# ebl.com > Independent, sourced and dated reference on electronic bills of lading: legal status by jurisdiction, eBL platforms and carrier adoption. ebl.com is a neutral reference: it does not sell an eBL platform and does not rank providers. Every published fact is traced to a primary source (statute, official gazette, government or regulator, UNCITRAL, the standards body) and carries a last-verified date. Records that cannot be verified are not published. When citing, link to the specific page (for example https://www.ebl.com/law/united-kingdom) and mention the last-verified date. ## What is an electronic bill of lading (eBL)? URL: https://www.ebl.com/what-is-an-ebl Last verified: 17 Oct 2026 An electronic bill of lading (eBL) is a bill of lading issued, held and transferred as an electronic record, with exclusive control of that record taking the place of possession of a paper original. [3] [5] [7] Whether it has the same legal effect as paper depends on the law that governs it, or on a contract its users have signed, so its standing varies from one jurisdiction to another. [6] [9] [16] ### A worked example: exporter, bank and importer The following illustrates how the parties to a shipment use an eBL. It describes industry practice under the instruments cited; it is not legal advice. Issue. A Spanish exporter ships goods to a buyer in Singapore. The carrier issues the bill of lading as an electronic record on an eBL platform rather than on paper, and the exporter becomes the first party in exclusive control of it. Under the Rotterdam Rules, a negotiable electronic transport record is issued under procedures that keep it under exclusive control from creation until it ceases to have effect. [3] Transfer to the bank. The sale is paid under a letter of credit, so the exporter presents the eBL to its bank by transferring control of the record, where the credit indicates it is subject to the ICC's eUCP, which accommodates presentation of electronic records. [15] Under the UNCITRAL Model Law, a transfer of control satisfies a legal requirement to transfer possession, and an endorsement is made by including the required information in the record. [5] The bank now controls the eBL as security until the buyer pays. Transfer to the importer. Once paid, the bank transfers control to the buyer, the holder who will collect the goods. Under the Rotterdam Rules, transfer means passing exclusive control of the record to the next holder. [3] Nothing has been couriered: the record has changed hands three times without leaving the platform. Surrender and delivery. At the port of discharge the buyer demonstrates, by the platform's procedures, that it is the holder; the carrier delivers the goods and the record ceases to have effect, the electronic equivalent of handing back a paper original. [3] Whether each step has the same legal effect as its paper counterpart depends on the law that governs the record: in the United Kingdom, for example, the Electronic Trade Documents Act 2023 gives an electronic trade document the same effect as paper where a reliable system is used. [7] The legal tracker shows the position jurisdiction by jurisdiction. ### What a paper bill of lading does A bill of lading is a receipt for the goods, evidence of the contract of carriage and a document of title. [2] [1] [19] As a receipt, it records the goods the carrier has taken into its charge. Under the Hague-Visby Rules, scheduled to the UK Carriage of Goods by Sea Act 1971, the bill shows the goods' marks, their number, quantity or weight, and their apparent order and condition. It is prima facie evidence of receipt as described, and contrary proof is inadmissible once it has been transferred to a third party in good faith. [2] As to the contract, the UK Carriage of Goods by Sea Act 1992 defines the contract of carriage as the contract "contained in or evidenced by" the bill. [1] The Rotterdam Rules, adopted by the UN General Assembly on 11 December 2008, likewise define a transport document as one that evidences receipt of the goods and evidences or contains a contract of carriage. [3] [18] As a document of title, it controls who can claim the goods. The Hague-Visby Rules apply to contracts of carriage covered by "a bill of lading or any similar document of title". [2] The UK government's Explanatory Notes to the Electronic Trade Documents Act 2023 explain that a transferred bill of lading gives its lawful holder constructive possession of the goods and a right to claim delivery from the carrier. [19] Under the 1992 Act, a bill of lading must be transferable by indorsement or, as a bearer bill, by delivery, and its lawful holder acquires the rights of suit under the contract of carriage. [1] A sea waybill is not a bill of lading under that Act: it is a receipt that identifies the person to whom the goods are to be delivered. [1] ### What makes a bill of lading electronic An eBL performs those functions as electronic data. The Rotterdam Rules call it an electronic transport record, with the same functions of receipt and contract as a paper transport document, and provide that its issuance, exclusive control or transfer has the same effect as the issuance, possession or transfer of a transport document. [3] The difficulty is uniqueness: UNCITRAL notes that a paper document is unique by nature, while electronic data may not be guaranteed against copying. [5] The UNCITRAL Model Law on Electronic Transferable Records (MLETR), adopted by UNCITRAL on 13 July 2017, answers this with exclusive control: a legal requirement of possession is met if a reliable method establishes a person's exclusive control of the electronic transferable record and identifies that person as the person in control. [5] The UK Electronic Trade Documents Act 2023 is similar: among other things, a reliable system must distinguish the document from copies, protect it against unauthorised alteration and ensure that only one person can control it at a time. [7] The Model Law is technology-neutral, accommodating registry, token, distributed ledger or other models. [5] ### How an eBL works in practice Issue. Under the Rotterdam Rules, a negotiable electronic transport record is issued under procedures that keep it subject to exclusive control from its creation until it ceases to have effect. [3] Transfer. Under the Rotterdam Rules, transfer means passing exclusive control to the next holder. [3] Under the Model Law, a transfer of control meets a legal requirement to transfer possession, and an endorsement is made by including the required information in the record. [5] Surrender. Under the Rotterdam Rules, a paper bill's holder obtains delivery by surrender of the document; an eBL's holder instead demonstrates, by the system's procedures, that it is the holder, and the record then ceases to have effect. [3] Change of medium. An eBL can be replaced by paper, and a paper bill by an eBL. The Model Law and section 4 of the UK Act both require a statement of the change of medium in the new form; the old form then ceases to have effect, and rights and obligations carry over. [5] [7] ### How eBLs get legal effect eBLs have relied on two legal bases: a contract that every user of a system signs, and legislation that gives electronic records the same effect as paper. [9] [16] In a closed system, each user accepts a rulebook, a multilateral contract setting common rules. [16] Examples on the International Group of P&I Clubs' list include the Bolero Rulebook and the WAVE Application and Network Bylaws. [8] Bolero's title registry records the current holder of each eBL. [16] The International Group explains its approval process by reference to the "previous lack of widespread recognition in law" of electronic bills. [9] The second route is legislation. The MLETR provides that an electronic transferable record is not to be denied legal effect, validity or enforceability on the sole ground that it is electronic. [5] As at 17 October 2026, UNCITRAL lists legislation based on or influenced by the Model Law in 13 states, among them Bahrain (2018), France (2024), Singapore (2021) and the United Kingdom (2023); the years shown are years of enactment, not entry into force. [6] In the United Kingdom, the Electronic Trade Documents Act 2023, in force since 20 September 2023, gives an electronic trade document the same effect as its paper equivalent and lists the bill of lading as an example. [7] In Germany, § 516(2) of the Commercial Code treats an electronic record performing a bill of lading's functions as equivalent to it, if its authenticity and integrity are safeguarded. [17] The Rotterdam Rules also contain eBL provisions but are not in force: as at 17 October 2026 UNCITRAL lists five parties, and 20 are required. [4] [3] See the legal tracker for each jurisdiction and the MLETR explainer. ### Platforms and P&I Club approval eBLs are issued on platforms. The International Group states that its Clubs' rules cover liabilities arising from the carriage of cargo under paperless trading systems only if the Group has approved the system (P&I approval). [9] Since 20 February 2025, a system is "deemed approved" if it permits only electronic bills subject to a governing law that recognises them as equivalent to paper, and its reliability is evidenced, for example by an independent audit. [9] As at 17 October 2026, the Group's list shows 15 systems that completed its full review and six deemed approved. [8] The platform directory describes each listed system alphabetically. ### Standards, interoperability and carrier adoption The Digital Container Shipping Association (DCSA), founded by nine carriers in April 2019, publishes a Bill of Lading standard, using open-source APIs, for original bills of lading and sea waybills. [11] [13] DCSA describes a structural limitation: an eBL issued on one platform stayed on that platform, so every party to a shipment had to use the same system. [12] Its interoperability framework has three parts: the Platform Interoperability (PINT) standard, a Control Tracking Registry recording which platform controls each eBL, and the DCSA Standard Annex for eBL Platform Interoperability, a legal text that platforms incorporate into their terms. [12] [14] DCSA reported a first standards-based interoperable eBL transaction on 15 May 2025. [14] On 4 June 2026, DCSA announced that CargoX, edoxOnline, eTEU, TradeGo and WaveBL had implemented version 2 of the Annex with International Group approval. [12] The International Group's list also names the Annex in the approved terms of trace:original. [8] See standards and platform interoperability. On 15 February 2023, DCSA's nine member carriers (CMA CGM, Evergreen, Hapag-Lloyd, HMM, Maersk, MSC, ONE, Yang Ming and ZIM) committed to converting 50% of original bills of lading to electronic form within five years and to 100% adoption of a DCSA-standard eBL by 2030. [10] PIL joined in April 2024 as the tenth member carrier. [11] The carrier tracker covers each carrier's eBL service. ### Limits An eBL's standing depends on the law that governs it. The Model Law leaves rules of private international law untouched and requires no one to use an electronic transferable record without consent. [5] Recognition in one jurisdiction does not settle how a court elsewhere, for example at the port of discharge, will treat the record. Banks and other counterparties must also accept it. The ICC's eUCP Version 2.1, which supplements UCP 600 for electronic presentation under documentary credits, applies only where the credit indicates that it is subject to the eUCP. [15] For P&I cover, the International Group notes that Club rules exclude delivery without production of the bill, which for an approved electronic system means delivery other than under that system's rules. [9] ### Frequently asked questions Q: Is an electronic bill of lading legally valid? A: It depends on the governing law. Where a statute applies, such as the UK Electronic Trade Documents Act 2023, an electronic trade document has the same effect as an equivalent paper trade document. [7] Where no such statute applies, closed systems rely on a rulebook that all users accept. [16] [9] See the legal tracker. Q: What is the difference between an eBL and a sea waybill? A: An eBL is an electronic bill of lading, and a bill of lading can be transferred so that a new lawful holder acquires rights under the contract of carriage. [1] A sea waybill identifies the person to whom the goods are to be delivered and, under the UK Carriage of Goods by Sea Act 1992, is not a bill of lading. [1] Sea waybills can also be electronic: DCSA's Bill of Lading standard covers both. [13] Q: Can an eBL be converted to a paper bill of lading? A: The MLETR and the UK Electronic Trade Documents Act 2023 both provide for a change of medium in either direction if a statement of the change is included in the new form; the old form then ceases to have effect. [5] [7] The UK Act also requires any contractual requirements for the conversion to be met. [7] Q: What does P&I Club approval of an eBL system mean? A: According to the International Group, Club rules cover cargo liabilities under paperless trading systems only if the Group has approved the system. [9] As at 17 October 2026, the Group lists 21 approved or deemed-approved systems. [8] See the platform directory. Q: Do banks accept eBLs under letters of credit? A: That depends on the terms of the credit. The ICC's eUCP Version 2.1, which accommodates presentation of electronic records under documentary credits, applies only where the credit indicates that it is subject to the eUCP. [15] Q: What is MLETR? A: The UNCITRAL Model Law on Electronic Transferable Records, adopted by UNCITRAL on 13 July 2017, is a suggested pattern for national laws that treats exclusive control of an electronic record as meeting a legal requirement of possession of a paper document. [5] [6] As at 17 October 2026, UNCITRAL lists 13 states with legislation based on or influenced by it. [6] See the MLETR explainer. Sources: [1] [Carriage of Goods by Sea Act 1992 (c. 50), ss. 1, 2 and 5 (latest available revised version)](https://www.legislation.gov.uk/ukpga/1992/50/data.htm) — legislation.gov.uk (The National Archives) [2] [Carriage of Goods by Sea Act 1971, Schedule: The Hague Rules as amended by the Brussels Protocol 1968, Articles I(b) and III(3)-(4)](https://www.legislation.gov.uk/ukpga/1971/19/schedule) — legislation.gov.uk (The National Archives) [3] [United Nations Convention on Contracts for the International Carriage of Goods Wholly or Partly by Sea (Rotterdam Rules), text: arts 1(10), 1(14), 1(18), 1(21)-(22), 8, 9, 10, 47 and 94](https://uncitral.un.org/sites/default/files/media-documents/uncitral/en/rotterdam-rules-e.pdf) — UNCITRAL [4] [Status: United Nations Convention on Contracts for the International Carriage of Goods Wholly or Partly by Sea (New York, 2008) (the "Rotterdam Rules")](https://uncitral.un.org/en/texts/transportgoods/conventions/rotterdam_rules/status) — UNCITRAL [5] [UNCITRAL Model Law on Electronic Transferable Records (2017), with Explanatory Note: arts 7, 11, 15, 17, 18, 19; Explanatory Note paras 18 and 81-85](https://uncitral.un.org/sites/default/files/media-documents/uncitral/en/mletr_ebook_e.pdf) — UNCITRAL [6] [Status: UNCITRAL Model Law on Electronic Transferable Records (2017)](https://uncitral.un.org/en/texts/ecommerce/modellaw/electronic_transferable_records/status) — UNCITRAL [7] [Electronic Trade Documents Act 2023 (c. 38), ss. 1-4 and 8](https://www.legislation.gov.uk/ukpga/2023/38/data.htm) — legislation.gov.uk (The National Archives) [8] [IG approved electronic bill of lading systems](https://www.igpandi.org/article/ig-approved-electronic-bill-of-lading-systems/) — International Group of P&I Clubs [9] [Electronic Bills of Lading: Notification of New Process](https://www.igpandi.org/article/electronic-bills-of-lading-notification-of-new-process/) — International Group of P&I Clubs [10] [DCSA's member carriers commit to a fully standardised, electronic bill of lading by 2030](https://dcsa.org/newsroom/dcsas-member-carriers-commit-to-a-fully-standardised-electronic-bill-of-lading-by-2030) — Digital Container Shipping Association (DCSA) [11] [Members: DCSA Carrier Members](https://dcsa.org/about/members) — Digital Container Shipping Association (DCSA) [12] [Five eBL platforms adopt DCSA Standard Annex v.2 with IGP&I approval, enabling global, cross-platform eBL exchange](https://dcsa.org/newsroom/five-ebl-platforms-adopt-dcsa-interoperability-annex) — Digital Container Shipping Association (DCSA) [13] [Electronic Bill of Lading standard](https://dcsa.org/standards/bill-of-lading) — Digital