Yes. You are generally operating as an NVOCC in the U.S. ocean trade lane in the following scenarios regardless of whether you issued a House Bill of Lading.: 

• when you re-sell full-container load (FCL) or less-than container load (LCL) ocean freight at a markup or profit
• when you issue your own House Bill of Lading or other shipping documents as the ocean freight transportation provider
• when you allow shipments to move under Service Contracts or rates agreed to by your company whether you issue your House Bill of Lading or not
• when you are listed as Shipper on an ocean Bill of Lading for cargo that you do not own
• when you hold your company out to the shipping public in advertising or other communications as an ocean freight transportation provider

For more information about DPI’s NVOCC licensing and registration services, click here. DPI Members may also more about NVOCCs over on the DPI Knowledge Center.