8

BILL OF LADING
HISTORICAL INTRODUCTION

Nobody can precisely say when the bill of lading (B/L) was used for the first time. The
first entries in the ship’s log book of goods shipped on seagoing vessels must be
more than a thousand years old.

In the "Ordonnance Maritime de Triani" (an Italian town) of 1063, it was laid down
that every master was obliged to have a clerk (in fact a writer) on board. It also made
mention of a log book or register. This is the first indication that goods which were
shipped were registered.

The ordinances of the Mediterranean towns and the “Consulat de la Mer”, made
reference of a "scribanus" or writer. The writer had to enter all the goods that were
loaded on board in a log book and keep it up to date. In accordance with the
"Consulat de la Mer", the master or the crew were not allowed to load or discharge
the goods without the writer being informed. When goods which were entered in the
logbook by the writer were lost, the master was obliged to refund them. If he could
not refund them, his ship could be sold. All entries in the log book had force of law.

Entry of the goods in the log book served thus as evidence that the goods had been
shipped on board. Shippers could receive an excerpt of the log book that could be
presented in case the log book was lost. These excerpts can be considered as the
precursors of the bill of lading.

The bill of lading, just like the insurance policy and the bill of exchange, originated in
Italy. It was found for the first time in 1526, in a decree of the town of Florence under
the name of "polizza di carico" i.e. "police de chargement".

In the sixteenth century, the use of the bill of lading is extended to Western Europe
and the ordinances around that time, contained several provisions which were
related to the bill of lading. We will limit ourselves to the "Ordonnance de Philippe II"
of 1563 regarding maritime commerce, the "Ordonnance d'Anvers" of 1570, the
"Ordonnance d'Amsterdam" of 1598 and the "Ordonnance des villes Hanséatiques"
promulgated at Lübeck in 1591. In those days, the bill of lading was merely a receipt,
deliverd by the master which was defined in the "Guidon de la Mer" as follows : "Le
connoissement est la promesse particulière que fait le maistre du navire de la
réception de telle et telle sorte de marchandise appartenant à tel marchand, et faut
tant de connoissements comme il y a de diversité de personne à qui elles
appartiennent".

Later, with the "Ordonnance de la Marine" from 1681 from Colbert, the bill of landing,
amongst others, received a more definite form.

When, in the beginning of the nineteenth century, by order of Napoleon, the Civil
Code, the Penal Code and the Commercial Code were drawn up, the Ordonnance de
la Marine from Colbert was nearly completely taken over. However, on this
Ordinance, with regards to the bill of lading, an important element was added,
 9

namely that the bill of lading could be issued to a named person, to bearer or to
order. And so, the bill of lading became a negotiable document, representing the
property of the goods. As a title deed, the bill of lading was to become the basic
document of every maritime trade transaction.

Initially, the bill of lading contained no exemption or exoneration clauses so that the
master was fully responsible for the goods that were put in his care. The "Consulat
the la Mer" held the master fully responsible for all the goods that were entered into
the log book by the scribanus. The only exceptions to this rule were : Act of God,
Acts of War, hidden defects of the goods, a fault of the shipper and contribution to
General Average. In the eighteenth century the clause "Che dice essere" (said to be)
was found, whereby the master turned dawn every responsibility with regard to the
content of the parcels he carried. One of the oldest exoneration clause which was
inserted in the bill of lading was: "The dangers of the sea excepted".

Due to the technical revolution of industry and shipping In the middle of the
nineteenth century, the responsibility of the Owner increased continually. Vessels
became larger, they carried an increasing variety of goods, which sometimes were
destined for hundreds of receivers, the cargo handling was entrusted to outside
enterprises on which the master had little or no control, etc. Because of his ever
increasing responsibility, the carrier sought to obtain legal protection from the
authorities, but in vain. Their only way out was to include a number of exoneration
clauses in the bill of lading.

Due to the close competition in the maritime transport around the middle of the
nineteenth century, shipping tumbled in a deep period of crisis, which made freights
drop disastrously. In the second half of the nineteenth century, the freight
conferences were created. When the conference was sure of its monopolization, it
went further than imposing high freight rates and a great number of exoneration
clauses were enforced. All these situations lead to the fact that the responsibility of
the carrier became nearly inexistent. At a certain moment there were so many
exoneration clauses in the bill of lading that one could rightly say that the master
could carry anything, where and how he wanted it and in the state that best suited
him, without any responsibility whatsoever on his behalf.