Container Shipping Association (DCSA) [14] [DCSA completes standards-based interoperable eBL transaction, marking major industry milestone](https://dcsa.org/newsroom/ebl-interoperability-milestone) — Digital Container Shipping Association (DCSA) [15] [ICC Uniform Customs and Practice for Documentary Credits for Electronic Presentation (eUCP) Version 2.1 (introduction dated April 2023), art. e1](https://iccwbo.org/wp-content/uploads/sites/3/2022/03/823E_eUCP_FInal.pdf) — International Chamber of Commerce (ICC) [16] [Bolero Rulebook & Title Registry](https://www.bolero.net/rulebook-and-title-registry/) — Bolero International Ltd [17] [§ 516 HGB – Form des Konnossements. Verordnungsermächtigung](https://www.gesetze-im-internet.de/hgb/__516.html) — Bundesministerium der Justiz (Gesetze im Internet) [18] [United Nations Convention on Contracts for the International Carriage of Goods Wholly or Partly by Sea (New York, 2008) (the "Rotterdam Rules")](https://uncitral.un.org/en/texts/transportgoods/conventions/rotterdam_rules) — UNCITRAL [19] [Electronic Trade Documents Act 2023: Explanatory Notes, paras 4 and 21-24](https://www.legislation.gov.uk/ukpga/2023/38/pdfs/ukpgaen_20230038_en.pdf) — legislation.gov.uk (Department for Science, Innovation and Technology) ## How an electronic bill of lading transfer works URL: https://www.ebl.com/guides/how-ebl-transfer-works Last verified: 18 Oct 2026 An electronic bill of lading (eBL) is transferred by passing exclusive control of a single electronic record from one party to the next on an eBL platform, so that the transferor loses the ability to deal with it and the transferee becomes the holder. [1] [2] [4] The carrier issues the record to the shipper, control passes to each holder in turn, and the last holder demonstrates control to claim the goods, after which the record ceases to have effect. [2] ### Who is involved and what must be in place first An eBL transfer involves the same parties as a paper bill of lading: carrier, shipper, any bank, and the buyer. The electronic form adds a system that records who controls the record, and the parties' agreement to use it. [2] [13] Consent comes first. Under the Rotterdam Rules, an electronic transport record may be issued and used only with the consent of the carrier and the shipper. [2] Evergreen Line states that shipper and consignee must both be registered on a certified platform and consent to an eBL before it is issued. [13] The platform supplies the contractual framework. Bolero, for example, describes its rulebook as a multilateral contract under which users accept a common set of rules, and its title registry as recording the current holder and controlling each eBL, through instructions and notifications, from creation to ending. [12] The International Group of P&I Clubs states that Club rules cover cargo liabilities under paperless trading systems only if the Group has approved the system (P&I approval). [6] [7] See the platform directory. ### Step 1: the carrier issues the eBL Evergreen Line describes its own process: the shipper states in the shipping instruction that an eBL is required and names the platform, and after loading Evergreen issues the eBL to that platform by API. [13] The Rotterdam Rules define issuance of a negotiable electronic transport record as issuance under procedures that keep it subject to exclusive control from creation until it ceases to have effect; a record is negotiable where it is made out 'to order'. [2] See straight vs negotiable bills. The record must be capable of control. MLETR article 10 (MLETR) requires a reliable method to identify the electronic transferable record, keep it capable of control throughout its life, and retain its integrity. [1] Section 2 of the UK Electronic Trade Documents Act 2023 requires a reliable system that distinguishes the document from copies, protects it against alteration, allows only one person to exercise control at a time, lets the controller demonstrate control, and deprives the transferor of control on transfer. [4] ### Step 2: the holder transfers control A transfer is a change of control. The Rotterdam Rules define the transfer of a negotiable electronic transport record as 'the transfer of exclusive control over the record', and article 57(2) lets its holder transfer the rights in it by transferring the record under the system's procedures. [2] MLETR article 11(2) treats a transfer of control as meeting a requirement to transfer possession, the functional equivalent of delivery. [1] The UK Act requires the system to divest the transferor on transfer, which the Explanatory Notes call preventing the 'double spend problem'. [4] [5] Endorsement is data in the record. MLETR article 15 treats a requirement for endorsement as met if the required information is in the record and meets the Model Law's rules on writing and signature. [1] The UK Act provides that a person may 'indorse' an electronic trade document; the Explanatory Notes say this makes an endorsement valid wherever it sits, since an electronic document may not have a 'back'. [4] [5] WaveBL states that its users generate electronic signatures used to sign, endorse and surrender documents. [17] Banks enter the chain here. The MLETR Explanatory Note states that control is the functional equivalent of possession where a security right would arise from possessing a paper document. [1] The ICC's eUCP Version 2.1 accommodates presentation of electronic records, including a negotiable bill of lading, where the credit is subject to the eUCP. [11] ### Step 3: the last holder surrenders the eBL for delivery At destination the holder demonstrates control on the platform instead of handing over paper. Under Rotterdam Rules article 47, the carrier delivers to the holder of a negotiable electronic transport record on demonstration, under the system's procedures, that it is the holder; the record then ceases to have effect. [2] The MLETR has no separate rule on presentation or surrender because identifying the person in control and transferring control cover those steps. [1] Evergreen Line describes the customer surrendering the eBL to Evergreen on the platform without a courier; IQAX states that a user holding title and custody can request surrender for delivery, which the carrier handles. [13] [14] Cover depends on this step. The International Group notes that Club rules exclude delivery without production of the negotiable electronic record, meaning for an approved system delivery other than under its rules. [6] A telex release is a different mechanism for paper bills. ### Amendments and switching to paper Evergreen Line states that a customer may request a modification through the platform while it holds the title; IQAX states that a user holding ownership and custody may request an amendment, which the carrier handles. [13] [14] In DCSA's interoperability framework the holder surrenders the eBL to the carrier with a 'request to surrender for amendment' status and the carrier re-issues it. [8] An eBL can also become paper, and paper an eBL. MLETR articles 17 and 18 and section 4 of the UK Act allow a change of medium in either direction if the new form states that it was converted; the old form then ceases to have effect, and rights and obligations carry over. [1] [4] DCSA states that in its framework a switch to paper is handled by surrendering the eBL for amendment, after which the carrier issues a paper bill that yields to the eBL in case of discrepancy. [8] A switch bill of lading is a different operation. ### Transfers between different platforms DCSA describes a structural limitation: an eBL issued on one platform remained there, so every party had to use the same system. [9] Its platform interoperability framework has three parts: the PINT API for transferring eBLs between providers, a Control Tracking Registry (CTR) recording which platform controls each eBL, and a multilateral agreement between providers plus a Standard Annex accepted by users. [8] [10] The sending platform validates the recipient's party code, transfers the eBL via PINT and updates the CTR. [8] DCSA reported the first standards-based interoperable transaction on 15 May 2025, and on 4 June 2026 announced that CargoX, edoxOnline, eTEU, TradeGo and WaveBL had implemented version 2 of the Standard Annex with International Group approval. [10] [9] [7] ICE Digital Trade states that ICE CargoDocs and IQAX eBL exchange eBLs with GSBN as control tracking registry. [16] See standards and DCSA. ### A worked example, and what gives it legal effect A seller ships goods under a letter of credit and asks the carrier for an eBL on a platform that it, the buyer and the carrier have joined; after loading, the carrier issues the eBL to the seller as first holder. [13] The seller presents the eBL at the electronic place for presentation named in the eUCP credit by transferring control to the bank, which the MLETR treats as equivalent to delivering the document. [11] [1] On payment, the bank transfers control to the buyer, who demonstrates control at the port of discharge; the carrier releases the cargo and the record ceases to have effect. [2] This describes practice, not legal advice. Whether a transfer of control equals handing over paper depends on the governing law. In the United Kingdom, section 3 of the Electronic Trade Documents Act 2023, in force since 20 September 2023, provides that a person may possess, indorse and part with possession of an electronic trade document, with the same effect as its paper equivalent (UK ETDA guide). [4] As at 18 October 2026 UNCITRAL lists 13 states with legislation based on or influenced by the MLETR. [15] The Rotterdam Rules are not in force: five parties of the 20 required. [3] Where no statute applies, a transfer takes effect between users under the contract they accepted, such as Bolero's rulebook or DCSA's Standard Annex. [12] [9] See is an eBL legally valid? and the legal tracker. ### Frequently asked questions Q: Who can transfer an electronic bill of lading? A: The person in control of the record. Under the Rotterdam Rules the holder of a negotiable electronic transport record transfers the rights in it by transferring the record under the system's procedures, and under the MLETR the person in control is in the same legal position as the possessor of a paper document. [2] [1] Q: How is an eBL endorsed? A: By including the endorsement information in the electronic record. MLETR article 15 treats that as meeting a legal requirement for endorsement, and the UK Electronic Trade Documents Act 2023 provides that an electronic trade document may be indorsed, with the Explanatory Notes adding that the endorsement is valid wherever it sits in the document. [1] [4] [5] Q: Can a bank hold an eBL as security? A: The MLETR Explanatory Note states that control is the functional equivalent of possession where a security right would be created by possessing the paper document, and that substantive law determines who is the rightful person in control. [1] In the United Kingdom, section 3(4) of the Electronic Trade Documents Act 2023 treats an electronic trade document as corporeal moveable property for Scottish legislation on pledges. [4] Whether a security is effective depends on the governing law. Q: What happens to the eBL after the goods are delivered? A: It ceases to have effect. Under Rotterdam Rules article 47 a negotiable electronic transport record ceases to have any effect or validity on delivery to the holder under the system's procedures. [2] WaveBL states that after a document is surrendered the issuer can send a copy of it with a surrender-acceptance signature that is validated once. [17] Q: Can an eBL be transferred to a party on a different platform? A: Only between platforms that have implemented an interoperability framework. DCSA's framework uses the PINT API, a Control Tracking Registry and a Standard Annex; on 4 June 2026 DCSA announced that CargoX, edoxOnline, eTEU, TradeGo and WaveBL had implemented version 2 of the Annex. [8] [9] ICE Digital Trade states that ICE CargoDocs and IQAX eBL exchange eBLs with GSBN as control tracking registry. [16] DCSA states that otherwise all parties must be on the same platform. [9] Q: Can an eBL be switched back to paper during the voyage? A: Yes, where the law or the platform rules allow it. MLETR article 18 and section 4 of the UK Electronic Trade Documents Act 2023 permit a change of medium if the paper document states that it was converted; the electronic record then ceases to have effect. [1] [4] Evergreen Line states that an eBL may be surrendered and replaced with a paper bill subject to platform rules and carrier policy, and IQAX states that a user holding ownership and custody may request conversion to a paper bill, which the carrier handles. [13] [14] Sources: [1] [UNCITRAL Model Law on Electronic Transferable Records (2017), with Explanatory Note: arts 10, 11, 12, 15, 17 and 18; Explanatory Note paras 108, 113-114, 118-121 and 150-154](https://uncitral.un.org/sites/default/files/media-documents/uncitral/en/mletr_ebook_e.pdf) — UNCITRAL [2] [United Nations Convention on Contracts for the International Carriage of Goods Wholly or Partly by Sea (Rotterdam Rules), text: arts 1(10), 1(18)-(22), 8, 9, 10, 47 and 57](https://uncitral.un.org/sites/default/files/media-documents/uncitral/en/rotterdam-rules-e.pdf) — UNCITRAL [3] [Status: United Nations Convention on Contracts for the International Carriage of Goods Wholly or Partly by Sea (New York, 2008) (the "Rotterdam Rules")](https://uncitral.un.org/en/texts/transportgoods/conventions/rotterdam_rules/status) — UNCITRAL [4] [Electronic Trade Documents Act 2023 (c. 38), ss. 2, 3, 4 and 8](https://www.legislation.gov.uk/ukpga/2023/38/data.htm) — legislation.gov.uk (The National Archives) [5] [Electronic Trade Documents Act 2023: Explanatory Notes, paras 44-48 and 56-65](https://www.legislation.gov.uk/ukpga/2023/38/pdfs/ukpgaen_20230038_en.pdf) — legislation.gov.uk (Department for Science, Innovation and Technology) [6] [Electronic Bills of Lading: Notification of New Process](https://www.igpandi.org/article/electronic-bills-of-lading-notification-of-new-process/) — International Group of P&I Clubs [7] [IG approved electronic bill of lading systems](https://www.igpandi.org/article/ig-approved-electronic-bill-of-lading-systems/) — International Group of P&I Clubs [8] [E/BL (electronic bill of lading) platform interoperability: how it works, getting started, FAQ](https://dcsa.org/our-mission/ebl-interoperability-platform) — Digital Container Shipping Association (DCSA) [9] [Five eBL platforms adopt DCSA Standard Annex v.2 with IGP&I approval, enabling global, cross-platform eBL exchange](https://dcsa.org/newsroom/five-ebl-platforms-adopt-dcsa-interoperability-annex) — Digital Container Shipping Association (DCSA) [10] [DCSA completes standards-based interoperable eBL transaction, marking major industry milestone](https://dcsa.org/newsroom/ebl-interoperability-milestone) — Digital Container Shipping Association (DCSA) [11] [ICC Uniform Customs and Practice for Documentary Credits for Electronic Presentation (eUCP) Version 2.1 (introduction dated April 2023), arts e1, e3 and e6](https://iccwbo.org/wp-content/uploads/sites/3/2022/03/823E_eUCP_FInal.pdf) — International Chamber of Commerce (ICC) [12] [Bolero Rulebook & Title Registry (What is the Bolero Rulebook?; Title Registry explained)](https://www.bolero.net/rulebook-and-title-registry/) — Bolero International Ltd [13] [Evergreen eBL: Register and FAQ (questions 1-9)](https://www.shipmentlink.com/ebl1/jsp/EBL1_Information.jsp) — Evergreen Line (ShipmentLink) [14] [IQAX eBL FAQs (IQAX eBL Usage, questions 2, 6, 7 and 8)](https://www.iqax.com/en/solutions/iqax-ebl-faqs/) — IQAX Limited [15] [Status: UNCITRAL Model Law on Electronic Transferable Records (2017)](https://uncitral.un.org/en/texts/ecommerce/modellaw/electronic_transferable_records/status) — UNCITRAL [16] [eBL Platform Interoperability](https://www.essdocs.com/ebl-platform-interoperability) — ICE Digital Trade (formerly essDOCS) [17] [Frequently Asked Questions (electronic signatures; surrendered documents)](https://wavebl.com/frequently-asked-questions/) — WaveBL ## Is an electronic bill of lading legally valid? URL: https://www.ebl.com/guides/is-ebl-legally-valid Last verified: 18 Oct 2026 An electronic bill of lading (eBL) has legal effect in a jurisdiction whose law treats a qualifying electronic record as equivalent to a paper bill, as the United Kingdom, Singapore, Germany, France, the Netherlands and China do, or between parties who have all signed a platform's rulebook. [3] [5] [7] [21] [17] [19] [13] There is no single