UCP 600 Article 22: Charter Party Bill of Lading Best Practices for Compliance

Introduction

The charter party bill of lading is a transport document used in bulk cargo, tramp shipping, and project cargo transactions where the vessel is chartered rather than sailing on a regular liner service. UCP 600 Article 22 governs the requirements for charter party bills of lading presented under a documentary credit. The requirements differ significantly from Article 20 (regular bills of lading) — most notably, Article 22 does not require carrier identification and permits the master, owner, or charterer (or their agents) to sign the document.

The charter party bill of lading occupies a unique position in UCP 600: it is the only transport document type where the bank expressly does not examine the underlying contract. Article 22(b) states: "A bank will not examine charter party contracts, even if they are required to be presented by the terms of the credit." This provision reflects the commercial reality that charter party contracts are complex, lengthy, and outside the scope of documentary examination.

This guide maps each Article 22 requirement to practical compliance steps, identifies the most frequent charter party bill of lading discrepancies, and provides a pre-shipment verification framework.

Failure Mode Analysis

Failure Mode 1: Applying Article 20 Instead of Article 22

The bank examines a charter party bill of lading using Article 20 requirements. It looks for carrier identification (not required under Article 22), checks for terms and conditions reference (not required under Article 22), and refuses for a charter party indication (which Article 22 permits).

Consequence: The bank applies the wrong article and finds discrepancies that do not exist under Article 22. The refusal is based on an inapplicable standard.

Failure Mode 2: Agent Signature Without Owner/Charterer Name

An agent signs the charter party bill of lading on behalf of the owner. The signature identifies the agent but does not indicate the name of the owner. Article 22(a)(i) requires an agent signing for the owner or charterer to "indicate the name of the owner or charterer."

Consequence: The bank refuses the charter party bill of lading. The missing owner/charterer name is a discrepancy under Article 22(a)(i).

Failure Mode 3: Bank Attempts to Examine the Charter Party Contract

The credit requires presentation of the charter party contract. The bank examines the contract and raises discrepancies based on the contract's terms. Article 22(b) expressly provides that the bank will not examine charter party contracts.

Consequence: The bank exceeds its examination authority. The charter party contract is presented for the bank's records, not for examination. Discrepancies based on the contract's terms are not valid.

Failure Mode 4: Missing On-Board Notation

The charter party bill of lading contains a "received for shipment" notation but no on-board notation. Article 22(a)(ii) requires evidence of goods shipped on board a named vessel.

Consequence: The bank refuses the presentation. The "received for shipment" notation does not evidence shipment on board.

Deterministic Resolution Architecture

Step 1: Confirm the Credit Permits a Charter Party Bill of Lading

Before arranging shipment, confirm that the credit permits a charter party bill of lading. Some credits expressly prohibit charter party bills of lading — if the credit prohibits them, you must arrange a regular bill of lading (Article 20) or a sea waybill (Article 21).

Step 2: Instruct the Master or Agent

Provide the vessel's master or agent with written instructions specifying: the exact port of loading and discharge (matching the credit), the requirement for an on-board notation with date, the master/owner/charterer signature with agent identification (if signed by agent), and the correct agent identification showing for whom the agent signs.

Step 3: Verify the Agent's Signature

If the document is signed by an agent, verify that the agent's signature indicates: (a) whether the agent signs for or on behalf of the master, owner, or charterer, and (b) the name of the owner or charterer (if the agent signs for owner or charterer).

Step 4: Verify the Draft Charter Party Bill of Lading

Request a draft before the vessel departs. Check each Article 22 requirement: correct signatory (master, owner, charterer, or named agent), on-board notation with date, correct ports, full set, no charter party indication prohibition (Article 22 permits charter party references).

Step 5: Confirm the On-Board Date

Verify the on-board notation date falls within the credit's shipment period.

Step 6: Check Port Flexibility

Article 22(a)(iii) permits the port of discharge to be shown as a range of ports or geographical area, as stated in the credit. If the credit specifies a range, the charter party bill of lading may show any port within that range.

Step 7: Present the Charter Party Contract If Required

If the credit requires presentation of the charter party contract, present it with the charter party bill of lading. The bank will not examine the contract under Article 22(b) — it is presented for the bank's records.

Step 8: Document Compliance

Record the compliance analysis showing each Article 22 requirement was satisfied. Maintain this record for audit and dispute-prevention purposes.

Conclusion

The charter party bill of lading under Article 22 is a distinct document type with requirements that differ from regular bills of lading (Article 20). The key distinctions — agent signature requirements, port flexibility, no examination of charter party contracts — reflect the commercial reality of bulk cargo shipping. Practitioners who understand these distinctions at the drafting stage avoid the most common compliance failures. Pre-shipment verification — instructing the master, confirming the credit permits charter party bills, verifying the agent's signature — eliminates the vast majority of discrepancies.

Frequently Asked Questions

Q1: Can the credit prohibit charter party bills of lading?

Yes. The credit may expressly state "charter party bills of lading not acceptable." If the credit prohibits them, you must arrange a regular bill of lading (Article 20) or a sea waybill (Article 21).

Q2: Does the bank examine the charter party contract?

No. Article 22(b) expressly provides: "A bank will not examine charter party contracts, even if they are required to be presented by the terms of the credit." The contract is presented for the bank's records, not for examination.

Q3: Who may sign a charter party bill of lading?

The master, owner, charterer, or a named agent for or on behalf of any of them (Article 22(a)(i)). An agent signing for the owner or charterer must indicate the owner's or charterer's name.

Q4: Can the port of discharge be shown as a range?

Yes. Article 22(a)(iii) permits the port of discharge to be shown as a range of ports or a geographical area, as stated in the credit. This reflects the nature of bulk cargo shipping.

Q5: Is a charter party indication a discrepancy under Article 22?

No. Unlike Article 20(a)(vi) which prohibits charter party indications on regular bills of lading, Article 22 governs charter party bills of lading specifically — a charter party indication is inherent to the document type.

Source Notes

The following sources are provided as context only and were not used as textual source material for this guide.

• ICC, "Set of Guidance Papers on Recommended Principles and Usages around UCP 600" (March 2023)
• ICC, "UCP 600 — Uniform Rules and Practice for Documentary Credits, Including eUCP Version 2.1" (July 2023)
• ICC Academy, "Uniform Rules for Documentary Credits (UCP 600) — eBook" (December 2024)
• ICC Academy, "Certified UCP 600 Specialist (CUCP)" (July 2025)
• ICC, "Commentary on UCP 600" (August 2019)