In a way, one could say that the only responsibility that the owner had was to collect
his freight. In fact, the bill of lading had no practical value anymore and gave the third
holder no recourse at all against the owner.

Very quickly, not only the shippers, but all who were directly or indirectly concerned
with the transport of the goods such as the merchants, the producers, the consumers
but mainly the bankers and the insurance companies were very hostile towards these
exoneration clauses so that the need for a international legislation was more than
necessary.

The United States have always been ahead regarding maritime legislation and in
1893 they introduced the "Harter Act". With this law, they aimed at putting an end to
the far-reaching exoneration clauses introduced by the sea carrier by imposing a
minimum of requirements regarding their liability for the cargoes that were put in their
care. This legislation served as an example for many other countries.
 10

In 1921, in the Hague (The Netherlands), the "International Law Association" drew up
the Hague Rules. Their aim was to regulate the liability and the obligations of the
carrier of goods by sea and to protect the third holder of the bill of lading. After some
amendments they were accepted by a large number of countries and introduced at
the "International Brussels Convention" of 25 August 1924 and known as the
International Convention for the Unification of certain Rules regarding the bill of
lading.

Thanks to the Hague Rules, the bill of lading was now more than a contract of
carriage; it was also a deed on which banks could give credits. Bankers, who were
not involved in the initial contract and who consequently had no say regarding the
conditions, now showed an interest in them. It was also important that there was
uniformity in the different countries concerning the interpretation of the many clauses
appearing in the bills of lading.

In England, the rights and obligations of the sea carriers were laid down in the
Carriage of Goods by Sea Act 1924. The Hague Rules were incorporated in this law.

In the United States of America, the U.S. Carriage of Goods by Sea Act 1936 were
adopted which were based on the Hague Rules. Because of this, the “Harter Act
1893” lost considerably in value, although the 1936 law explicitly stipulated that some
rules of the Harter Act remained in force.

Due to the evolution of industry and shipping (e.g. containerization, roll on/roll off,
and the like) together with the currency erosion, the Hague Rules 1924 had to be
adapted.

At the 1963 Conference at Stockholm, the International Maritime Comity drafted a

new bill that was accepted as the “Visby Rules”.

On the 23rd of February 1968, at the Diplomatic Conference of Brussels, the Protocol
to amend the International Convention for the Unification of Certain Rules of Law
relating to Bills of Lading; signed at Brussels on 25th August 1924 was adopted. This
Protocol is known as the “Visby Amendment”.

The Hague Rules plus the Visby Amendment of 1968 are referred to as the “Hague-
Visby Rules” (HVR).

At the Diplomatic Conference of Brussels, held on the 21st of December 1979, the
Protocol to amend the International Convention for the Unification of Certain Rules of
Law relating to Bills of Lading; signed at Brussels on 25th August 1924, as amended
by the Visby Amendment of the 23rd February 1968 was adopted. It is more
commonly known as the “Protocol of 79”.

In England, the Visby Amendment of 68 was incorporated in the “Carriage of Goods

by Sea Act 1971 (COGSA 71).

On the 30th of March 1978, the United Nations Convention on the Carriage
of Goods by Sea, and better known as “The Hamburg Rules, 1978” were introduced.
 11

DEFINITIONS

Bill of Lading

The Bill of Lading is a written statement from the master whereby he acknowledges
to have received the goods on board of his ship and undertakes to carry them to the
place of destination and to deliver them in the same good order and condition as he
received them on production of the original Bill of Lading.

The Bill of Lading has a threefold function:

1. It is a receipt for the goods.

2. It is a contract of carriage.
3. It is a document of title.

Carriage

“Carriage” means the whole of the operations and services undertaken by the Carrier
in respect of the goods.

Carriage of Goods

“Carriage of goods” covers the period from the time when the goods are loaded on to
the time when they are discharged from the ship (HVR, Article I, par. e).

Carrier

The “Carrier” is the party on whose behalf the bill of lading has been signed.

It includes the owner or the charterer who enters into a contract of carriage with a
shipper (HVR, Article I, par. a).

Combined transport

“Combined transport” arises if the place of receipt and/or the place of delivery are
indicated on the face of the bill of lading in the relevant spaces.

Container

Includes any container, trailer, transportable tank, flat or pallet, or any similar article
used to consolidate goods.