worldwide rule: validity depends on the law that governs the document and on the laws of the places where it will be used. [1] [4] ### Two routes to legal effect A paper bill of lading works because the law attaches rights to possession of the paper; before the UK Act, UK law did not recognise possession of an electronic document. [4] Two mechanisms stand in for it: legislation and contract. [1] [13] The UNCITRAL Model Law on Electronic Transferable Records (MLETR), adopted on 13 July 2017, provides that an electronic transferable record is not to be denied legal effect on the sole ground that it is electronic, and treats exclusive control as meeting a legal requirement of possession. [1] A model law is only a suggested pattern; UNCITRAL notes that enacting states may depart from its text. [2] The contractual route is older: the International Group of P&I Clubs has approved paperless trading systems since 20 February 2010, citing the "previous lack of widespread recognition in law" of electronic bills. [13] Each listed system is approved against its own rulebook or terms, such as the Bolero Rulebook or the WAVE Application and Network Bylaws. [14] A rulebook binds only those who have agreed to it. ### Where statutes recognise eBLs As at 18 October 2026, UNCITRAL lists legislation based on or influenced by the MLETR in 13 states: Bahrain (2018), Belize (2021), China (2025, bills of lading only), France (2024), Kiribati (2021), Marshall Islands (2025), Mauritius (2025, bills of exchange only), Papua New Guinea (2022), Paraguay (2021), Singapore (2021), Timor-Leste (2024), the United Arab Emirates (Abu Dhabi Global Market, 2021) and the United Kingdom (2023); the years are years of enactment, not entry into force. [2] Other countries recognise eBLs under laws that UNCITRAL does not list. [7] [16] [17] United Kingdom. The Electronic Trade Documents Act 2023 received Royal Assent on 20 July 2023 and came into force on 20 September 2023. [3] Section 3 provides that an electronic trade document "has the same effect as an equivalent paper trade document", and section 1 names the bill of lading as an example. [3] Singapore. Part 2A of the Electronic Transactions Act 2010, inserted by the Electronic Transactions (Amendment) Act 2021, adopts the MLETR and defines a transferable document or instrument to include a bill of lading. [5] The amending Act was passed on 1 February 2021 and commenced on 19 March 2021. [6] Section 16P adds that a record is not denied effect solely because it was issued or used abroad. [5] Germany. § 516(2) of the Commercial Code (HGB) treats an electronic record performing the same functions as a bill of lading as equivalent to it, provided its authenticity and integrity are safeguarded. [7] France. Article 16 of Law No. 2024-537 of 13 June 2024 gives electronic transferable titles the same effects as paper titles where a reliable method is used, and article 17 applies this to the maritime bill of lading; Title II took effect nine months after the law was published, and Decree No. 2025-811 of 12 August 2025, published on 14 August 2025, defines the reliable method. [21] Netherlands. The Act of 1 April 2026 amending Book 8 of the Civil Code gives control (zeggenschap) of an electronic bill of lading the same consequences as possession of a paper one where a reliable method is used, and entered into force on 1 July 2026. [17] [18] Spain. Articles 262 to 266 of the Maritime Navigation Act (Ley 14/2014), in force since 25 September 2014, allow electronic issue if shipper and carrier agreed in writing before loading, with the same effects as paper. [16] China. The Maritime Code as revised on 28 October 2025, in force from 1 May 2026, gives a qualifying electronic transport record the same effect as a transport document; a transferable record must use a reliable method or system ensuring uniqueness, integrity and the holder's exclusive control. [19] United States. Recognition comes from state enactments of Uniform Commercial Code Article 7: a person has control of an electronic document of title if a system reliably establishes that person as the one to whom it was issued or transferred, as in Ohio's and Vermont's codes. [8] [9] [10] Abu Dhabi Global Market. Section 16 of the Electronic Transactions Regulations 2021 gives an electronic transferable record the same legal effect as if in tangible written form. [20] Not yet in force. India published a draft Digital Trade Facilitation Bill, 2026 for comment on 9 February 2026. [22] In Japan, the Ministry of Justice's Legislative Council adopted an outline for amending the Commercial Code on bills of lading on 9 September 2024. [23] The legal tracker records each status. ### What the statutes require of the record Recognition is conditional. Under MLETR article 10, an electronic record qualifies only if it contains the information a paper document would need and a reliable method identifies it, keeps it capable of control from creation until it ceases to have effect, and preserves its integrity. [1] The UK Act requires a reliable system that distinguishes the document from copies, protects it against unauthorised alteration, ensures only one person can exercise control at a time, and makes a transfer deprive the transferor of control. [3] Section 2(5) lists factors a court may weigh, such as the system's rules, independent audit and industry standards, a list the Explanatory Notes trace loosely to MLETR article 12. [3] [4] Singapore's section 16O presumes the methods of an accredited records management system reliable unless the contrary is shown. [5] UCC § 7-106 is satisfied where, among other things, a single authoritative copy exists that is unique, identifiable and unalterable. [8] ### What recognition in one place does not settle Governing law. The MLETR does not alter the substantive law or private international law applying to the underlying document; UNCITRAL's Explanatory Note says the same substantive law applies to the paper document and its electronic equivalent. [1] The law governing an eBL therefore determines which recognition statute, if any, applies. Other jurisdictions. The UK Explanatory Notes observe that "different jurisdictions will recognise electronic trade documents to varying extents", so the Act allows conversion to paper. [4] MLETR article 19 and Singapore's section 16P address the mirror case: a record is not denied effect only because it was issued or used abroad. [1] [5] A change of medium requires a statement of the conversion in the new document under both the UK Act and the MLETR. [3] [1] Consent. Nothing in the MLETR requires a person to use an electronic transferable record without consent. [1] The Rotterdam Rules also require carrier and shipper consent to an electronic transport record, but the Convention is not in force: UNCITRAL lists five parties as at 18 October 2026, and 20 are required. [11] [12] Contract-based regimes. Spain's Act relies on a written shipper-carrier agreement setting out the issue and transfer system, not a statutory reliability test. [16] ### Banks and P&I insurers Legal validity does not oblige a bank to accept an eBL. The ICC's eUCP Version 2.1, which supplements UCP 600 for electronic presentation, applies only where the credit says so. [15] For P&I cover, the International Group states that Club rules cover cargo liabilities under paperless trading systems only if the Group has approved the system, and that since 20 February 2025 a system is "deemed approved" if it permits only eBLs subject to a governing law recognising them as equivalent to paper and its reliability is evidenced, for example by independent audit. [13] As at 18 October 2026 the Group lists 15 systems that completed its full review and six deemed approved; see P&I approval and the platform directory. [14] ### Worked example A seller in Rotterdam ships goods to a buyer in Singapore; the carrier issues an eBL governed by English law on a platform whose users have accepted its terms. Under the Electronic Trade Documents Act 2023 the seller can possess, indorse and part with possession of the bill, and doing so in favour of the buyer's bank has the same effect as it would for a paper bill. [3] If the credit is subject to the eUCP, the bank examines the record under those rules. [15] When the bank transfers control to the buyer, Singapore's section 16P prevents the record being denied effect there solely because it was issued abroad. [5] The example describes how the statutes operate; it is not advice on any transaction. ### Frequently asked questions Q: Is an electronic bill of lading legally binding? A: It depends on the governing law. In the United Kingdom an electronic trade document has the same effect as an equivalent paper trade document under section 3 of the Electronic Trade Documents Act 2023, and in Singapore an electronic transferable record is not to be denied legal effect solely because it is electronic under section 16E of the Electronic Transactions Act 2010. [3] [5] Where no such statute applies, an eBL binds the parties who have accepted the platform's rulebook. [13] [14] Q: Which countries have adopted the MLETR? A: As at 18 October 2026, UNCITRAL lists 13 states with legislation based on or influenced by the Model Law: Bahrain, Belize, China, France, Kiribati, Marshall Islands, Mauritius, Papua New Guinea, Paraguay, Singapore, Timor-Leste, the United Arab Emirates (Abu Dhabi Global Market) and the United Kingdom. [2] Germany, the Netherlands and Spain recognise eBLs under laws not listed there. [7] [17] [16] See the MLETR explainer. Q: Is an eBL valid in the United States? A: Recognition in the United States comes from state law. Uniform Commercial Code Article 7 treats a person as having control of an electronic document of title when a system reliably establishes that person as the one to whom it was issued or transferred, and state codes such as Ohio's and Vermont's set out this test. [8] [9] [10] The United States is not listed on UNCITRAL's MLETR status page. [2] Q: Does a UK eBL remain valid at a foreign port of discharge? A: The UK Act applies as a matter of UK law; the government's Explanatory Notes say that different jurisdictions will recognise electronic trade documents to varying extents, and the Act therefore allows conversion to paper. [4] [3] Whether a foreign court gives effect to the record depends on that country's law; Singapore, for example, does not deny effect to a record solely because it was issued abroad. [5] Q: Do the Rotterdam Rules make eBLs valid? A: Article 8 of the Rotterdam Rules provides that the issuance, exclusive control or transfer of an electronic transport record has the same effect as the issuance, possession or transfer of a transport document, but the Convention is not in force: UNCITRAL lists five parties as at 18 October 2026, and 20 are required. [11] [12] Q: Will a bank accept an eBL under a letter of credit? A: Only if the credit allows it. The ICC's eUCP Version 2.1 governs electronic presentation under documentary credits and applies only where the credit indicates that it is subject to the eUCP. [15] Sources: [1] [UNCITRAL Model Law on Electronic Transferable Records (2017), with Explanatory Note: arts 1, 2, 7, 10, 11, 12, 17, 18 and 19; Explanatory Note paras 22-23 and 33](https://uncitral.un.org/sites/default/files/media-documents/uncitral/en/mletr_ebook_e.pdf) — UNCITRAL [2] [Status: UNCITRAL Model Law on Electronic Transferable Records (2017)](https://uncitral.un.org/en/texts/ecommerce/modellaw/electronic_transferable_records/status) — UNCITRAL [3] [Electronic Trade Documents Act 2023 (c. 38), ss. 1-4 and 8](https://www.legislation.gov.uk/ukpga/2023/38/data.htm) — legislation.gov.uk (The National Archives) [4] [Electronic Trade Documents Act 2023: Explanatory Notes, paras 1-2, 5-6, 33 and 75](https://www.legislation.gov.uk/ukpga/2023/38/pdfs/ukpgaen_20230038_en.pdf) — legislation.gov.uk (Department for Science, Innovation and Technology) [5] [Electronic Transactions Act 2010, Part 2A (Electronic Transferable Records), ss. 16A, 16B, 16D, 16E, 16H, 16I, 16O and 16P](https://sso.agc.gov.sg/Act/ETA2010?ProvIds=P12A-) — Singapore Statutes Online (Attorney-General's Chambers) [6] [Electronic Transactions (Amendment) Act 2021 (Act 5 of 2021), Acts Supplement: dates of passing, assent and commencement](https://sso.agc.gov.sg/Acts-Supp/5-2021/) — Singapore Statutes Online (Attorney-General's Chambers) [7] [§ 516 HGB – Form des Konnossements. Verordnungsermächtigung](https://www.gesetze-im-internet.de/hgb/__516.html) — Bundesministerium der Justiz (Gesetze im Internet) [8] [Uniform Commercial Code § 7-106. Control of Electronic Document of Title](https://www.law.cornell.edu/ucc/7/7-106) — Legal Information Institute, Cornell Law School [9] [Ohio Revised Code § 1307.106 Control of electronic document of title [UCC 7-106]](https://codes.ohio.gov/ohio-revised-code/section-1307.106) — Ohio Legislative Service Commission [10] [Vermont Statutes, Title 9A, Article 7, § 7-106. Control of electronic document of title](https://legislature.vermont.gov/statutes/section/09A/007/00106) — Vermont General Assembly [11] [United Nations Convention on Contracts for the International Carriage of Goods Wholly or Partly by Sea (Rotterdam Rules), arts 8, 9 and 94](https://uncitral.un.org/sites/default/files/media-documents/uncitral/en/rotterdam-rules-e.pdf) — UNCITRAL [12] [Status: United Nations Convention on Contracts for the International Carriage of Goods Wholly or Partly by Sea (New York, 2008) (the "Rotterdam Rules")](https://uncitral.un.org/en/texts/transportgoods/conventions/rotterdam_rules/status) — UNCITRAL [13] [Electronic Bills of Lading: Notification of New Process](https://www.igpandi.org/article/electronic-bills-of-lading-notification-of-new-process/) — International Group of P&I Clubs [14] [IG approved electronic bill of lading systems](https://www.igpandi.org/article/ig-approved-electronic-bill-of-lading-systems/) — International Group of P&I Clubs [15] [ICC Uniform Customs and Practice for Documentary Credits for Electronic Presentation (eUCP) Version 2.1 (introduction dated April 2023), arts e1 and e3](https://iccwbo.org/wp-content/uploads/sites/3/2022/03/823E_eUCP_FInal.pdf) — International Chamber of Commerce (ICC) [16] [Ley 14/2014, de 24 de julio, de Navegación Marítima, arts 262-265 and entry-into-force data (consolidated text)](https://www.boe.es/buscar/act.php?id=BOE-A-2014-7877) — Agencia Estatal Boletín Oficial del Estado [17] [Wet van 1 april 2026 tot wijziging van Boek 8 van het Burgerlijk Wetboek in verband met de invoering van het elektronisch cognossement, Stb. 2026, 86 (arts 400-401)](https://zoek.officielebekendmakingen.nl/stb-2026-86.html) — Officiële bekendmakingen (Staatsblad) [18] [Besluit van 8 juni 2026 tot vaststelling van het tijdstip van inwerkingtreding van de Wet invoering elektronisch cognossement, Stb. 2026, 140](https://zoek.officielebekendmakingen.nl/stb-2026-140.html) — Officiële bekendmakingen (Staatsblad) [19] [中华人民共和国海商法 (Maritime Code of the People's Republic of China), as revised 28 October 2025, arts 82-86 and 310](https://policy.mofcom.gov.cn/claw/clawContent.shtml?id=104015) — Ministry of Commerce of the People's Republic of China (policy.mofcom.gov.cn) [20] [Electronic Transactions Regulations 2021, Part 5, section 16: Electronic Transferable Records](https://en.adgm.thomsonreuters.com/rulebook/16-electronic-transferable-records) — Abu Dhabi Global Market (ADGM Rulebook) [21] [Application de la loi n° 2024-537 du 13 juin 2024 visant à accroître le financement des entreprises et l'attractivité de la France: articles 14 à 17 (titres transférables électroniques) and Décret n° 2025-811 du 12 août 2025](https://www.senat.fr/application-des-lois/ppl23-536.html) — Sénat (République française) [22] [Trade Notice No. 24/2025-26: Request for comments on the draft of 'The Digital Trade Facilitation Bill, 2026'](https://content.dgft.gov.in/Website/dgftprod/cb2fc214-b604-4cb8-a924-c3a439ad7a14/Trade%20Notice%2024%20dated%2009.02.2026.pdf) — Directorate General of Foreign Trade, Government of India [23] [法制審議会第２００回会議（令和６年９月９日開催）: 商法（船荷証券等関係）等の改正に関する要綱 adopted](https://www.moj.go.jp/shingi1/shingi03500044_00004.html) — Ministry of Justice, Japan ## Electronic vs paper bill of lading URL: https://www.ebl.com/guides/ebl-vs-paper-bill-of-lading Last verified: 18 Oct 2026 A paper bill of lading is a physical document whose holder possesses it and transfers it by indorsement or delivery; an electronic bill of lading (eBL) is an electronic record whose holder has exclusive control of it and transfers that control. [2] [5] [3] Both act as receipt, evidence of the contract of carriage