Common carriers publishing automated tariffs as vessel-operating common carriers (VOCCs) must operate at least one vessel in common carriage in the foreign commerce of the United States to maintain their status. 

Organizations offering common carriage that do not operate at least one vessel are considered non-vessel-operating common carriers (NVOCCs).  Licensing, registration, and financial responsibility requirements for NVOCCs are set forth in 46 C.F.R. Part 515 and are different from the requirements VOCCs must meet. Operating as an NVOCC and failing to meet all relevant requirements may result in a civil monetary penalty.   

Questions regarding VOCC status can be addressed to the Bureau of Trade Analysis at tradeanalysis@fmc.gov.