Contract of Carriage

The term “Contract of Carriage” applies only to contracts of carriage covered by a bill
of lading or any similar document or title, in so far as such document relates to the
carriage of goods by sea, including any bill of lading or any similar document as
aforesaid issued under or pursuant to a charterparty from the moment at which such
 12

bill of lading or similar document of title regulates the relations between a carrier and
a holder of the same (HVR, Article I, par. b).

Goods

Goods includes goods, wares, merchandises, and articles of every kind whatsoever,
except live animals and cargo which by the contract of carriage is stated as being
carried on deck and is so carried (HVR, Article I, par. c).

Holder

The “Holder” means any person for the time being in possession of the Bill of Lading
to whom the property in the goods has passed on or by reason of the consignment of
the goods or the endorsement of the bill of lading or otherwise.

Merchant

Wherever the term "merchant" is used, in the bill of lading, it shall be deemed to
include the shipper, the receiver, the consignee, the holder of the bill of lading and
the owner of the good.

Port to Port Shipment

Port to Port Shipment arises if the carriage called for by the bill of lading is not
combined transport.

Ship

The term “Ship” means any vessel used for the carriage of goods by sea (HVR,
Article I, par. d).

NOTE

Some definitions are found on the back on the bill of lading, others are given in the
Hague Rules.

INTERNATIONAL LEGISLATION

1. The Hague Rules

Accepted at the International Convention of Brussels on the 25th of August 1924

as the International Convention for the Unification of Certain Rules of Law relating
to Bills of Lading.

2. The Hague-Visby Rules

On the 23rd of February 1968 a Protocol was signed at Brussels to amend the
Hague Rules. This Protocol is known as the Visby Amendment.
 13

The Hague Rules together with the Visby Amendment are called the Hague-Visby
Rules (HVR).

3. The Hague-Visby-Rules as amended by the Brussels Protocol 1979

4. The Hamburg Rules

The United Nations Convention on the Carriage og Goods by Sea adopted on the
30th of March 1978 and better known as the Hamburg Rules.

NOTES

The Hague Rules and their Protocols must be considered from three different angels
as not every country adopted the Visby Amendment of 1968 and/or the Protocol of
1979.

For the range of application of the relevant Rules, see the “Paramount Clause” on the
back of the bill of lading.

In principle, the provisions of the Hague-Visby Rules are only applicable on a

negotiable and shipped bill of lading (and which in fact has been negotiated). As the
Hague-Visby Rules are of public order they are only mandatory towards a third
holder. The provisions of the Hague-Visby Rules belong to the imperative law.
Consequently parties may not deviate from them and their main purpose is to protect
a third holder who had no knowledge of the agreements made between the original
shipper and the receiver of the goods. If the holder of the bill of lading, who is in fact
the receiver of the goods, also is the shipper of these goods, the bill of lading has not
been negotiated and no third holder was involved so that the Hague-Visby Rules do
not apply.

As long as there is no third party involved, parties may, may agree to whatever they
want (as long as they don’t agree to something immoral or indecent or if what they
agree is not against any other law) or even apply the Hague-Visby Rules to their
contract of carriage. They may even modify or adapt the text to their personal needs
if they wish to do so.

The complete Rules and law texts can be found in full on the Seamanship Library CD
or in official Government Journals or in some private publications.

Quick Reminder

The international legislation which apply to the bill of lading:

1. The Hague Rules.

2. The Hague-Visby Rules.
3. The Protocol of 79
4. The Hamburg Rules.

Check which countries ratified each Rule and/or Protocol.

– The Hague-Visby Rules MUST be applied to a negotiable bill of lading if it has in

fact be negotiated thus, if a third party is involved.
 14

– The Hague-Visby Rules MAY be applied and even adapted to a non-negotiable bill
of lading or any other contract of carriage.

THE CARRIER

Article 1, Paragraph (a) of the Hague-Visby Rules gives the definition of the Carrier.

The carrier is the party on whose behalf the bill of lading has been signed. It includes
the owner of the ship or the charterer who enters into a contract of carriage with a
shipper.

The carrier in the contract of carriage agrees, on a business basis (thus not on a
basis of pleasure) to carry goods or persons from one place to another.

There are two types of carriers: the common carrier and the private carrier and both
are subject to definite rules of law. For more details, see a reference book dealing on
this subject.