and document of title, but an eBL's legal effect depends on the law that governs it or on the rules of the system that issued it, and P&I cover for cargo carried under an eBL depends on the system being approved by the International Group of P&I Clubs. [3] [6] [7] ### The short answer The two forms do the same job. Under the Hague-Visby Rules, scheduled to the UK Carriage of Goods by Sea Act 1971, a bill of lading is a receipt showing the identifying marks on the goods, their number, quantity or weight, and their apparent order and condition; under the UK Carriage of Goods by Sea Act 1992 it contains or evidences the contract of carriage and must be transferable by indorsement or, as a bearer bill, by delivery. [1] [2] The Explanatory Notes to the UK Electronic Trade Documents Act 2023 add that a transferred bill gives its lawful holder constructive possession of the goods and a right to claim delivery from the carrier. [6] The difference is how the document exists and how it moves. Paper is possessed and handed over; an eBL is held through exclusive control of an electronic transferable record, which the UNCITRAL Model Law on Electronic Transferable Records (MLETR) treats as meeting a legal requirement of possession. [5] The Rotterdam Rules provide that the issuance, exclusive control or transfer of an electronic transport record has the same effect as the issuance, possession or transfer of a paper transport document. [3] The Explanatory Notes record that the law governing these documents is premised on their being physically held, and the MLETR leaves rules of private international law untouched, so an eBL's standing depends on the law that applies to it. [6] [5] The Notes also record that before the 2023 Act the law in the United Kingdom did not recognise possession of electronic documents, so they "could not therefore be used effectively in electronic form". [6] ### Comparison, feature by feature Form. A paper bill is a document that the carrier must issue on the shipper's demand after receiving the goods. [1] An eBL is information in electronic messages: an electronic transport record in the Rotterdam Rules, an electronic trade document in the UK Act, which also requires a reliable system. [3] [4] Uniqueness. UNCITRAL's Explanatory Note says a paper document is "by nature unique", while an absolute guarantee that electronic data cannot be replicated may not be technically feasible, so the MLETR relies on reliable identification of the record and on control. [5] The UK Act requires the system to distinguish the document from copies and to prevent more than one person controlling it at a time, which the Law Commission of England and Wales calls preventing "double spending". [4] [8] Transferability. A paper bill passes by indorsement and delivery, or by delivery alone as a bearer bill, and the UK 1992 Act defines the holder by possession. [2] An eBL passes by transfer of control: under the MLETR this meets a requirement to transfer possession, and under the Rotterdam Rules the holder is the person to whom the record was issued or transferred under the system's procedures. [5] [3] Delivery of the goods. Under the Rotterdam Rules, a paper holder obtains delivery by surrender of the document; an eBL holder demonstrates through the system's procedures that it is the holder, after which the record ceases to have effect. [3] Where several paper originals exist and their number is stated, surrender of one suffices and the others cease to have effect. [3] Risk of loss, delay and forgery. The Law Commission's 2022 report records consultee evidence that goods often reach the discharge port before the paper bill, especially in commodity chains with sub-sales, causing storage or demurrage costs. [8] The Swedish Club's note to the International Group's standard letter of indemnity says cargo sometimes arrives before documents and that liability for delivery without the original bill is not covered by P&I insurance. [10] The UK P&I Club's 2017 guidance names mis-delivery as the first risk of such delivery. [11] Skuld reported in 2012 that members had seen forged bills of lading made on copies of their headed paper. [12] The Law Commission recorded a "strong, cogent" consultee argument that electronic documents "will not necessarily reduce the risk of fraud" and agreed that some types of fraud affect both forms equally. [8] Speed. The Law Commission records one consultee's evidence that buying from a supplier in California and selling to a customer in Europe involved at least four courier services of two to four days each, against minutes for an electronic transfer; this is consultee evidence, not the Commission's own finding. [8] Legal basis. A paper bill rests on statutes such as the UK 1971 and 1992 Acts. [1] [2] An eBL rests either on legislation giving it equal effect, such as the UK Electronic Trade Documents Act 2023, in force since 20 September 2023, or on the rulebook of a trading system; the International Group states that it approved such systems from 20 February 2010 "in the absence of legal recognition of electronic bills of lading". [4] [16] As at 18 October 2026, UNCITRAL lists legislation based on or influenced by the MLETR in 13 states. [9] Insurance cover. The International Group states that Club rules cover cargo liabilities under paperless trading systems only if the Group has approved the system; other exclusions, including delivery without production of the bill, apply to both forms. [7] Change of form. The MLETR, the UK Act and the Rotterdam Rules each allow a change of medium in either direction; each requires a statement of the change in the new form and provides that the old form ceases to have effect. [5] [4] [3] ### How each is used in a shipment Paper. A seller ships goods and receives original bills from the carrier. [1] It indorses an original and couriers it to its bank, which presents it under a letter of credit; the buyer's bank releases it to the buyer against payment, and the buyer surrenders it at the discharge port. [2] [8] [11] [3] If the goods arrive first, the carrier may be asked to release cargo against a letter of indemnity, a request The Swedish Club advises members to resist and the UK P&I Club describes as not recommended. [10] [11] Electronic. The carrier issues the record on a platform and the seller holds exclusive control; control passes to the seller's bank, the buyer's bank and the buyer, who at destination shows the carrier through the platform's procedures that it is the holder. [3] [5] DCSA states that, before platform interoperability, all parties had to be onboarded on the same platform to exchange eBLs. [13] Under the ICC's eUCP Version 2.1, the rules for electronic presentation apply only where the credit indicates that it is subject to the eUCP. [14] ### How much is still paper The UK Explanatory Notes cite a DCSA estimate that 16 million original bills of lading were issued by ocean carriers in 2020 and that more than 99% were paper. [6] DCSA's press release of 15 February 2023 states that carriers issue around 45 million bills a year and that 1.2% were electronic in 2021; the two figures use different bases. [15] [6] In that release, DCSA's nine member carriers (CMA CGM, Evergreen, Hapag-Lloyd, HMM, Maersk, MSC, ONE, Yang Ming and ZIM) committed to converting 50% of original bills to electronic form within five years and 100% by 2030. [15] DCSA projects savings of US$6.5 billion in direct costs and US$30-40 billion in annual global trade growth, attributing the latter to McKinsey (October 2022). [15] See the carrier tracker. ### What does not change The Hague-Visby Rules, as scheduled to the UK 1971 Act, apply to contracts of carriage covered by "a bill of lading or any similar document of title", and under the UK 2023 Act an electronic trade document has the same effect as an equivalent paper trade document. [1] [4] The International Group lists the same cover exclusions for both forms. [7] Consent still matters. The MLETR requires no one to use an electronic transferable record without consent, and the Rotterdam Rules make an electronic transport record subject to the consent of carrier and shipper. [5] [3] Recognition in one jurisdiction does not settle the position elsewhere: UNCITRAL notes that enacting states may depart from the Model Law text, and the International Group says the majority of jurisdictions had yet to adopt legislation like the UK's. [9] [16] See the legal tracker and Is an eBL legally valid?. ### Frequently asked questions Q: Is an electronic bill of lading the same as a paper bill of lading? A: It performs the same functions, but its legal effect depends on the governing law or system rules. [3] [7] In the United Kingdom, the Electronic Trade Documents Act 2023 gives an electronic trade document the same effect as an equivalent paper trade document. [4] Q: What happens if a paper bill of lading is lost or delayed? A: The Swedish Club publishes the International Group's standard letter of indemnity for delivery without the original and states that liability for such delivery is not covered by P&I insurance; the UK P&I Club advises members to ask why the original is unavailable. [10] [11] Q: Is an eBL more secure against fraud than paper? A: The Law Commission of England and Wales said a system meeting its criteria records document movements in a way that makes tampering very difficult, but recorded a consultee argument that electronic documents "will not necessarily reduce the risk of fraud" and agreed that some types of fraud affect both forms equally. [8] Skuld has reported forged paper bills made on copied headed paper. [12] Q: Can an eBL be switched to paper, or paper to an eBL? A: The MLETR, the UK Electronic Trade Documents Act 2023 and the Rotterdam Rules each allow a change of medium in either direction, require a statement of the change in the new form, and provide that the old form ceases to have effect. [5] [4] [3] Q: Does P&I insurance cover cargo carried under an eBL? A: The International Group states that Club rules cover cargo liabilities under paperless trading systems only if the Group has approved the system; from 20 February 2025 a system is deemed approved if it permits only eBLs governed by a law recognising them as equivalent to paper and its reliability is evidenced. [7] See the platform directory. Q: What share of bills of lading are electronic? A: DCSA stated on 15 February 2023 that 1.2% of around 45 million bills issued in 2021 were electronic; the UK Explanatory Notes cite an earlier DCSA estimate that over 99% of 16 million original bills in 2020 were paper. [15] [6] Sources: [1] [Carriage of Goods by Sea Act 1971, Schedule: The Hague Rules as amended by the Brussels Protocol 1968, Articles I(b) and III(3)-(4)](https://www.legislation.gov.uk/ukpga/1971/19/schedule) — legislation.gov.uk (The National Archives) [2] [Carriage of Goods by Sea Act 1992 (c. 50), ss. 1(2)-(3), 2(1) and 5(1)-(2) (revised version showing s. 1(5)-(6) omitted on 20 September 2023)](https://www.legislation.gov.uk/ukpga/1992/50/data.htm) — legislation.gov.uk (The National Archives) [3] [United Nations Convention on Contracts for the International Carriage of Goods Wholly or Partly by Sea (Rotterdam Rules), text: arts 1(10), 1(18)-(22), 8, 9, 10 and 47(1)](https://uncitral.un.org/sites/default/files/media-documents/uncitral/en/rotterdam-rules-e.pdf) — UNCITRAL [4] [Electronic Trade Documents Act 2023 (c. 38), ss. 1-5 and 8](https://www.legislation.gov.uk/ukpga/2023/38/data.htm) — legislation.gov.uk (The National Archives) [5] [UNCITRAL Model Law on Electronic Transferable Records (2017), with Explanatory Note: arts 7, 10, 11, 17, 18 and 19; Explanatory Note paras 81-85](https://uncitral.un.org/sites/default/files/media-documents/uncitral/en/mletr_ebook_e.pdf) — UNCITRAL [6] [Electronic Trade Documents Act 2023: Explanatory Notes, paras 1-6](https://www.legislation.gov.uk/ukpga/2023/38/pdfs/ukpgaen_20230038_en.pdf) — legislation.gov.uk (Department for Science, Innovation and Technology) [7] [Electronic Bills of Lading: Notification of New Process](https://www.igpandi.org/article/electronic-bills-of-lading-notification-of-new-process/) — International Group of P&I Clubs [8] [Electronic trade documents: Report and Bill (Law Com No 405, HC 1188), paras 1.30-1.31, 2.52, 2.55-2.56 and 10.19-10.24](https://cdn.websitebuilder.service.justice.gov.uk/uploads/sites/54/2025/12/Electronic-Trade-Documents-final-report-ACCESSIBLE-1.pdf) — Law Commission of England and Wales [9] [Status: UNCITRAL Model Law on Electronic Transferable Records (2017)](https://uncitral.un.org/en/texts/ecommerce/modellaw/electronic_transferable_records/status) — UNCITRAL [10] [INT GROUP A: Standard form Letter of Indemnity to be given in return for delivering cargo without production of the original Bill of Lading (International Group standard form, with Club note to members)](https://www.swedishclub.com/uploads/2023/12/LOI-INT-GROUP-A.pdf) — The Swedish Club [11] [Bills of Lading 2017: Delivery of cargo without original bills of lading](https://ukpandi.com/fileadmin/uploads/ukpandi/Documents/imports/13108/news/30520-uk_bills_loi_2017_new_this.pdf) — UK P&I Club (Thomas Miller) [12] [Fraud (member advisory on forged bills of lading and other transport documents)](https://www.skuld.com/topics/legal/pi-and-defence/fraud/) — Skuld [13] [E/BL (electronic bill of lading) platform interoperability](https://dcsa.org/our-mission/ebl-interoperability-platform) — Digital Container Shipping Association (DCSA) [14] [ICC Uniform Customs and Practice for Documentary Credits for Electronic Presentation (eUCP) Version 2.1, art. e1](https://iccwbo.org/wp-content/uploads/sites/3/2022/03/823E_eUCP_FInal.pdf) — International Chamber of Commerce (ICC) [15] [DCSA's member carriers commit to a fully standardised, electronic bill of lading by 2030](https://dcsa.org/newsroom/dcsas-member-carriers-commit-to-a-fully-standardised-electronic-bill-of-lading-by-2030) — Digital Container Shipping Association (DCSA) [16] [Electronic bills of lading - FAQs](https://www.igpandi.org/article/electronic-bills-of-lading-faqs/) — International Group of P&I Clubs ## Sea waybill vs bill of lading URL: https://www.ebl.com/guides/sea-waybill-vs-bill-of-lading Last verified: 18 Oct 2026 A bill of lading is a receipt and evidence of the contract of carriage that is transferred by indorsement or delivery, and the carrier releases the goods to its holder against surrender of the document. [1] [4] A sea waybill names the consignee and is not a document of title: the carrier delivers to that consignee on proof of identity, without surrender of any document. [1] [5] [11] ### The difference in one paragraph Under the UK Carriage of Goods by Sea Act 1992, a bill of lading is transferable by indorsement or, as a bearer bill, by delivery; a document incapable of such transfer is not a bill of lading under that Act. [1] A sea waybill is a document that is not a bill of lading but is a receipt evidencing a contract of carriage by sea and identifies the person to whom the carrier is to deliver. [1] The Rotterdam Rules draw a similar line: a negotiable transport document is consigned to order or to bearer and not marked non-negotiable; any other is non-negotiable. [4] ### Comparison Transferability. A bill of lading passes by indorsement or, if made out to bearer, by delivery, and its lawful holder acquires the rights of suit under the contract of carriage. [1] A sea waybill does not pass in this way; the named consignee acquires rights of suit as the person to whom delivery is to be made. [1] Hapag-Lloyd's waybill terms are headed "Not Negotiable"; BIMCO's LINEWAYBILL form is titled "Non-Negotiable Liner Sea Waybill". [9] [11] Document of title. The Hague-Visby Rules, scheduled to the UK Carriage of Goods by Sea Act 1971, apply to contracts covered by "a bill of lading or any similar document of title". [3] Maersk describes its Seaway Bill as identical to a negotiable bill of lading except that it is not a document of title; MSC's sea waybill states on its face that it is not a document of title. [8] [15] Originals. Where more than one original bill of lading is issued, the Rotterdam Rules provide that surrender of one suffices and the others cease to have effect. [4] Maersk states that no originals are issued for its Seaway Bill. [8] Delivery. Under the Rotterdam Rules the carrier delivers against surrender of a negotiable transport document and must refuse delivery without it; where no negotiable document has been issued, the carrier delivers to the consignee and may refuse delivery if the claimant does not properly identify itself. [4] The CMI Uniform