UCP 600 Article 15: Examining Bills of Lading

Introduction

The bill of lading is the most important transport document in documentary-credit practice. Under UCP 600 Articles 19–25, bills of lading are subject to detailed examination requirements. When a credit calls for a bill of lading, the examining bank applies the Article 14(a) facial-compliance standard and cross-references the specific requirements of Articles 20 (marine/sea or inland waterway transport documents). The bill of lading is the document that evidences shipment, title, and the contract of carriage — its examination is the most rigorous in the entire document set.

This guide covers the specific compliance requirements for bills of lading under UCP 600, the common discrepancies, and the examination methodology.

Failure Mode Analysis

Failure Mode 1: On-board notation missing or incorrect

The bill of lading does not bear an on-board notation, or the on-board notation is undated. Under Article 20(a)(ii), the bill of lading must indicate shipment on board a named vessel. ISBP 745 A14 requires that the on-board notation must be dated. An undated on-board notation is a discrepancy.

Failure Mode 2: Port of discharge does not match the credit

The credit states "port of discharge: Rotterdam." The bill of lading shows "port of discharge: Antwerp." Under Article 20(a)(iii), the bill of lading must indicate the port of discharge as stated in the credit. Even if Antwerp is the intended final destination, the bill of lading must state the credit port.

Failure Mode 3: Bill of lading not signed by the carrier

The bill of lading is unsigned, or is signed by the shipper rather than the carrier. Under Article 20(a)(i), the bill of lading must be signed by the carrier or a named agent for or on behalf of the carrier. A missing or incorrect signature is a discrepancy.

Failure Mode 4: Full set of originals not presented

The bill of lading indicates "original 1 of 3" but only one original is presented. Under Article 20(a)(iv), the bill of lading must be the sole original or all originals as indicated. If three originals are indicated, all three must be presented.

Failure Mode 5: Transshipment occurs when prohibited

The credit prohibits transshipment. The bill of lading indicates that the goods were transshipped at an intermediate port. Under Article 20(b), transshipment is permitted unless the credit expressly prohibits it. If the credit prohibits transshipment, the bill of lading must not indicate transshipment.

Failure Mode 6: Shipment date inconsistency

The bill of lading is dated after the credit expiry date. Under ISBP 745 A14, the on-board date must not be later than the last day for shipment. A shipment date that falls after the credit period is a discrepancy.

Failure Mode 7: Goods description conflict

The bill of lading describes the goods differently from the invoice. Under Article 14(d), data must be consistent across documents. A goods description on the bill of lading that conflicts with the invoice is a discrepancy.

Deterministic Resolution Architecture

1. Read the credit's bill-of-lading requirement. Identify the exact port of loading, port of discharge, any transshipment prohibition, and any special conditions. The credit text is the authority.

2. Verify the carrier's identity and signature. Confirm that the bill of lading is signed by the carrier or a named agent. Check the carrier's name and the agent's authorization.

3. Confirm the on-board notation. Verify that the bill of lading bears a dated on-board notation. The on-board date must not exceed the credit's shipment date.

4. Match the ports. Compare the port of loading and port of discharge on the bill of lading against the credit. They must match exactly.

5. Check transshipment. If the credit prohibits transshipment, confirm that the bill of lading does not indicate transshipment at any intermediate port.

6. Verify the full set of originals. If the bill of lading indicates multiple originals, confirm that all originals are presented.

7. Cross-check the goods description and quantity. Compare the bill of lading description and quantity against the invoice. They must be consistent under Article 14(d).

8. Confirm the shipment date. The on-board date must fall within the credit period and must not precede the invoice date (unless the credit permits).

Implementation Checklist

Conclusion

The bill of lading is the cornerstone document in documentary-credit practice. Its examination under UCP 600 requires attention to the carrier's identity and signature, the on-board notation, the ports of loading and discharge, transshipment compliance, the full set of originals, and the consistency of data with other documents. A systematic approach — reading the credit, verifying each Article 20 requirement, and cross-checking across the document set — ensures a complying presentation.

The correct process is not "present any bill of lading that shows shipment." It is to verify every Article 20 requirement, confirm the on-board notation, match the ports, and ensure consistency across the document set.

FAQ

What is the difference between a received-for-shipment and an on-board bill of lading?

A received-for-shipment bill of lading indicates that the goods have been received by the carrier but not yet loaded on the vessel. An on-board bill of lading indicates that the goods have been loaded on the vessel. UCP 600 Article 20(a)(ii) requires an on-board notation unless the credit stipulates otherwise.

Does the bill of lading need to show the vessel name?

Yes, under Article 20(a)(ii), the bill of lading must indicate that the goods have been shipped on board a named vessel. The vessel name must appear on the bill of lading.

Can the bill of lading indicate a port of discharge different from the credit?

No. Article 20(a)(iii) requires the bill of lading to indicate the port of discharge as stated in the credit. A different port is a discrepancy.

What if the bill of lading indicates transshipment and the credit prohibits it?

This is a discrepancy. Under Article 20(b), transshipment is permitted unless the credit prohibits it. If the credit prohibits transshipment, the bill of lading must not indicate transshipment at any intermediate port.

How many originals of the bill of lading must be presented?

Under Article 20(a)(iv), if the bill of lading indicates that more than one original has been issued, all originals must be presented. If only one original is indicated, one original suffices.

Source Notes

• Canonical authority: UCP 600 Articles 20, 14; ISBP 745 paragraphs A13–A18.
• Live context: ICC Academy documentary-credit certification and types of documentary credit content surfaced through Google News RSS. Context only.