NVOCC’s operation income mainly depends on freight differences. So， to a small-sized operator， unpaid or not in time payment of freights for a large contract will certainly affect its capital turnover and lead to the difficult operation. However， such things are common seennowadays. Till now， guarantee given to NVOCC enterprises is limited， and weak.As is known to all， RMB 800，000 of cash deposit is an important entry requirement to NVOCC market. What does “RMB 800，000 of cash deposit” mean? Most enterprises regard it as a distinguishing from general freight agents， the “qualification”. Are“qualification” and “capital” equal， and can they transform into the other to “get the money’s worth”?Entry requirement should be tightenIt is sure that the cash deposit can’t equal market entry qualification， but cash deposit has raised more and more voices to lift market entry requirements.According to Regulations on Ocean Shipping and the implementation provisions， enterprises applying for NVOCC business only need to “register lading bill in Ministry of Communications， pay RMB 800，000 of cash deposit and complete filing of freight”， and there is no requirement on the registered capital. Industrial participants appoint that no requirement on registered capital reduces the entry barriers of NVOCC market. What’s worse， there are unqualified companies in NVOCC market， causing disordered market competition.It seems that cash deposit has been the key factor for a company to undertake NVOCC business or not. According to CASA， regulations on ocean shipping have no registered capital requirement on corporate applicators for NVOCC， and though a requirement on registered capital can raise the entry barriers， it cannot play the role of recovery and warning as cash deposit.Every market needs a step by step development. In consideration of market standardization and protection， it may be appropriate to lift NVOCC market entry requirements by other means. Meanwhile， CASA hopes NVOCC enterprises to regulate their behaviors， and have a standardized and lawful operation.“Capital problems” put NVOCC enterprises to a more risky situationNVOCCs often have a larger investment and higher costs， especially when they take new businesses as carriers， because NVOCCs are not only responsible for land transportation of goods or containers before shipment， but also for export declaration， documentation and cargo warehousing， etc.NVOCCs usually are commercial organizations that do not have strong economic strength as actual carriers. Once encountering a problem， they even don’t have ships available for mortgage or seizure， nor other property to for the protection of the third parties. Cash deposit， to some extent， can ease shippers’ concerns. But， in practice， NVOCCs have greatly different financial status and business scales， so the amount of cash deposit shall differ. In general， the risk in choosing a NVOCC is often greater than freight agents.Besides， when taking goods business， freight forwarders will sign a transportation contract with a third party under the owner’s name rather than his own， and they are not on behalf of a carrier to issue marine bill of lading. The only duty for freight forwarders is arranging export transportation and related export procedures. Although freight forwarders sometimes provide transportation and related storage， packing， customs clearance and inspection; after all， they are not the carrier or the goods owner.In other words， when freight forwarders undertake import and export business entrusted by the goods owner， they will be sure agents as long as they act under the owner’s name. And they will not be responsible for goods losses or damages caused by a third party， if the agent itself and the second party it chose has no fault. The both parties of the transportation contract arranged by an agent are the shipper and the actual carrier. When the goods occurs damage or losses， the agent can assist the goods owner to claim against the responsible parties， but this is not his duty. NVOCC signs contracts in person when undertakes goods transportation business， therefore he should be responsible for goods damage and losses. In this way， NVOCC takes much more responsibilities than freight agents.Is RMB 800，000 of cash deposit much?According to regulations on ocean shipping， entering NOVCC markets only needs a registration and pay RMB 800，000 of cash deposit， and RMB 200，000 of cash deposit for each branch. It is learned that the cash deposit basically has two functions: on one hand， to recover the goods owner’s losses; on the other， to pay the fines for corporate illegal operation activities. In fact， NVOCC business is more risky， and RMB 800，000 is not sufficient for larger amounts of commercial compensation. Such a cash deposit is more like governmental supervision， to prevent from commercial disputes. It seems that RMB 800，000 for each enterprise is not that much.On January 1st， 2002， the Regula- tions on Ocean Shipping of the People’s Republic of China， which established NVOCC system， took effect. It is learned that 3，000 plus companies have obtained NVOCC qualifications through paying cash deposit to the special account by the end of 2008， meaning the account had had a total deposit of RMB 2.4 billion by then. If we can make good use of this amount of money， the capital bottleneck of NVOCC enterprises will be solved， turning this“qualification” (RMB 800，000) into“capital” in need.Breakthrough in deposit system and utilization“Deposit” adds financial burdens to NVOCC enterprises， especially when the financial crisis still has its influence. CASA has discussed the possibilities of replacing insurance system with cash deposit with CIRC and other departments. However， as insurance companies belong to a third party， they can play the compensation function， but not that of governmental fines. This is a difficult problem for long.On this Nov. 16th， deposit liability insurance system for non-vesseloperating common carriers took effect. In the future， NVOCC can choose cash deposit or liability insurance to obtain qualification for NVOCC business. 5 NVOCC enterprises were allowed insure deposit liability insurance. This was a new measure taken by Ministry of Communication together with CIRC to promote industrial development， innovate administrative supervision model and develop modern logistics and transportation industry.It is learned that due to historical reasons， cash deposit was the only financial liability guarantee for NVOCCs. During the drafting of Regulations on Ocean Shipping (the“regulations”)， former Ministry of Transportation tried to incorporate guarantee， insurance and cash deposit into NVOCC liability insurance， but due to unmatched financial and insurance markets， finally cash deposit was stated as the only liability guarantee means for NVOCC companies.