Rules for Sea Waybills, Hapag-Lloyd's waybill terms and BIMCO's form all provide for delivery to the consignee on proof of identity. [5] [9] [11] Right of control. Under the CMI Uniform Rules the shipper may change the consignee until the consignee claims delivery, or may transfer the right of control to the consignee no later than the carrier's receipt of the goods, noting this on the waybill. [5] Hapag-Lloyd's terms allow the shipper to change the consignee up to arrival on written notice; ZIM's and MSC's terms make a change of the delivery party subject to the carrier's discretion and a written request. [9] [13] [15] Liability regime. UK COGSA 1971 gives the Hague-Visby Rules the force of law for a non-negotiable receipt marked as such only where the contract expressly provides that the Rules govern it as if it were a bill of lading. [2] The CMI Uniform Rules apply to the waybill any convention or national law that would have applied compulsorily to a bill of lading. [5] Hapag-Lloyd's and ZIM's terms, and BIMCO's form, each name the regime that applies. [9] [11] [13] Evidence of receipt. Under the Hague-Visby Rules a bill of lading is prima facie evidence of receipt of the goods as described, and proof to the contrary is inadmissible once it has been transferred to a third party in good faith. [3] The CMI Uniform Rules give a waybill statement a parallel effect: prima facie between carrier and shipper, conclusive for a consignee acting in good faith. [5] ### When each document is used A bill of lading is used where the goods may change hands in transit or where a party needs a document that controls delivery. [1] [4] A sea waybill is used where no such transfer is needed and the consignee is known at shipment; the shipper keeps the right of control unless it transfers it. [5] [11] During the COVID-19 lockdowns ONE urged customers to consider sea waybills or straight bills of lading, because delivery under a sea waybill does not require production of the document, and warned that it could not release cargo under an original bill of lading unless the originals were surrendered to its office. [12] ZIM's waybill terms apply US COGSA to shipments to or from the United States and treat the waybill for that purpose as a non-negotiable straight bill of lading. [13] Worked example. A seller in Valencia ships furniture to a buyer in Rotterdam who has paid in advance. No bank or intermediate buyer needs to hold title, so the seller asks the carrier for a sea waybill naming the buyer as consignee; on arrival the buyer identifies itself and collects the containers without presenting any document. [5] [11] Had the sale required payment against documents, the seller would have asked for a to-order bill of lading and indorsed it to the buyer's bank, and the buyer would have obtained the goods by surrendering the indorsed bill to the carrier. [1] [4] This describes practice; it is not legal advice. ### Electronic forms of both documents Both documents have electronic equivalents, but the legal problem differs. The Rotterdam Rules define a negotiable electronic transport record as one consigned to order whose use meets the procedures of article 9; any other electronic transport record is non-negotiable. [4] Only the negotiable record needs procedures for issuance, integrity, demonstration of holdership and confirmation of delivery, because only it replaces possession of a paper original with exclusive control. [4] The Rules have not entered into force: UNCITRAL lists five parties against the twenty required. [16] See the legal tracker. In the United Kingdom, the Electronic Trade Documents Act 2023, in force since 20 September 2023, applies to documents whose possession is required by law or commercial practice to claim performance of an obligation; its list of examples names the bill of lading but not the sea waybill. [6] An electronic bill of lading under the Act depends on a reliable system that allows only one person to control the document at a time. [6] See the UK ETDA explained. Industry standards cover both. DCSA states that its Bill of Lading standard applies to both original bills of lading and seaway bills. [7] Hapag-Lloyd states that its eBLs are still original bills of lading with document type MBL/OBL, while its separate sea waybill terms govern a download contract for electronic consignments. [14] [10] The carrier tracker lists each carrier's electronic bill of lading service. ### Points that differ by contract and jurisdiction The UK Carriage of Goods by Sea Act 1992 governs rights of suit under English law; UK COGSA 1971 extends the Hague-Visby Rules to a non-negotiable receipt only where the contract so provides; the CMI Uniform Rules apply only when a contract adopts them. [1] [2] [5] Each carrier's waybill terms set their own rules on changing the consignee and on liability. [9] [13] [15] ebl.com describes the law and carriers' published terms; it does not advise on a particular shipment. ### Frequently asked questions Q: Is a sea waybill a bill of lading? A: Not under the UK Carriage of Goods by Sea Act 1992, which defines it as a document that is not a bill of lading. [1] Maersk's own description calls its Seaway Bill a type of bill of lading that is not a document of title. [8] Q: Does the consignee need to present a sea waybill to collect the goods? A: No, under the CMI Uniform Rules, BIMCO's LINEWAYBILL form and the waybill terms of Hapag-Lloyd and MSC: the carrier delivers to the named consignee on proof of identity. [5] [9] [11] [15] Under the Rotterdam Rules, a non-negotiable document that states it must be surrendered is an exception. [4] Q: Can a sea waybill be transferred to another buyer? A: Not by indorsement. [1] Under the CMI Uniform Rules the shipper may instead instruct the carrier to change the consignee before delivery is claimed, subject to the carrier's terms. [5] [9] [15] Q: Can a sea waybill be electronic? A: Yes. DCSA's Bill of Lading standard covers seaway bills, the Rotterdam Rules define a non-negotiable electronic transport record, and Hapag-Lloyd's sea waybill terms cover electronic consignments. [7] [4] [10] Q: Do the Hague-Visby Rules apply to a sea waybill? A: The Rules apply to contracts covered by a bill of lading or similar document of title. [3] Under UK COGSA 1971 they have the force of law for a non-negotiable receipt only if the contract expressly so provides. [2] The CMI Uniform Rules apply any convention that would have applied compulsorily to a bill of lading. [5] Q: Is an electronic bill of lading the same as an electronic sea waybill? A: No. An electronic bill of lading replaces possession of a paper original with exclusive control, which is why the UK Electronic Trade Documents Act 2023 requires a reliable system allowing only one person to control it at a time. [6] Hapag-Lloyd states that its eBLs remain original bills of lading. [14] A sea waybill names the consignee and is not surrendered for delivery. [1] [5] See What is an eBL?. Sources: [1] [Carriage of Goods by Sea Act 1992 (c. 50), ss. 1, 2 and 5 (latest available revised version)](https://www.legislation.gov.uk/ukpga/1992/50/data.htm) — legislation.gov.uk (The National Archives) [2] [Carriage of Goods by Sea Act 1971 (c. 19), s. 1(4) and 1(6)](https://www.legislation.gov.uk/ukpga/1971/19/data.htm) — legislation.gov.uk (The National Archives) [3] [Carriage of Goods by Sea Act 1971, Schedule: The Hague Rules as amended by the Brussels Protocol 1968, Articles I(b) and III(4)](https://www.legislation.gov.uk/ukpga/1971/19/schedule) — legislation.gov.uk (The National Archives) [4] [United Nations Convention on Contracts for the International Carriage of Goods Wholly or Partly by Sea (Rotterdam Rules), text: arts 1(14)-(22), 8, 9, 45, 46, 47 and 51](https://uncitral.un.org/sites/default/files/media-documents/uncitral/en/rotterdam-rules-e.pdf) — UNCITRAL [5] [CMI Uniform Rules for Sea Waybills, rules 1, 3, 4, 5, 6 and 7](https://comitemaritime.org/wp-content/uploads/2018/06/Uniform-Rules-of-Waybills.pdf) — Comité Maritime International (CMI) [6] [Electronic Trade Documents Act 2023 (c. 38), ss. 1-3 and commencement information](https://www.legislation.gov.uk/ukpga/2023/38/data.htm) — legislation.gov.uk (The National Archives) [7] [Electronic Bill of Lading standard](https://dcsa.org/standards/bill-of-lading) — Digital Container Shipping Association (DCSA) [8] [What is a Seaway Bill?](https://www.maersk.com/support/faqs/2023/08/15/what-is-seaway-bill) — A.P. Moller - Maersk [9] [Sea Waybill · Not Negotiable · Terms and Conditions (LV 01-24), clauses 3 and 5](https://www.hapag-lloyd.com/content/dam/website/downloads/pdf/Sea_Waybill_Terms_and_Conditions_LV_01-24_EN.pdf) — Hapag-Lloyd AG [10] [Sea Waybill Terms and Conditions (download contract for electronic consignments)](https://www.hapag-lloyd.com/en/online-business/documentation/sea-waybill-terms-and-conditions.html) — Hapag-Lloyd AG [11] [LINEWAYBILL: Non-Negotiable Liner Sea Waybill (sample copy), front page and clause 10](https://www.bimco.org/media/ighitdb2/sample-copy-linewaybill.pdf) — BIMCO [12] [General Advisory for Customers: Encourage Sea Waybills or Straight Bills of Lading under the current COVID-19 situation (undated text; file path dated 2020-04)](https://cms-resources.one-line.com/sites/oneglobal/files/2020-04/Encourage%20Sea%20Waybills%20or%20Straight%20Bills%20of%20Lading%20under%20the%20current%20COVID-19%20situation.pdf) — Ocean Network Express (ONE) [13] [Waybill Terms and Conditions, clauses 2, 4 and 15](https://www.zim.com/help/waybill) — ZIM Integrated Shipping Services Ltd [14] [Electronic Bill of Lading (eBL)](https://www.hapag-lloyd.com/en/online-business/documentation/electronic-bill-of-lading.html) — Hapag-Lloyd AG [15] [MSC Sea Waybill Terms and Conditions, front page and clauses 1, 2, 5 and 20](https://msc.com/-/media/files/legal-files/sea-waybill.pdf?rev=-1) — MSC Mediterranean Shipping Company [16] [Rotterdam Rules: status (parties and actions required for entry into force)](https://uncitral.un.org/en/texts/transportgoods/conventions/rotterdam_rules/status) — UNCITRAL ## Telex release vs electronic bill of lading URL: https://www.ebl.com/guides/telex-release-vs-electronic-bill-of-lading Last verified: 18 Oct 2026 A telex release is a carrier's instruction to its destination office or agent to deliver without presentation of the original paper bill of lading, sent after the shipper has returned the originals, usually at origin. [5] [6] [9] An electronic bill of lading (eBL) is different in kind: the bill itself is an electronic record, transferred by passing exclusive control and surrendered within its system, so no paper original exists. [14] [15] [16] ### At a glance What it is. A telex release is a process layered on a paper bill of lading: the bill is issued, then returned to the carrier so that cargo can be released without it. [5] [9] An electronic bill of lading is the bill in electronic form, as provided for in the UNCITRAL Model Law on Electronic Transferable Records (MLETR). [14] Document of title. The TT Club, a transport and logistics mutual insurer, writes that telex release "is a process and never by itself an instruction to release cargo without presentation of a bill of lading". [9] Under the Rotterdam Rules, exclusive control or transfer of an electronic transport record has the same effect as possession or transfer of a paper one. [16] Transferability. After a telex release the goods go to the party the shipper designated; MSC Chile asks for to-order bills to be endorsed to that party. [5] [9] An eBL passes by transfer of exclusive control to the next holder, with any endorsement included in the record. [14] [16] Delivery. Maersk describes its electronic cargo release as releasing cargo at destination on proof of the receiver's identity as consignee. [3] An eBL holder obtains delivery by demonstrating under the system's procedures that it is the holder; the record then ceases to have effect. [16] Legal basis. The TT Club states that a carrier has no legal obligation to offer telex release; it rests on the carrier's own procedures. [9] An eBL rests on the terms or rulebook of its system and, where enacted, on legislation such as the UK Electronic Trade Documents Act 2023. [13] [15] Insurance. The International Group of P&I Clubs states that Club Rules exclude delivery without production of the negotiable document; for an approved electronic system that means delivery otherwise than under its rules. [12] ### What a telex release is MSC's Chile page defines telex release as "Release without original BL" where originals have already been printed. [5] Hapag-Lloyd (America)'s US notice calls the charge the "Bill of Lading Surrender Fee (or Telex Release Fee)". [7] Maersk calls its online version Electronic Cargo Release, "also known as 'Telex' or 'Express' release". [3] The TT Club describes the classical case: the shipper, once paid, returns all originals to the carrier, typically at the port of loading; the carrier then instructs its agent or branch at the place of delivery to deliver to the party the shipper designated, and files the returned bills. [9] Maersk Line Myanmar's advisory of 1 October 2019 has the shipper return the three originals to the counter and collect a surrendered (telex released) document after payment. [1] MSC Chile requires freight paid and the three originals returned with a request letter; to-order bills must be endorsed, or the shipper signs a letter of indemnity. [5] Hapag-Lloyd's UK notice of March 2020 offered telex release "subject to destination acceptance". [6] The TT Club adds that it never applies to sea waybills. [9] Maersk has moved the request online: the transport document receiver can request release through maersk.com once the original has been issued online under a web printing agreement. [2] Its Indonesia advisory of 19 September 2024 states that manual telex release, against the full set of originals and an original letter of indemnity, ceased from 4 September 2024. [4] Each carrier charges a fee; the FAQ below gives the published amounts. [5] [8] [2] ### Worked example A seller in Valparaíso ships to a buyer in Rotterdam under three original bills of lading. Once the buyer pays, the seller returns the originals to the carrier with a telex release request and pays the fee; the carrier marks them surrendered and instructs its Rotterdam office to release the cargo to the named consignee. [5] [9] On an eBL, no paper is printed: the seller transfers exclusive control of the record to the buyer after payment, and the buyer demonstrates within the platform that it is the holder to obtain delivery. [14] [16] This describes practice, not legal advice. ### What an electronic bill of lading is An eBL is the bill of lading itself held as an electronic record. The MLETR, adopted by UNCITRAL on 13 July 2017, provides that a requirement for possession is met if a reliable method establishes a person's exclusive control of the electronic transferable record, and transfer of possession by transfer of control; its Explanatory Note lists bills of lading among the documents covered. [14] In the United Kingdom, the Electronic Trade Documents Act 2023, in force since 20 September 2023, names the bill of lading as a paper trade document and gives an electronic trade document the same effect as paper where a reliable system ensures that only one person can control it at a time. [15] Its Explanatory Notes state that a transferred bill gives its lawful holder constructive possession of the goods. [19] The Rotterdam Rules, not in force (UNCITRAL lists five parties as at 18 October 2026 against the 20 required), provide that the carrier delivers to the holder of a negotiable electronic transport record once it demonstrates its status under the system's procedures; the record then ceases to have effect. [16] [17] The International Group lists 15 approved and six deemed-approved systems as at 18 October 2026; see the platform directory and how an eBL transfer works. [13] ### Risk and insurance cover A telex release replaces presentation of the original with an instruction. The TT Club's article of 2 July 2009 relays cases reported by ITIC, an insurer of ship agents: emails made to look as if they came from the carrier; a "go ahead" message, meant to redirect cargo, read by the agent as a release instruction; and a release request entered in a shared system, then cancelled with no further entry, so that the agent released cargo worth USD 250,000. [9] It also reports a Sydney case in which the shipper had not surrendered all the originals, and advises agents to verify release emails through the carrier's genuine address. [9] Gard's