Article 20 — Bill of Lading: On-Board Notation Requirements

Introduction

UCP 600 Article 20 governs bills of lading presented under documentary credits. When a credit requires a bill of lading, the document must bear an "on board" notation if the credit requires "shipped on board" or "on board" wording. This guide examines the regulatory framework, failure scenarios, and resolution process for on-board notation requirements.

Failure Mode Analysis

Failure 1: Bill of Lading Shows "Received for Shipment" Without On-Board Notation

The bill of lading is marked "received for shipment" but does not carry an on-board notation. If the credit requires "shipped on board," this is a discrepancy.

Failure 2: On-Board Notation Is Undated

The bill of lading carries an on-board notation but the notation does not bear a date. ISBP 745 Paragraph F8 requires the on-board notation to be dated.

Failure 3: On-Board Notation Date Differs from Bill of Lading Date

The bill of lading date is 1 January, but the on-board notation date is 5 January. The on-board notation date is the controlling shipment date under ISBP 745 Paragraph F9.

Failure 4: On-Board Notation Is Not Signed or Initialed

The on-board notation is stamped but not signed or initialed. ISBP 745 Paragraph F8 requires the notation to be signed or initialed.

Deterministic Resolution Architecture

Step 1: Determine if the Credit Requires an On-Board Notation

Review the credit to determine whether it requires "shipped on board" or "on board" wording. If so, the on-board notation is mandatory.

Step 2: Locate the On-Board Notation on the Bill of Lading

Find the on-board notation on the bill of lading. It may be pre-printed, stamped, or otherwise indicated.

Step 3: Verify the Notation Is Dated

Confirm that the on-board notation bears a date. The date must be within the credit's shipment period.

Step 4: Verify the Notation Is Signed or Initialed

Confirm that the on-board notation is signed or initialed by the carrier or its agent.

Step 5: Compare the On-Board Notation Date Against the Credit's Shipment Period

Cross-reference the on-board notation date with the latest shipment date in the credit.

Step 6: Issue a Discrepancy Notice

If the on-board notation is missing, undated, unsigned, or outside the shipment period, issue a refusal notice under Article 16.

Step 7: Request a Corrected Bill of Lading

The beneficiary must obtain a corrected bill of lading from the carrier with the proper on-board notation.

Conclusion

The on-board notation is a fundamental requirement for bills of lading under UCP 600. It serves as evidence that the goods have been shipped on board the vessel. The notation must be dated, signed or initialed, and must fall within the credit's shipment period. Practitioners must verify the notation at the time of document collection.

FAQ

Can a bill of lading be issued without an on-board notation?

Yes, if the credit does not require "shipped on board" or "on board" wording. In that case, a "received for shipment" bill of lading is acceptable under Article 20.

Does the on-board notation date need to match the bill of lading date?

No. The on-board notation date is the controlling shipment date under ISBP 745 Paragraph F9. It may differ from the bill of lading date.

What if the on-board notation is on the back of the bill of lading?

ISBP 745 Paragraph F8 does not specify the location of the notation. It must be on the bill of lading, whether front or back, and must be dated and signed or initialed.

Can the carrier apply the on-board notation after the bill of lading is issued?

Yes. The carrier may apply the on-board notation at any time, as long as the goods are actually on board. The notation date is the shipment date.

Does the on-board notation need to name the vessel?

Article 20(a)(ii) requires the bill of lading to indicate the goods have been shipped on board a named vessel. The on-board notation should reference the vessel.

Source Notes

Context only. The source dossier returned the following sources for this topic. The underlying query was: "article 20 bill of lading on multi-family documentary credit site:iccwbo.org"

• Incoterms® 2020 — ICC (Published 29 Mar 2023)

• Context: Incoterms rules such as FOB, CFR, and CIF require a shipped on board bill of lading as evidence of shipment. The on-board notation confirms compliance with these Incoterms.

• UCP 600 - Including eUCP Version 2.1 — ICC (Published 31 Jul 2023)

• Context: The full text of UCP 600 establishes the on-board notation requirements under Article 20.

• Uniform Rules for Documentary Credits (UCP 600) - eBook — ICC Academy (Published 12 Dec 2024)

• Context: The UCP 600 text provides the primary source for on-board notation requirements.

• Certified UCP 600 Specialist (CUCP) — ICC Academy (Published 12 Jul 2025)

• Context: The CUCP certification covers bill of lading requirements, including the on-board notation, as a core competency.

• Commentary on UCP 600 — ICC (Published 02 Aug 2019)

• Context: The ICC Commentary provides official interpretation of Article 20 and addresses common on-board notation discrepancies.