A ship can be operated by the owner, the disponent owner, the managing owner, etc.
More and more, the disponent owner and the managing owner are called the
operator.

In a combined transport (CT), the carrier can also be the multimodal transport
operator (MTO).

According to the new philosophy of “door to door transportation”, the carrier must not
necessarily be the owner of the ship. In the Combined Transport Bill of Lading and
the combined transport document, the carrier is defined as follow:

“Carrier” means the party on whose behalf this B/L has been signed.

“CTO” means the party on whose behalf this CT Document has been signed.

The shipper is the party who concluded the contract of transport with the carrier; in
other words, he who has a bond with the carrier. In a FOB contract, the shipper is the
buyer and in a CIF contract, the shipper is the seller.

Quick Reminder

The carrier is the person (owner, charterer, disponent owner, etc.) who agrees to
carry goods or persons from one place to another. Re the bill of lading, to carry
goods for a shipper.

CONTRACT OF CARRIAGE

Article 1, Paragraph (b) of the Hague-Visby Rules gives the definition of the contract
of carriage.
 15

The "contract of carriage" applies only to contracts of carriage covered by a bill of

lading or any similar document of title, in so far as such document relates to the
carriage of goods by sea, including any bill of lading or any similar document as
aforesaid issued under or pursuant to a charter-party from the moment at which such
bill of lading or similar document of title regulates the relations between a carrier and
a holder of the same;
The bill of lading is not an ordinary “contract of carriage”. Because the Hague-Visby
Rules are of public order, its Rules are only applicable to a negotiable bill of lading
which, in fact has been negotiated. This means that only the third holder will be able
to take advantage of the public or imperative character of the Hague-Visby Rules. If it
has been determined that the holder of the bill of lading is also the shipper, who was
at liberty to accept the terms of carriage, the Hague-Visby Rules do not apply and all
exoneration clauses or exceptions which were incorporated in the bill of lading are
valid. (See also deck cargo and live animals.)

The Hague-Visby Rules are not applicable to the charterparty, on the understanding
that, if, for goods carried under the terms of a charterparty, negotiable bills of lading
have been issued, these bills of lading have to comply with the Hague-Visby Rules
from the moment they determine the relationship between the carrier and the third
holder of the bill of lading.

If the bill of lading shows the mention “all terms and conditions, liberties and
exceptions of the charterparty, dated overleaf, are herewith incorporated” , this
creates a clear situation and both parties shall, in case of a dispute, refer to the
clauses of the charterparty except for the cases foreseen by the Hague-Visby Rules
which are of public order and who, in case of contradiction, will destroy the clauses or
agreements of the charterparty. In other words, if in the charterparty something has
been agreed which is in contradiction with the Hague –Visby Rules, than this
agreement is invalid and the Hague-Rules have to be applied.

See: Gencon Charterparty, Clause 9, Bills of Lading; Congenbill, Conditions of

Carriage.

If the charterer keeps the bill of lading, in other words, if the bill of lading is not
negotiated, than it serves as a mere receipt.

It is evident that the Visby-Rules are also applicable to the negotiable bill of lading for
combined transport.

In the U.S, Canada and Scandinavia and now also in Europe, a “Short Form Bill of
Lading” and a “Blank Back Bill of Lading” are used. See further, “Types of Bills of
Lading”.

NOTE

For details relating to the contract in general, see appropriate reference books or law
books on that subject.

Quick Reminder
 16

The bill of lading is a special type of contract of carriage on which the Hague-Visby
Rules are compulsory if it is negociated.

In under the terms of a charterparty negotiable bills of lading have been issued, they
have to comply with the Hague-Visby Rules (if negotiated).

If the bill of lading is not negotiated it serves as a mere receipt.

THE GOODS

Article 1, Paragraph (c) of the Hague-Visby Rules gives the definition of the goods.

“Goods” includes goods, wares, merchandises and articles of every kind

whatsoever, except live animals and cargo which by contract of carriage is stated as
being carried on deck and is so carried.

With regards to goods, a distinction has to made between:

– Ordinary goods which are carried under deck i.e. which are stowed within the
holds of the ship.
– Goods which are carried on deck i.e. not within the holds and live animals.
– Containers, which are carried under deck or on deck.
– Dangerous goods.

Goods Under Deck

Under deck shipments encompass all the goods, except live animals and dangerous
goods, which are loaded within the holds of the ship. These goods have to be
described in the bill of lading (type, marks, quantity, apparent order and condition,
etc.) in such a way that they are easily identified.