Guidance on Bills of Lading notes that many bill forms state that one original must be surrendered, duly endorsed, in exchange for the goods; that Gard's Rules exclude cover in certain circumstances where proper delivery has not been made; and that accepting a letter of indemnity is a commercial decision outside P&I cover. [10] The International Group's Clubs circulated standard-form letters of indemnity for delivery without production of bills of lading. [11] For eBLs, the Group covers liabilities under paperless systems only where the system is approved or, from 20 February 2025, deemed approved (P&I approval). [12] ### When each is used Telex release is used where a paper bill has been issued and no longer needs to change hands; Maersk's FAQ gives the case of a shipper surrendering the bill once the consignee has paid. [2] The TT Club states that the main reason appears to be that some countries, for instance in the Far East, do not recognise sea waybills for some dealings. [9] Maersk's UAE export instructions list 17 destinations, including Brazil, Chile and Venezuela, under a release restriction. [20] A sea waybill is a third option. Under the UK Carriage of Goods by Sea Act 1992 a sea waybill is not a bill of lading but identifies the person to whom the carrier is to deliver; MSC Chile's "Express Release (Sea Waybill)" is release without an original bill, declared in the manifest. [18] [5] See sea waybill vs bill of lading. An eBL keeps the bill transferable as a document of title: under the MLETR transfer of control stands in for transfer of possession. [14] Recognition in one jurisdiction does not settle how a court at the port of discharge will treat it; the International Group's deemed-approval criteria turn on governing law. [12] See is an eBL legally valid and the legal tracker. ### Frequently asked questions Q: Is a telex release the same as an electronic bill of lading? A: No. A telex release is a carrier's instruction to release cargo without presentation of the paper original after the originals have been surrendered; MSC's Chile page defines it as "Release without original BL" when originals are already printed. [5] An eBL is the bill of lading held as an electronic record whose exclusive control takes the place of possession, as provided in the MLETR and the UK Electronic Trade Documents Act 2023. [14] [15] Q: What is the difference between telex release and express release? A: Carriers use the terms differently. MSC's Chile page describes "Express Release (Sea Waybill)" as cargo release without an original bill, declared in the manifest, and telex release as release without the original where originals were already printed and have been returned. [5] Maersk describes its Electronic Cargo Release as "also known as 'Telex' or 'Express' release". [3] The TT Club writes that "express release" causes confusion because an "express" bill of lading is a term sometimes used for a sea waybill, and that the expression should be avoided. [9] Q: Does a telex release need the original bills of lading? A: The carrier instructions reviewed here require the originals to be returned, or never released, before the release is sent. Maersk Line Myanmar's procedure either has the shipper request a surrendered bill when submitting shipping instructions, so no originals are handed out, or has the first set of three originals returned to the counter. [1] MSC Chile requires the three originals with a telex release request letter. [5] Maersk's online service surrenders a bill that was issued online under a web printing agreement. [2] Q: Does a telex release cost money? A: The carriers reviewed here charge a fee. MSC Chile lists USD 60 for telex release in its export documentation charges effective 1 January 2026, MSC Indonesia lists IDR 1,100,000 for an outbound telex release fee, and Maersk's electronic cargo release charge depends on the country of the bill of lading owner's registered address, with amounts ranging from zero in some countries to local-currency figures in others. [5] [8] [2] Q: Is cargo delivered under a telex release covered by P&I insurance? A: The International Group states that Group Club Rules exclude delivery of cargo without production of the negotiable document, and Gard states that accepting a letter of indemnity is a commercial decision outside P&I cover. [12] [10] Whether a particular telex release delivery falls within cover depends on the Club's rules and the facts; ebl.com does not give legal or insurance advice. Q: Can a telex release be done for an eBL? A: An eBL does not need one. Under the Rotterdam Rules, the holder of a negotiable electronic transport record obtains delivery by demonstrating its status under the system's procedures, and the record then ceases to have effect, so there is no paper original to surrender at origin. [16] The MLETR and the UK Act do, however, allow a change of medium from electronic to paper, after which the paper bill is handled as paper. [14] [15] Sources: [1] [Customer Advisory: Surrender (Telex) B/L Procedure (Maersk Line Myanmar)](https://eascpcd.maersk.com/~/media_sc9/maersk/local-information/files/asia-pacific/myanmar/overview/surrender-telex-bl-procedure.pdf) — A.P. Moller - Maersk [2] [How to surrender the Bill of Lading document to Maersk?](https://www.maersk.com/support/faqs/how-to-surrender-bill-of-lading-to-maersk) — A.P. Moller - Maersk [3] [Electronic Cargo Release Service – TLE/TLI - World from/to Russia](https://www.maersk.com/news/articles/2021/06/09/electronic-cargo-release-service) — A.P. Moller - Maersk [4] [Electronic Cargo Release / Electronic Telex Release (Indonesia advisory)](https://maersk.com/news/articles/2024/09/19/electronic-cargo-release-electronic-telex-release) — A.P. Moller - Maersk [5] [Local Information: Chile — Export Local Procedures and Export Documentation Charges (effective 1 January 2026)](https://www.msc.com/en/local-information/america/chile) — MSC Mediterranean Shipping Company [6] [UK – Office opening and document release (March 2020)](https://www.hapag-lloyd.com/pt/services-information/news/2020/03/uk---office-opening-and-document-release.html) — Hapag-Lloyd AG [7] [USA – Bill of Lading Surrender Fee / Telex Release Fee (March 2018)](https://www.hapag-lloyd.com/de/services-information/news/2018/03/usa--_-bill-of-lading-surrender-fee---telex-release-fee.html) — Hapag-Lloyd AG [8] [MSC Indonesia Local Charges (updated 27 March 2024), item 14: Outbound – Telex Release Fee](https://www.msc.com/-/media/files/msc-cargo/local-information/asia-pacific/indonesia/msc-indonesia-local-charges-updates---3-may-2024.pdf) — MSC Mediterranean Shipping Company [9] [TT Talk – 'Telex release' by email](https://www.ttclub.com/news-and-resources/news/article/tt-talk-telex-release-by-email/) — TT Club (Through Transport Mutual Insurance Association, managed by Thomas Miller) [10] [Gard Guidance on Bills of Lading, sections 1.3.4.2, 1.3.4.4, 1.3.4.6 and 4.8](https://assets.eu.ctfassets.net/jchk06tdml2i/1KzN7tcMHhaqwmF2DwcHRm/1be1fd79b0d227458f6d366fcd1bbf1c/Guidances_Gard_Guidance_bills_of_lading_March_2011.pdf) — Gard AS [11] [Circular: International Group Standard Form Letters of Indemnity — Delivery of cargo without production of Bills of Lading (September 2010)](https://britanniapandi.com/wp-content/uploads/2025/03/igstandardformloi09-2010.pdf) — The Britannia Steam Ship Insurance Association Limited [12] [Electronic Bills of Lading: Notification of New Process](https://www.igpandi.org/article/electronic-bills-of-lading-notification-of-new-process/) — International Group of P&I Clubs [13] [IG approved electronic bill of lading systems](https://www.igpandi.org/article/ig-approved-electronic-bill-of-lading-systems/) — International Group of P&I Clubs [14] [UNCITRAL Model Law on Electronic Transferable Records (2017), with Explanatory Note: arts 2, 7, 10, 11, 15, 17 and 18; Explanatory Note para 38](https://uncitral.un.org/sites/default/files/media-documents/uncitral/en/mletr_ebook_e.pdf) — UNCITRAL [15] [Electronic Trade Documents Act 2023 (c. 38), ss. 1-4 and 8](https://www.legislation.gov.uk/ukpga/2023/38/data.htm) — legislation.gov.uk (The National Archives) [16] [United Nations Convention on Contracts for the International Carriage of Goods Wholly or Partly by Sea (Rotterdam Rules), text: arts 1(10), 1(18)-(22), 8, 9 and 47](https://uncitral.un.org/sites/default/files/media-documents/uncitral/en/rotterdam-rules-e.pdf) — UNCITRAL [17] [Status: United Nations Convention on Contracts for the International Carriage of Goods Wholly or Partly by Sea (New York, 2008) (the "Rotterdam Rules")](https://uncitral.un.org/en/texts/transportgoods/conventions/rotterdam_rules/status) — UNCITRAL [18] [Carriage of Goods by Sea Act 1992 (c. 50), s. 1](https://www.legislation.gov.uk/ukpga/1992/50/data.htm) — legislation.gov.uk (The National Archives) [19] [Electronic Trade Documents Act 2023: Explanatory Notes, para 4](https://www.legislation.gov.uk/ukpga/2023/38/pdfs/ukpgaen_20230038_en.pdf) — legislation.gov.uk (Department for Science, Innovation and Technology) [20] [Your guide to Electronic Cargo Release (Telex Release) — UAE export instructions](https://uescpcd.maersk.com/~/media_sc9/maersk/local-information/files/west-central-asia/uae/export/electronic-bl-release.pdf) — A.P. Moller - Maersk ## Straight vs negotiable (to-order) bill of lading URL: https://www.ebl.com/guides/straight-vs-negotiable-bill-of-lading Last verified: 18 Oct 2026 A negotiable bill of lading is made out "to order" and can be transferred to a new holder by endorsement and delivery, so that whoever lawfully holds it can claim the goods. [1] [3] [6] A straight bill of lading names a single consignee; endorsing it does not transfer it, and the carrier delivers to that person, in some systems only against surrender of the document. [3] [4] [10] ### The short answer The difference lies in the consignee box. Under the US Federal Bills of Lading Act (49 U.S.C. § 80103), a bill is negotiable if it states that the goods are to be delivered "to the order of a consignee", and non-negotiable if it states that they are to be delivered to a consignee. [3] The Rotterdam Rules, adopted by the UN General Assembly on 11 December 2008 and not in force (five parties; twenty needed), use the same test: a negotiable transport document is one whose wording, such as "to order", shows the goods consigned to the order of the shipper or consignee, or to bearer. [6] [16] A to-order bill passes from holder to holder, each lawful holder acquiring rights against the carrier. [1] [6] A straight bill can reach only the named consignee. [3] In the United Kingdom, the Carriage of Goods by Sea Act 1992 counts as bills of lading only documents transferable by indorsement or, as bearer bills, by delivery; the Court of Appeal has read a straight bill as a sea waybill under that Act. [1] [10] ### Comparison Consignee. Negotiable bill: to the order of a named party, or to bearer. [3] [5] Straight bill: a named consignee, no "order" wording. [3] [5] Transferability. Negotiable bill: by endorsement and delivery, or by delivery alone if endorsed in blank or made out to bearer. [1] [6] Straight bill: not transferable by endorsement; under UCC § 7-104 a bill consigned to a named person stays non-negotiable even if goods are released only against that person's signed order. [3] [5] Delivery. Negotiable bill: under 49 U.S.C. § 80110 the carrier delivers to the holder, who must possess the bill and offer to indorse it; under Rotterdam Rules art. 47 delivery is "upon surrender of the negotiable transport document". [4] [6] Straight bill: under § 80110 the carrier delivers to the named consignee; under the Rotterdam Rules a non-negotiable document that says it must be surrendered is surrendered, otherwise delivery is against identification. [4] [6] Electronic form. Both: the Rotterdam Rules define negotiable and non-negotiable electronic transport records, and the UNCITRAL Model Law on Electronic Transferable Records (MLETR) says a straight bill's limited transferability should not prevent its electronic issue. [6] [7] ### How a negotiable (to-order) bill works A to-order bill is a document of title that circulates. Under the Rotterdam Rules the holder of an order document transfers its rights by delivering it "duly endorsed either to such other person or in blank"; a bearer or blank-endorsed document passes by delivery alone. [6] UCC § 7-104 uses the same test, "to bearer or to the order of a named person". [5] In the United Kingdom, section 2 of the 1992 Act vests in the lawful holder of a bill of lading "all rights of suit under the contract of carriage as if he had been a party to that contract"; section 5(2) defines the holder as the named consignee in possession, or a person in possession after indorsement or, for a bearer bill, other transfer. [1] Delivery therefore depends on the document. Under 49 U.S.C. § 80110 the carrier may deliver to a person holding a bill made out to that person's order, or indorsed to that person or in blank. [4] Maersk's online transfer service covers original (negotiable) bills, not waybills; a bill "cannot be transferred to the consignee if it is 'to order' of shipper or bank". [12] ### How a straight bill works, and the presentation question A straight bill names the consignee and stops there. Under 49 U.S.C. § 80103(b) an indorsement does not "make the bill negotiable" or "give the transferee any additional right". [3] DCSA describes straight bills as not transferring title, with a named consignee that cannot be changed. [14] Whether the consignee must still present the paper has been litigated. In The Rafaela S [2003] EWCA Civ 556, the bill named a consignee without "order" wording but its attestation clause said one original "must be surrendered duly endorsed in exchange for the goods or delivery order". [10] Rix LJ, with whom Peter Gibson LJ agreed, held that the clause applied in straight as well as negotiable form, that a straight bill which must be produced for delivery is a document of title, and that the document was "a bill of lading or similar document of title" under the Hague-Visby Rules, scheduled to the Carriage of Goods by Sea Act 1971. [10] [2] The case reached the House of Lords in 2005; the UK P&I Club's briefing describes the Law Lords as concluding that the document was a bill of lading requiring presentation at the place of delivery. [11] The ruling had an insurance consequence. The UK P&I Club states that the International Group clubs amended the Pooling Agreement, with a rule change effective 20 February 2009, restricting cover where cargo is delivered without production of a straight bill, or of a waybill whose express terms or governing law require production at the discharge port. [11] In carrier practice the straight bill sits between the two. Ocean Network Express, in a customer notice during the COVID-19 lockdowns, named sea waybills its preferred document because delivery "does not need to be made against production of the Sea Waybill itself", with straight bills as the alternative, originals left at origin and cargo released under its surrender-at-origin or telex release procedure. [13] ### Electronic equivalents An electronic bill of lading can be either kind. The Rotterdam Rules define a negotiable electronic transport record as one carrying "to order" or "negotiable" wording and used under the article 9(1) procedures; delivery is "upon demonstration by the holder" under those procedures, and rights pass by transferring the record, "whether it be made out to order or to the order of a named person". [6] The MLETR, adopted by UNCITRAL on 13 July 2017, treats exclusive control of an electronic transferable record as equivalent to possession, and transfer of control as transfer of possession. [7] [17] Article 15 treats an endorsement requirement as met if the required information is included in the record; the Explanatory Note names straight bills as documents whose transferability "may be limited due to other agreements" and leaves transferability to substantive law. [7] In the United Kingdom, the Electronic Trade Documents Act 2023, in force since 20 September 2023, lists the bill of lading among its example trade documents and provides that "A person may possess, indorse and part with possession of an electronic trade document", with the same effect as the paper equivalent; it does not distinguish to-order from straight bills. [8] It implements the Law Commission's report of 16 March 2022 (Law Com No 405), which tied possession to a reliable system under which one person controls the document at a time and transfer divests the transferor. [9] [15] DCSA's Bill of Lading