for every packed CTU |
| 6. Dangerous goods compliance | DG cargo must also comply with the IMDG Code; the CTU Code requirements are additional to, not in place of, IMDG requirements |
Cargo Securing Under the CTU Code
The cargo securing requirements of the CTU Code are the area where DunLash products directly support compliance. The Code requires that cargo be secured against the dynamic forces of transport — defined as multiples of the cargo weight — using securing systems that are rated for the task. Key principles:
- Securing systems must have a documented breaking strength — not just a nominal rating
- The MSL (Maximum Securing Load) of each lashing or strapping component must be determinable from test data
- Cargo must be restrained against longitudinal, transverse, and vertical forces as defined by the transport mode
- The number of lashings or straps is calculated based on the required restraint force and the MSL of the product
DunLash provides SGS certified strapping and lashing products with independently documented breaking strengths for every size and configuration. The SGS Technical Inspection Reports that accompany DunLash products are the specific documentation the CTU Code requires.
The 15cm Rule — What It Means in Practice
One of the CTU Code requirements that most directly affects how South African exporters pack containers is the 15cm rule: cargo must not protrude more than 15 centimetres beyond the container floor sill at the door end when the doors are open.
For many cargo types — palletised goods, bundled materials, agricultural produce — this means the rearmost pallet or unit must be loaded at least 15cm back from the door opening. This creates a gap at the door end that, if not managed, reduces the usable floor area of the container and may affect cubic capacity utilisation.
Correct loading practice, combined with dunnage bags to fill the void behind the rearmost load and prevent forward movement during the voyage, is the compliant solution. DunLash dunnage air bags in appropriate sizes fill this rear void, prevent cargo movement, and ensure the 15cm compliance gap is maintained throughout the voyage.
Container Packing Certificate — What to Include
The Container Packing Certificate (CPC) is the documented evidence that the CTU Code has been followed. A compliant CPC should confirm:
- The identity of the CTU (container number, seal number)
- That the CTU was inspected and found fit for purpose before packing
- That cargo was packed and secured in accordance with the CTU Code
- For DG cargo: that the cargo complies with the applicable IMDG Code requirements
- The name and contact details of the person responsible for packing
- The date and place of packing
The CPC is part of the transport documentation provided to the shipping line and is available to port authorities on request. In the event of a cargo claim, the CPC is the first document the insurer and shipping line will request.
How DunLash Supports CTU Code Compliance
- SGS certified products — every DunLash strapping and lashing product has an independently witnessed SGS Technical Inspection Report documenting system breaking strength. This is the product certification referenced in CTU Code compliance documentation
- Product specification sheets — clear documentation of product dimensions, breaking strengths, and MSL values for use in lashing calculation records
- Cargo securing assessments — DunLash can assess your cargo securing approach against CTU Code requirements and recommend compliant product selections
- Pack house training — DunLash provides hands-on training for pack house staff covering correct product application, lashing calculation basics, and CTU Code awareness
