On-Board Notation Requirements Under UCP 600 Article 20
Introduction
The on-board notation is the mechanism by which a bill of lading evidences that goods have been loaded onto a vessel. UCP 600 Article 20(a)(ii) requires the bill of lading to indicate that goods have been shipped on board a named vessel at the port of loading stated in the credit. This indication can be achieved by pre-printed wording or by a separate dated on-board notation. The on-board notation is one of the most examined and most frequently failed requirements in bill of lading practice.
This guide addresses the strict requirements for on-board notations, where failures arise, and how to resolve them deterministically.
Failure Mode Analysis
Failure Mode 1: On-board notation missing from a received-for-shipment B/L
The bill of lading is pre-printed "Received for shipment." There is no on-board notation. Article 20(a)(ii) requires evidence of shipment on board. A received-for-shipment document without an on-board notation does not comply.
Failure Mode 2: On-board notation lacks a date
The bill of lading contains a stamp: "Shipped on board MV Pacific." No date appears in the stamp. Article 20(a)(ii) requires an on-board notation indicating the date of shipment. An undated notation does not establish the shipment date.
Failure Mode 3: On-board notation date is after the latest shipment date
The on-board notation is dated 15 April. The credit's latest shipment date is 31 March. The notation establishes the shipment date, but that date falls outside the permitted shipment period. The bill of lading is discrepant.
Failure Mode 4: On-board notation does not identify the vessel
The bill of lading states "intended vessel MV Pacific." The on-board notation states "Shipped on board" but does not identify the actual vessel. Article 20(a)(ii) requires the on-board notation to indicate the date of shipment and, when the vessel is qualified, the name of the actual vessel.
Failure Mode 5: Multiple ports of loading with incomplete notations
The bill of lading indicates two ports of loading: Shanghai and Ningbo. The on-board notation covers only Shanghai. ISBP 745 E6(h) requires a dated on-board notation for each port of loading. The notation for Ningbo is missing.
Deterministic Resolution Architecture
- Determine whether the bill of lading is pre-printed "Shipped on board" or "Received for shipment."
- If pre-printed "Shipped on board," confirm the issuance date is the shipment date or that a separate on-board notation indicates the shipment date.
- If "Received for shipment," confirm a separate dated on-board notation exists.
- Verify the on-board notation includes the date of shipment.
- If the vessel is qualified with "intended," confirm the on-board notation identifies the actual vessel.
- If multiple ports of loading are indicated, confirm a dated on-board notation exists for each port.
- Confirm the on-board date falls within the credit's shipment period.
- If the on-board notation is in a designated field or box, confirm it meets the requirements of ISBP 745 E6(a).
- If any element is missing, obtain a corrected bill of lading before presentation.
Conclusion
The on-board notation is the mechanism that converts a received-for-shipment document into an on-board document and establishes the shipment date. Article 20(a)(ii) and ISBP 745 E6 set strict requirements: the notation must indicate the date of shipment, the vessel (if qualified), and the port of loading. An incomplete or missing on-board notation is one of the most common bill of lading discrepancies. Pre-presentation verification of the on-board notation prevents this failure.
FAQ
Does the on-board notation need to be a stamp?
No. ISBP 745 E6(a) states the on-board date may be indicated in a designated field or box. The notation need not be a traditional stamp.
Can the on-board date be before the issuance date?
Yes. If the bill of lading is issued after loading and contains an on-board notation dated before the issuance date, the on-board date is the shipment date.
What if the on-board notation is handwritten?
ISBP 745 E24 requires corrections on a bill of lading to be authenticated. A handwritten notation that is not authenticated may be discrepant.
Does the on-board notation need to state the port of loading?
ISBP 745 E6(e) addresses situations where the port of loading appears in the "Place of receipt" field. A dated on-board notation evidencing shipment at the port stated is required.
Can the on-board notation be on a separate document?
No. The on-board notation must appear on the bill of lading itself. A separate document cannot satisfy Article 20(a)(ii).
Source Notes
- Canonical authority: UCP 600 Article 20(a)(ii); ISBP 745 paragraphs E6(a) through E6(h).
- Live context: Google News RSS scan, ICC "Recommendations of the Banking Commission in respect of the requirements for an on-board notation," raw document; ICC Academy "Certified UCP 600 Specialist (CUCP)," July 2025. Context only, not legal authority.
| Regulation | Article / Section | Requirement | Consequence |
|---|---|---|---|
| UCP 600 | Article 20 | Bill of Lading | Binary determination (compliant/discrepant) |
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Quick Reference Summary
- No reference captured.
Compliance Checklist
| ✓ What Banks Expect | ✗ What Beneficiaries Often Do Wrong |
|---|---|
| On-board notation missing from a received-for-shipment B/L | The bill of lading is pre-printed "Received for shipment." There is no on-board notation. Article... |
| On-board notation lacks a date | The bill of lading contains a stamp: "Shipped on board MV Pacific." No date appears in the stamp.... |
| On-board notation date is after the latest shipment date | The on-board notation is dated 15 April. The credit's latest shipment date is 31 March. The notat... |
| On-board notation does not identify the vessel | The bill of lading states "intended vessel MV Pacific." The on-board notation states "Shipped on ... |
| Multiple ports of loading with incomplete notations | The bill of lading indicates two ports of loading: Shanghai and Ningbo. The on-board notation cov... |
← Scroll horizontally to see all columns
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