FCL container shipment tends to have lower freight rates than an equivalent weight of cargo in bulk.

The market was also not geared towards transporting or selling cargo in bulk, therefore most ships carried a wide range of different products in different holds and traded outside fixed routes.

The code applies to ships carrying oil or any hazardous cargo in bulk, and it recommends that all tankers of more than 5000 tonnes are provided with electronic and satellite navigation equipment.

The 500 tons were not specific goods because, in the words of Lord Hanworth M.R. 'There was no ascertainment or identification of the 500 tons out of the cargo in bulk.'

As of 1999, the International Convention for the Safety of Life at Sea defines a bulk carrier as "a ship constructed with a single deck, top side tanks and hopper side tanks in cargo spaces and intended to primarily carry dry cargo in bulk; an ore carrier; or a combination carrier."