standard has two transport document types: a bill of lading, which can be negotiable, and a sea waybill, non-negotiable and issued to a named consignee. [18] [19] See platforms and the legal tracker. ### Worked example A seller in Spain ships machinery to a buyer in the United States under a letter of credit and asks the carrier for a bill to the order of the issuing bank. Once the buyer pays, the bank endorses the bill to the buyer, who presents it, and under 49 U.S.C. § 80110 the carrier delivers to the holder who possesses the bill and offers to indorse it. [3] [4] Had the buyer paid in advance, the seller could instead have named the buyer on a straight bill: the buyer could not pass the goods on by endorsing it, and the carrier would deliver to the named consignee, who must present the paper only if the bill's terms or governing law require it. [3] [4] [10] [11] This describes practice, not legal advice. ### Frequently asked questions Q: What does "to order" mean on a bill of lading? A: It makes the bill negotiable. Under 49 U.S.C. § 80103 a bill is negotiable if it states that the goods are to be delivered to the order of a consignee, and under the Rotterdam Rules a document is negotiable if wording such as "to order" shows the goods are consigned to the order of the shipper or of the consignee, or to bearer. [3] [6] The holder can then transfer it by endorsement and delivery. [6] Q: Can a straight bill of lading be endorsed to someone else? A: Not so as to transfer it. Under 49 U.S.C. § 80103(b), indorsing a non-negotiable bill does not make it negotiable or give the transferee any additional right. [3] Under UCC § 7-104 a bill consigned to a named person is non-negotiable. [5] In the UK, the Carriage of Goods by Sea Act 1992 excludes from its definition of a bill of lading any document that cannot be transferred by indorsement or as a bearer bill. [1] Q: Does the consignee have to present a straight bill of lading to get the goods? A: It depends on the document's terms and the governing law. In The Rafaela S, the Court of Appeal of England and Wales held on 16 April 2003 that a straight bill whose attestation clause required surrender had to be produced to obtain delivery; the UK P&I Club reports that the House of Lords in 2005 also concluded that the document required presentation at the place of delivery. [10] [11] Under the Rotterdam Rules, a non-negotiable document that says it must be surrendered is surrendered, while one that does not is delivered against identification. [6] Under 49 U.S.C. § 80110 the carrier delivers to the consignee named in a non-negotiable bill. [4] Q: Is a straight bill of lading the same as a sea waybill? A: Not quite. For the purposes of the UK Carriage of Goods by Sea Act 1992, the Court of Appeal in The Rafaela S read a straight bill as falling within the definition of a sea waybill, since it is not transferable by indorsement. [1] [10] But the same court held that a straight bill whose terms require production remains a document of title for the Hague-Visby Rules, and Ocean Network Express distinguishes the two in practice: delivery under a sea waybill does not require production of the waybill, while originals of a bill must be surrendered. [10] [13] See sea waybill. Q: Can a straight bill or a to-order bill be electronic? A: Yes, in systems and jurisdictions that recognise electronic records. The Rotterdam Rules define both negotiable and non-negotiable electronic transport records. [6] The UK Electronic Trade Documents Act 2023 gives an electronic trade document the same effect as its paper equivalent and does not distinguish the two forms. [8] The MLETR is aimed at transferable documents, and its Explanatory Note says the limited transferability of a straight bill should not prevent its issue on an electronic transferable records management system. [7] Q: Why does the straight-bill question matter for P&I insurance? A: Because of The Rafaela S. The UK P&I Club states that, following the decision, the International Group clubs amended the Pooling Agreement, with a matching rule change effective 20 February 2009, to restrict cover where cargo is delivered without production of a straight bill of lading, or of a waybill whose express terms or governing law require production at the discharge port. [11] See P&I approval. Sources: [1] [Carriage of Goods by Sea Act 1992 (c. 50), ss. 1, 2, 3 and 5 (latest available revised version)](https://www.legislation.gov.uk/ukpga/1992/50/data.htm) — legislation.gov.uk (The National Archives) [2] [Carriage of Goods by Sea Act 1971, Schedule: The Hague Rules as amended by the Brussels Protocol 1968, Articles I(b), III(3)-(4), III(7) and X](https://www.legislation.gov.uk/ukpga/1971/19/schedule) — legislation.gov.uk (The National Archives) [3] [49 U.S. Code § 80103 - Negotiable and nonnegotiable bills (Federal Bills of Lading Act)](https://www.law.cornell.edu/uscode/text/49/80103) — Legal Information Institute, Cornell Law School (US Code) [4] [49 U.S. Code § 80110 - Duty to deliver goods (Federal Bills of Lading Act)](https://www.law.cornell.edu/uscode/text/49/80110) — Legal Information Institute, Cornell Law School (US Code) [5] [U.C.C. § 7-104. Negotiable and Nonnegotiable Document of Title](https://www.law.cornell.edu/ucc/7/7-104) — Legal Information Institute, Cornell Law School (Uniform Commercial Code, 2003 text) [6] [United Nations Convention on Contracts for the International Carriage of Goods Wholly or Partly by Sea (Rotterdam Rules), text with General Assembly resolution 63/122 of 11 December 2008: arts 1(10), 1(15), 1(16), 1(19), 1(20), 45, 46, 47 and 57](https://uncitral.un.org/sites/default/files/media-documents/uncitral/en/rotterdam-rules-e.pdf) — UNCITRAL [7] [UNCITRAL Model Law on Electronic Transferable Records (2017), with Explanatory Note: arts 2, 7, 11 and 15; Explanatory Note paras 21, 88, 119 and 150-154](https://uncitral.un.org/sites/default/files/media-documents/uncitral/en/mletr_ebook_e.pdf) — UNCITRAL [8] [Electronic Trade Documents Act 2023 (c. 38), ss. 1-3 and 8](https://www.legislation.gov.uk/ukpga/2023/38/data.htm) — legislation.gov.uk (The National Archives) [9] [Electronic trade documents (project page: recommendations and timeline)](https://lawcom.gov.uk/project/electronic-trade-documents/) — Law Commission of England and Wales [10] [JI MacWilliam Co Inc v Mediterranean Shipping Company SA (The Rafaela S) [2003] EWCA Civ 556, Court of Appeal (Civil Division), 16 April 2003, paras 92-94, 142-147 and 148-156](https://caselaw.nationalarchives.gov.uk/ewca/civ/2003/556) — Find Case Law, The National Archives [11] [Rafaela S change to Rule 2, Section 17 no impact on waybills (briefing, dated February 2009 on its face)](https://www.ukpandi.com/media/files/imports/13108/briefings/2797-rafaela-s-change-to-rule-217.pdf) — UK P&I Club (Thomas Miller P&I Ltd) [12] [How to transfer the Bill of Lading ownership to another party?](https://www.maersk.com/support/faqs/how-to-transfer-the-bill-of-lading-ownership-to-another-party) — A.P. Moller - Maersk [13] [General Advisory for Customers: Encourage Sea Waybills or Straight Bills of Lading under the current COVID-19 situation (undated customer notice; file path dated April 2020)](https://cms-resources.one-line.com/sites/oneglobal/files/2020-04/Encourage%20Sea%20Waybills%20or%20Straight%20Bills%20of%20Lading%20under%20the%20current%20COVID-19%20situation.pdf) — Ocean Network Express (ONE) [14] [Bill of Lading (B/L) vs Sea Waybill: what's the difference?](https://dcsa.org/newsroom/sea-waybill-vs-bill-of-lading) — Digital Container Shipping Association (DCSA) [15] [Electronic Trade Documents Act 2023: Explanatory Notes, Overview of the Act](https://www.legislation.gov.uk/ukpga/2023/38/notes/division/2/index.htm) — legislation.gov.uk (Department for Science, Innovation and Technology) [16] [Status: United Nations Convention on Contracts for the International Carriage of Goods Wholly or Partly by Sea (New York, 2008) (the "Rotterdam Rules") - parties and entry-into-force requirement](https://uncitral.un.org/en/texts/transportgoods/conventions/rotterdam_rules/status) — UNCITRAL [17] [UNCITRAL Model Law on Electronic Transferable Records (2017) (text page: adoption date)](https://uncitral.un.org/en/texts/ecommerce/modellaw/electronic_transferable_records) — UNCITRAL [18] [DCSA Information Model 2024Q4: Transport document type](https://models.dcsa.org/2024Q4/EARoot/EA3/EA1/EA1/EA682.htm) — Digital Container Shipping Association (DCSA) [19] [Bill of Lading 3.0 documentation: 1. Introduction](https://dcsa.org/standards/bill-of-lading/documentation-bill-of-lading-3/bill-of-lading-3-introduction) — Digital Container Shipping Association (DCSA) ## Switch bill of lading URL: https://www.ebl.com/guides/switch-bill-of-lading Last verified: 18 Oct 2026 A switch bill of lading is a replacement bill of lading: the carrier takes back the full set of originals issued at the load port and issues a new set in its place, so that the bill presented at discharge is not the one first issued. [1] [5] The carriers whose instructions are cited here issue switch bills only on conditions, typically surrender of every original, a letter of indemnity and limits on what may change, because a second set in circulation and a false statement on the new set each create liability. [1] [4] [5] [6] ### What a switch bill of lading is A switch bill is not a new kind of document. It is an ordinary bill of lading issued for cargo that already has one, in exchange for that first set, so that the bill presented at discharge is not the one signed at loading. [1] [4] Hapag-Lloyd's letter of indemnity for switch bills states the exchange: the requester surrenders the full first set of originals, and the carrier issues another set of original bills or sea waybills naming a new shipper and consignee and, where applicable, a new notify party. [4] Maersk's Malaysia instructions present the same request as an amendment of the shipper, consignee and notify-party details against surrender of all three originals. [5] Surrender matters because of what a bill does. Under the UK Carriage of Goods by Sea Act 1992, the lawful holder of a bill, including by delivery of an indorsed bill, has "transferred to and vested in him all rights of suit" under the contract of carriage. [3] Skuld and Gard warn that a second set issued while the first still circulates means several bills for the same cargo, each of which may be presented for delivery. [1] [2] ### Why traders ask for one The common reasons are commercial. Gard lists splitting one bill into smaller parcels, consolidating bills for blended cargo, changing the discharge port after a sale made while the goods are at sea, keeping a trader's supplier confidential from its buyer, and correcting bills that do not meet a letter of credit's requirements. [2] West of England names the buyer who wants to appear as shipper so that the sub-buyer does not see the supplier, and the trader who wants to change or add a delivery port. [6] Hapag-Lloyd's letter of indemnity has the requester release the carrier from any liability for disclosing the original shipper's details to a third party. [4] Worked example. A trader buys steel coils from a mill in Asia and resells them to a customer in the Gulf. The mill ships against a to-order bill naming itself as shipper. The trader does not want its customer to see the mill's name, so it surrenders all three originals to the carrier's office, signs the carrier's letter of indemnity and pays the fee. The carrier issues a second set naming the trader as shipper and the Gulf customer as consignee, with cargo, ports and quantity unchanged, which the trader presents to its customer against payment. [4] [5] [1] ### The conditions carriers impose Surrender of the full first set. Maersk's Malaysia instructions require surrender of all three originals issued at the load port, which the carrier says is how ownership of title is determined. [5] Its Singapore process starts work only after the full first set is confirmed surrendered at a Maersk office, and its 14 July 2026 advisory on the online workflow lists surrender of the full first set at a counter desk as step one. [7] [8] Hapag-Lloyd's form has the requester surrender the full first set and warrant that it alone is entitled to possession and delivery of the goods. [4] A negotiable bill. Maersk's Singapore process states that a sea waybill is not negotiable and cannot be switched; the bill type must first be amended to a negotiable bill. [7] See sea waybill vs bill of lading. A letter of indemnity. Hapag-Lloyd's switch LOI indemnifies the carrier, its servants and agents, the vessel and her owner, charterer, operator and master against any liability arising from the switch, requires the requester to provide security if a vessel is arrested or detained, is governed by German law, and says the carrier may refuse the request at its sole discretion. [4] Maersk's Malaysia instructions require a letter indemnifying Maersk Malaysia against all risks and liabilities. [5] Limits on what may change. Maersk's Malaysia instructions do not amend the volume, measurement or weight declared by the shipper at the load port, citing Article III rule 3 of the Hague-Visby Rules, unless the change is instructed and approved from the origin office. [5] Under those Rules, scheduled to the UK Carriage of Goods by Sea Act 1971, the bill shows the quantity or weight supplied by the shipper and the apparent order and condition of the goods, and once the bill has been transferred to a third party acting in good faith "proof to the contrary shall not be admissible". [9] Payment, timing and fees. Maersk's Malaysia instructions require all outstanding freight and surcharges to be paid and charge MYR 300; its Singapore process asks for requests no later than 10 working days before arrival at the final port of discharge and charges SGD 270 per bill, plus SGD 140 per bill once the import manifest has been submitted. [5] [7] Its North America notice of 6 October 2025 set a USD 175 switch fee and a USD 125 administration fee for requests submitted through Maersk.com rather than by email; its notice of 8 July 2026 kept both fees but reversed the channel, so that the USD 125 fee applies to requests made outside Maersk.com. [10] [11] These are one carrier's figures; fees, channels and lead times differ by carrier and country. [5] [7] [10] [11] ### Risks Two sets in circulation. Skuld warns that if new bills are issued before the originals are cancelled and returned, several bills may circulate for the same cargo, a dishonest shipper could sell the goods twice, and the carrier may face a shortage claim equal to the full cargo value. [1] Gard and West of England make the same point about misdelivery. [2] [6] False statements. Skuld names a different load port stated to hide the cargo's origin, and ante-dated or post-dated bills used to draw on a letter of credit. [1] Gard names hiding a sanctioned shipper, altering the shipment date to fall before a credit's last shipment date, and altering the cargo description to turn claused bills into clean ones. [2] Both clubs say the new bill should show its true place and date of issue. [1] [2] Under the Hague-Visby Rules the shipper's guarantee of the quantity and weight it supplies does not limit the carrier's liability to anyone else. [9] Cover and indemnities. Skuld states that no express rule in its terms automatically removes P&I cover because bills were switched, but cover for cargo claims may be lost where the new bill is antedated, post-dated or describes the cargo or its quantity in a way the member knows is incorrect. [1] West of England says cover may be prejudiced for cargo claims arising from false statements on switch bills and will "nearly always be prejudiced" for misdelivery claims. [6] Gard and West of England both say a letter of indemnity does not reinstate cover, and Gard adds that it may be unenforceable where fraud or illegality is involved. [2] [6] ### What the P&I clubs say to check The clubs' guidance converges on a short list. The requester explains the purpose, and the carrier satisfies itself that it is legitimate. [1] [2] [6] The requester shows it is the lawful holder of the complete original set, since bills may have been transferred or indorsed since issue. [1] Gard adds that the original shipper's consent to removal from the bill is normally obtained. [2] The draft of the new bill matches the original in format and clauses, with cargo description, ports and quantity identical. [1] The original set is cancelled before the new set is issued. [1] [2] [6] The LOI is checked for the signatory's authority and the