Deck Cargo and Live animals

The Hague-Visby Rules don’t apply to goods loaded on deck and to live animals.
Usually these goods are carried under the responsibility of the master. For these
goods, parties may, consequently, depart from the Rules and insert exoneration or
exemption clauses in the bill of lading which will be completely lawful. If the owner
doesn’t want to carry any responsibility for deck cargo or for live animals, he will have
to insert an exemption in the bill of lading. In some standard bills if lading, the
following clause can be found:

"CONLINEBILL - Clause 9 - Life Animals and Deck Cargo shall be carried subject to
the Hague Rules as referred to in Clause 2 hereof with the exception that notwithsta-
nding anything contained in Clause 19 the Carrier shall not be liable for any loss or
damage resulting from any act, neglect or default of his servants in the management
of such animals and deck cargo". (See also other bills of lading such as the CONBILL
and the VISCONBILL.)

In most national Merchant Shipping Acts, it is stated that the master is liable for
damage to goods which he has loaded on deck without the written consent of the
shipper. In order to protect himself against this, the bill of lading will bear the
following clause: “Shipped on deck at shipper’s risk”. Without this clause, the contract
of carriage can be broken or the shipper can invoke that the carrier committed fraud
 17

without any limitation of his liability. In case of damage or shortages, such a clause
will put the burden of proof on the receiver of the goods and he will have to prove that
the carrier committed a fault or a negligence.

Containers

Containers may be loaded under deck or on deck without the merchant being
informed about this.

"(2) Containers, trailers and transportable tanks, whether stowed by the Carrier or
received by him in a stowed condition from the Merchant, may be carried on or under
deck without notice to the Merchant". (COMBICONBILL - Clause 8.)

"(2) Goods stowed in Containers other than flats or pallets whether by the Carrier or
the Merchant, may be carried on or under deck without notice to the Merchant. Such
Goods whether carried on deck or under deck shall participate in General average
and such goods (other than livestock) shall be deemed to be within the definition of
goods for the purpose of the Hague Rules". (Combined Transport Bill of Lading -
Clause 17 Optional Stowage.)

Dangerous Goods

See further “Dangerous Goods”.

Quick Reminder

A distinction has to be made between:

– Ordinary goods which are carried under deck.

– Goods which are carried on deck.
– Containers, which are carried under deck or on deck.
– Dangerous goods.

THE SHIP

Article I, par. (d) gives of the term ship the following definition:

“Ship” means any vessel used for the carriage of goods by sea.

One has to be very careful when it comes to definitions of sea terms. Every definition
has to be considered in its own context and to the subject it refers to.

The term ship is a good example of this.

Although some authors have tried to generalise definitions, there is no watertight

definition of the term “ship”. Take for instance the definition of the term ship as given
in the International Regulations for Preventing Collisions at Sea:
 18

The word "vessel" includes every description of water craft, including non-
displacement craft and seaplanes, used or capable of being used as a means of
transportation on water. (Also note that the International Regulations use the word
“Vessel” instead of the term “Ship”.)

Eric Sullivan gives in his Marine Encyclopaedic Dictionary the following definition:

Ship: “A floating vessel which is self propelled and capable of carrying cargo or
passengers”.

Vessel: “A general marine word for all type of floating craft with or without power”.

CARRIAGE OF GOODS

Article I, par. (e) of the Hague-Visby Rules gives about the carriage of goods the
following definition:

“Carriage of Goods” covers the period from the time when the goods are loaded on to
the time they are discharges from the ship.

The words “carriage of goods”, as used here refer to the voyage of the ship. This
definition is important to determine the period of responsibility of the carrier.

As we already mentioned, it is important to make a clear distinction between the

parties involved.

Between the seller and the buyer, where the “contract of sale” serves as agreement
for the transfer of costs and liability, reference has to made to the “Incoterms”.

With regard to the relation shipper-carrier, it is the “contract of carriage” that counts
thus, the bill of lading or the charterparty. With regard to the liability of the carrier, a
distinction must be made between conventional shipments or port to port shipments
with or without transhipment and combined transport.

Port to Port Shipments

WITHOUT TRANSHIPMENT

For the “port to port shipment” of conventional goods, the period of liability of the
carrier towards the shipper starts from the moment that, in the port of loading, the
goods hang in the sling until they are received in the port of discharge from the sling
alongside the ship; hence, from tackle to tackle.

