Charter Party Bills of Lading Under UCP 600 Article 22

Introduction

A charter party bill of lading is a transport document issued under a charter party agreement—a contract between the shipowner and the charterer for the hire of a vessel or part of its capacity. Under UCP 600, charter party bills of lading are subject to specific requirements set out in Article 22, which distinguishes them from regular bills of lading governed by Article 19. The key difference is that charter party bills of lading are not required to name the carrier if the credit permits their presentation. This guide examines the regulatory framework, the specific requirements of Article 22, common failure modes, and the compliance procedures for charter party bills of lading.

Failure Mode Analysis

Failure Mode 1: Charter Party Reference Missing

If the bill of lading does not indicate on its face that it is subject to a charter party, it fails to satisfy Article 22(a). The absence of this reference means the document cannot be treated as a charter party bill of lading under UCP 600.

Failure Mode 2: Wrong Signatory

Under Article 22(b), the bill of lading must be signed by the master, the owner, or the charterer. If it is signed by a party other than these (e.g., a freight forwarder or the shipper), the document is discrepant.

Failure Mode 3: Port of Loading or Discharge Not Stated

Article 22(c) requires the bill of lading to name the port of loading and the port of discharge. If either port is omitted, the document fails to comply with the credit's requirements.

Failure Mode 4: On-Board Notation Missing or Discrepant

A charter party bill of lading must still show an on-board notation with a date that falls within the shipment period. The absence of an on-board notation or a date outside the permitted window creates a discrepancy.

Deterministic Resolution Architecture

Step 1: Confirm the Credit Permits Charter Party Bills of Lading

Verify that the documentary credit permits presentation of a charter party bill of lading. If the credit requires a regular bill of lading under Article 19, a charter party bill of lading is not acceptable.

Step 2: Verify the Charter Party Reference

Confirm that the bill of lading indicates on its face that it is subject to a charter party. This reference must be explicit and identifiable.

Step 3: Identify the Signatory

Confirm that the bill of lading is signed by the master, the owner, or the charterer. The signature must be identified as one of these parties. If the bill of lading is signed by a freight forwarder, the document is discrepant.

Step 4: Verify Port and On-Board Details

Confirm that the bill of lading names the port of loading and the port of discharge, and that the on-board notation is present with a date within the shipment period.

Step 5: Request Corrections from the Charterer or Master

If the bill of lading is discrepant, contact the charterer or the master to request a corrected document. The charterer or master can issue an amended bill of lading with the correct details.

Step 6: Request Applicant Waiver

If corrections cannot be made within the presentation period, request applicant waiver under UCP 600 Article 16(b). Include the charterer's or master's confirmation of the correct details.

Step 7: Present Corrected Documentation

Submit the corrected charter party bill of lading along with a covering letter explaining the discrepancy and the correction.

Conclusion

Charter party bills of lading are governed by a distinct set of rules under UCP 600 Article 22. The absence of a carrier name requirement, the charter party reference, and the specific signatory rules create a unique compliance profile. Exporters and charterers should verify all Article 22 requirements before presenting the document.

FAQ

Q1: Can a charter party bill of lading be presented if the credit does not mention it?
No. Under UCP 600 Article 22, a charter party bill of lading may only be presented if the credit specifically permits it. If the credit requires a regular bill of lading under Article 19, a charter party bill of lading is not acceptable.

Q2: Does the charter party bill of lading need to name the carrier?
No. Under Article 22(d), a charter party bill of lading need not indicate the name of the carrier. This is a key exception from Article 19.

Q3: Who can sign a charter party bill of lading?
Under Article 22(b), the bill of lading must be signed by the master, the owner, or the charterer. The signature must be identified as one of these parties.

Q4: What if the bill of lading is signed by a freight forwarder?
The document is discrepant. Under Article 22(b), only the master, owner, or charterer may sign a charter party bill of lading.

Q5: Can a charter party bill of lading be combined with a regular bill of lading?
No. The document must comply with either Article 19 (regular bill of lading) or Article 22 (charter party bill of lading). It cannot satisfy both simultaneously.

Source Notes

Context only: The following sources were identified in the search dossier and provide background context on documentary credit practices and ICC publications. They do not constitute direct citations for this article's analysis.

1. ICC — "Set of Guidance Papers on Recommended Principles and Usages around UCP 600" (March 2023). Interpretive guidance on UCP 600 articles. Source context: ICC official publication listing.
2. ICC Digital Library — "Position Papers n° 1, 2, 3, 4 on UCP 500" (April 2019). Historical context on charter party bill of lading treatment. Source context: ICC Digital Library listing.
3. ICC — "UCP 600" (July 2023). Direct reference to UCP 600 rules. Source context: ICC official publication listing.
4. ICC Academy — "Uniform Rules for Documentary Credits (UCP 600) - eBook" (December 2024). UCP 600 digital reference. Source context: ICC Academy publication listing.
5. ICC Academy — "Certified UCP 600 Specialist (CUCP)" (July 2025). UCP 600 certification program. Source context: ICC Academy publication listing.