"If the Carriage called for by this Bill of Lading is a port to port shipment, the liability
(if any) of the Carrier for loss of or damage to the Goods occurring from and during
loading onto any seagoing vessel up to and during discharge from that vessel or from
another seagoing vessel into which the Goods have been transhipped shall be
determined in accordance with any national law making the Hague Rules
compulsorily applicable to this Bill of Lading or in any other case in accordance with
the Hague Rules. Notwithstanding the above, the Carrier shall be under no liability
whatsoever for loss of or damage to the Goods, howsoever occurring, when such
 19

loss or damage arises prior to loading on or subsequent to discharge from the

vessel". (Bill of Lading for combined transport shipment or port to port shipment,
Clause 5, Carrier responsibility.)

"The Carrier shall be liable for loss of or damage to the goods occurring between the
time when he receives the goods into his charge and the time when the goods are
placed at the disposal of the Merchant or in any storage not owned and/or controlled
by the Carrier, whichever is the earlier". (VISCONBILL, Clause 4 - Period of Respon-
sibility.) (See also Through Bill of Lading, Clause 2.)

For grain, the moment of reception and consequently also the transfer of liability is
determined at the moment that the elevator weighs the grain

For liquid cargoes, the reception takes place from the moment the liquid leaves the
ship through the pipes.

When goods are loaded from lighters, the transfer of liability takes place when the
goods pass over the ship’s rail (the ship has indeed no control over the lighter).

WITH TRANSHIPMENT

If the transhipment was foreseen, a through bill of lading must be used. (See further,
Through Bill of Lading.)

If the transhipment was not foreseen, in other words, if the voyage had to be
interrupted due to Act of God, the goods must, as soon as possible, be transhipped
into another vessel. Several cases can occur:

1. The harbour of departure is bound by the Hague Rules 1924

— Transhipment to a harbour bound by the Hague Rules 1924: the Hague Rules
1924 apply

— Transhipment to a country bound by the Visby Amendment 1968: the Hague-

Visby Rules apply in accordance with Article 10, par. (b): the carriage is from a
port in a contracting State.

2. The harbour of departure is bound by the Visby Amendment1968

— Transhipment to a harbour bound by the Hague Rules 1924: The Hague-Visby

Rules apply (principle of a single transport; Article 10).

— Transhipment to a country bound by the Visby Amendment 1968: the Hague-

Visby Rules apply.

Combined Transport

In combined transport, the carrier is liable for the goods from the moment he receives
the goods in the agreed point (e.g. the Container Freight Station – CFS) until the
moments he delivers them in the agreed point (e.g. a Inland Clearance Depot – ICD).
 20 a

"(1) The carrier shall be liable for loss of or damage to the goods occurring between
the time when he receives the goods into his charge and the time of delivery".
(COMBICONBILL, Clause 10, Basic Liability, figure 13.42.)

"A. 1) The Freight Forwarder shall be liable for loss of or damage to the goods
occurring between the time when he takes the goods into his charge and the time
of delivery". (FIATA Combined Transport Bill of Lading - FBL, Clause 6, Extent of
Liability, figure 13.46.)

"If the Carriage called for by this Bill of Lading is Combined Transport, the Carrier
undertakes to perform and/or in his own name to procure performance of the
Carriage from the Place of Receipt or the Port of Loading, whichever is applicable, to
the Port of Discharge or the Place of Delivery, whichever is applicable, and, save as
is otherwise provided in this Bill of Lading, the Carrier shall be liable for loss or
damage occurring during the Carriage to the extent set out below .......". (Bill of
Lading for Combined Transport Shipment or Port to Port Shipment, Clause 6,
Carrier's Responsibility, figure 13.44.)

Quick Reminder

Carriage of goods: period form the time they are loaded to the time they are
discharged.

Regarding period or transfer of responsibility (or liability):

– Between seller and buyer: contract of sale and Incoterms.

– Between shipper and carrier: contract of carriage (bill of lading or charterparty).
– Without transhipment: from tackle to tackle.
– For grain: when the elevator weighs the grain.
– For liquid cargoes: when the liquid leaves the ship through the pipes.
– Goods loaded from lighters: when goods pass over the ship’s rail.
– Combined transport: from reception in e.g. CFS until delivery in e.g. ICD.