provider's creditworthiness, and Skuld suggests it be co-signed by a bank of good standing. [6] [1] This describes the clubs' guidance; it is not legal advice. ### Switching an electronic bill of lading Skuld contrasts the two media: an electronic bill of lading can be amended while the goods are in transit without issuing new bills, which mitigates the risk of multiple bills in circulation that a second paper set creates. [1] Amendment. Article 16 of the UNCITRAL Model Law on Electronic Transferable Records (MLETR) provides that where the law requires or permits amendment of a transferable document, the requirement is met for an electronic record if a reliable method is used so that the amended information is identified as such. [12] The Explanatory Note says amended information must be "identified as such and therefore be recognizable", because an amendment visible on paper may not be visible in an electronic record. [12] Change of medium is different. Articles 17 and 18 of the Model Law and section 4 of the UK Electronic Trade Documents Act 2023 allow a paper bill to be replaced by an electronic one or the reverse, with a statement of the change of medium in the new form; the old form ceases to have effect. [12] [13] The Explanatory Note states that "replace" in article 17 does not refer to reissuance, a distinct concept. [12] Whether a carrier offers a switch on an electronic bill is set by each carrier's and platform's own terms; the carrier pages cited here describe paper procedures. [5] [7] [8] See the carrier tracker and platform directory. ### Frequently asked questions Q: What is a switch bill of lading? A: A replacement set of bills of lading that the carrier issues after the first set is surrendered, usually to change the named shipper, consignee or notify party. [1] [4] [5] The cargo, voyage and contract of carriage stay the same; the document is reissued. [4] [5] Q: Why would someone need a switch bill of lading? A: Common reasons published by P&I clubs are to keep a supplier's identity from the end buyer, to change or add a discharge port after an on-water sale, to split or consolidate parcels, and to correct bills that do not meet a letter of credit's terms. [2] [6] [1] Q: Do all originals have to be surrendered before a switch bill is issued? A: The carrier instructions opened for this guide all require it. Maersk asks for the full set of first originals to be surrendered before processing starts, and Hapag-Lloyd's letter of indemnity has the requester surrender the full first set. [5] [7] [8] [4] The P&I clubs give the reason: two sets in circulation create a misdelivery risk. [1] [2] [6] Q: Can the cargo description, weight or date be changed on a switch bill? A: Maersk's Malaysia instructions do not amend declared volume, measurement or weight without origin approval, citing Article III rule 3 of the Hague-Visby Rules. [5] Skuld says the cargo description, ports and quantity must be identical and the original issue date must not be carried over, and Gard says replacement bills should be dated to show when they are actually issued. [1] [2] Q: Is a switch bill of lading legal? A: The P&I clubs describe switching as a legitimate commercial practice where the request has a genuine purpose and the new bill states the facts accurately, and as potential fraud where it misstates the load port, date, shipper or cargo. [1] [2] [6] Whether a particular switch is lawful depends on the facts and the governing law; this guide does not give legal advice. Q: Can an electronic bill of lading be switched? A: The MLETR allows an electronic transferable record to be amended by a reliable method that identifies the amended information, and Skuld notes that electronic bills can be amended in transit. [12] [1] Whether a given carrier or platform offers this is set by their own terms; a change of medium under the MLETR or the UK Electronic Trade Documents Act 2023 is a separate step that does not affect the parties' rights and obligations under the bill. [12] [13] Sources: [1] [Switch bills of lading](https://www.skuld.com/topics/legal/pi-and-defence/switch-bills-of-lading/) — Skuld (Assuranceforeningen Skuld) [2] [When an irresistible force meets an immovable object: can owners accommodate a charterer's request to switch bills of lading?](https://gard.no/insights/when-irresistible-force-meets-immovable-object/) — Gard [3] [Carriage of Goods by Sea Act 1992 (c. 50), ss. 2(1) and 5(2)](https://www.legislation.gov.uk/ukpga/1992/50/data.htm) — legislation.gov.uk (The National Archives) [4] [Letter of Indemnity (Undertaking for issuance of a switch bill of lading)](https://www.hapag-lloyd.com/content/dam/website/downloads/pdf/LOI_of_Switch_BL.pdf) — Hapag-Lloyd AG [5] [Switch Bill of Lading Request (Malaysia advisory)](https://www.maersk.com/~/media_sc9/maersk/local-information/files/asia-pacific/malaysia/switch-bill-of-lading-advisory.pdf) — Maersk (Maersk Malaysia Sdn Bhd, Sealand) [6] [Claims Guides: Bills of Lading 2 - Letters of Indemnity (section d, switch bills of lading)](https://www.westpandi.com/getattachment/6ef545bc-e311-41bf-9aee-79215e90463f/p-i_guide_bills_of_lading_2_4pp_v2_lr.pdf) — West of England P&I Club [7] [Switch process (Singapore export), version 1, 14 February 2025](https://ewscpcd.maersk.com/~/media_sc9/maersk/local-information/files/asia-pacific/singapore/export/switch-process-14-feb-2025-v1.pdf) — Maersk [8] [Switch Bill process update](https://www.maersk.com/news/articles/2026/07/14/switch-bill-process-update) — Maersk [9] [Carriage of Goods by Sea Act 1971, Schedule: The Hague Rules as amended by the Brussels Protocol 1968, Article III rules 3, 4 and 5](https://www.legislation.gov.uk/ukpga/1971/19/schedule) — legislation.gov.uk (The National Archives) [10] [Switch Bill requirement on proper declaration for North America cargo owners](https://www.maersk.com/news/articles/2025/10/06/switch-bill-requirement-on-proper-declaration-for-north-america-cargo-owners) — Maersk [11] [Switch Bill process update - North America](https://www.maersk.com/news/articles/2026/07/08/switch-bill-process-update-north-america) — Maersk [12] [UNCITRAL Model Law on Electronic Transferable Records (2017), with Explanatory Note: arts 16, 17 and 18; Explanatory Note paras 157-158, 168 and 172](https://uncitral.un.org/sites/default/files/media-documents/uncitral/en/mletr_ebook_e.pdf) — UNCITRAL [13] [Electronic Trade Documents Act 2023 (c. 38), ss. 3 and 4](https://www.legislation.gov.uk/ukpga/2023/38/data.htm) — legislation.gov.uk (The National Archives) ## MLETR explained: the UNCITRAL Model Law on Electronic Transferable Records URL: https://www.ebl.com/law/mletr Last verified: 17 Oct 2026 The MLETR is a model law adopted by UNCITRAL on 13 July 2017 that sets out when an electronic record can do the legal work of a paper transferable document, such as a bill of lading, a bill of exchange or a warehouse receipt. [2] It has no force of its own: it takes effect only through national legislation, and as of 17 October 2026 UNCITRAL lists legislation based on or influenced by it in 13 states. [3] ### What the MLETR is and how it was adopted The Model Law on Electronic Transferable Records (MLETR) was prepared by UNCITRAL, the United Nations Commission on International Trade Law, and adopted by the Commission at its 1057th meeting on 13 July 2017. [1] [2] UNCITRAL's Working Group IV (Electronic Commerce) drafted it over ten sessions between 2011 and 2016. [1] On 7 December 2017 the UN General Assembly adopted resolution 72/114, which recommends that all states give favourable consideration to the Model Law when revising or adopting legislation on electronic commerce. [4] Its purpose is to enable the legal use of electronic transferable records both domestically and across borders. [2] It applies to electronic records that are functionally equivalent to paper transferable documents or instruments, which UNCITRAL describes as typically including bills of lading, bills of exchange, promissory notes and warehouse receipts. [2] An Explanatory Note with article-by-article commentary accompanies the text. [1] ### What the Model Law does not do A model law is a suggested pattern that legislators may adopt into domestic law, and states that enact it may depart from the text. [3] Until a jurisdiction legislates, the MLETR has no legal effect there. It also does not create substantive law on transferable documents. Article 1(2) provides that, apart from its own provisions, it does not affect any rule of law governing a transferable document or instrument, including consumer protection rules. [1] The Explanatory Note adds that the same substantive law, including private international law, applies to a paper document and to an electronic record with the same information. [1] It deals with transferability and leaves negotiability, and the rights of the holder, to substantive law. [1] Article 1(3) excludes securities such as shares and bonds and other investment instruments. [1] The text addresses electronic equivalents of paper documents, not transferable records that exist only in electronic form. [1] Nothing in it obliges a person to use an electronic transferable record without consent, although consent may be inferred from conduct (article 7(2) and (3)). [1] ### Key provisions, article by article Article 2 defines an "electronic record", an "electronic transferable record" (an electronic record meeting article 10) and a "transferable document or instrument" (a paper document that entitles the holder to claim performance of an obligation and to transfer that right by transferring the document). [1] Article 7(1) provides that an electronic transferable record shall not be denied legal effect, validity or enforceability solely because it is electronic. [1] Articles 8 and 9 give functional equivalents for writing (information accessible for later reference) and signature (a reliable method that identifies the person and indicates their intention). [1] Article 10 is the core test: a legal requirement for a paper transferable document is met by an electronic record that contains the required information and for which a reliable method is used to identify it as the electronic transferable record, to make it capable of control from creation until it ceases to have effect, and to retain its integrity. [1] Article 11 makes control the equivalent of possession. A possession requirement is met if a reliable method is used to establish a person's exclusive control of the record and to identify that person as the one in control; transfer of possession is met by transfer of control. [1] Article 12 sets a general reliability standard: the method must be as reliable as appropriate for its function in the light of all relevant circumstances (listed factors include operational rules, data integrity, security, independent audit and industry standards), or be proven in fact to have fulfilled its function. [1] Article 15 covers endorsement, which is met if the endorsement information is included in the record and satisfies articles 8 and 9. [1] Article 16 allows amendment by a reliable method that identifies amended information as such. [1] Articles 17 and 18 govern change of medium from paper to electronic and back: a reliable method must be used, a statement of the change must be inserted, the old form becomes inoperative, and the parties' rights and obligations are unaffected. [1] Article 19 provides that an electronic transferable record shall not be denied legal effect solely because it was issued or used abroad, while leaving private international law untouched. [1] The text is technology neutral, accommodating registry, token, distributed ledger or other models. [1] [2] ### Which jurisdictions have enacted MLETR-based laws As checked on 17 October 2026, UNCITRAL's status page lists legislation based on or influenced by the MLETR in 13 states and 13 jurisdictions. [3] The years are the years the legislation was passed as notified to the UNCITRAL Secretariat, not entry-into-force dates. [3] The listed enactments are: Bahrain (2018); Belize (2021); China (2025, influenced by the Model Law and only for bills of lading); France (2024); Kiribati (2021); Marshall Islands (2025, influenced by the Model Law); Mauritius (2025, only for bills of exchange); Papua New Guinea (2022); Paraguay (2021); Singapore (2021); Timor-Leste (2024); the United Arab Emirates for the Abu Dhabi Global Market (2021); and the United Kingdom (2023, influenced by the Model Law). [3] UNCITRAL describes the list as indicative only. [3] The Netherlands is not on the list, although the explanatory memorandum to its electronic bill of lading Act says the Act aligns with the MLETR as far as possible. [3] [12] That Act was dated 1 April 2026 and entered into force on 1 July 2026. [11] [13] ### How national laws differ Singapore follows the Model Law text closely. Part 2A of its Electronic Transactions Act 2010, inserted by the Electronic Transactions (Amendment) Act 2021, states that it adopts the Model Law (section 16B), and its sections 16A to 16P follow the MLETR's structure, including control as the equivalent of possession (section 16I) and non-discrimination of foreign records (section 16P). [6] [7] It names bills of exchange, promissory notes and bills of lading as transferable documents. [6] Article 4 of the MLETR leaves party derogation to each enacting state; Singapore's section 16D(3) allows derogation from all of Part 2A but not from only some of it. [1] [6] The amending Act came into operation on 19 March 2021; the government described it as adopting the MLETR "with modifications". [7] [8] The United Kingdom's Electronic Trade Documents Act 2023 takes a different route. Instead of treating control as an equivalent of possession, section 3 provides that a person may possess, indorse and part with possession of an electronic trade document, which has the same effect as its paper equivalent. [5] Section 2 sets out the reliable-system requirements, including that no more than one person can exercise control at a time. [5] Section 1 lists examples of covered documents, among them bills of lading, ship's delivery orders, warehouse receipts and marine insurance policies. [5] For change of form, section 4 requires a statement of conversion and compliance with contractual or other requirements, but, unlike MLETR articles 17 and 18, no reliable method for the conversion itself. [1] [5] The Act was passed on 20 July 2023, came into force on 20 September 2023 under section 8(2), and contains no counterpart to article 19. [5] Scope varies elsewhere. China's Maritime Code, as revised on 28 October 2025 and in force from 1 May 2026, deals with electronic transport records in Articles 82 to 86; Article 85 requires transferable records to give the holder exclusive control and leaves detailed standards to the national cyberspace authority and the State Council transport department. [10] The Netherlands Act covers only electronic bills of lading, through amendments to Book 8 of the Civil Code. [11] [12] France enacted its rules in Loi n° 2024-537 of 13 June 2024. [9] ### What it means for electronic bills of lading Where a state has enacted MLETR-based law, an electronic bill of lading that meets its conditions can satisfy legal requirements that previously needed a paper bill of lading, such as possession, transfer and endorsement, through a reliable system. [1] [5] [6] The International Group of P&I Clubs lists approved electronic bill of lading systems with the terms and conditions, such as a rulebook or user agreement, approved for each. [14] Article 19 bars rejecting a record solely because it was issued abroad, but leaves private international law in place, so governing law and the law where the bill is relied on still matter. [1] Coverage differs too: some enactments are limited to bills of lading or to bills of exchange. [3] See the legal tracker for each jurisdiction's instrument, dates and scope, and the platform directory for systems in use. ### Frequently asked questions Q: What does MLETR stand for? A: MLETR stands for the UNCITRAL Model Law on Electronic Transferable Records, adopted by UNCITRAL on 13 July 2017. [2] Q: Is the MLETR legally binding? A: No. It is a model law that states may enact with changes; it has legal effect only through national legislation. [3] UN General Assembly resolution 72/114 recommends that states give it favourable consideration. [4] Q: Which countries have adopted the MLETR? A: As of 17 October 2026, UNCITRAL lists Bahrain, Belize, China, France, Kiribati, the Marshall Islands, Mauritius, Papua New Guinea, Paraguay, Singapore, Timor-Leste, the United Arab Emirates (Abu Dhabi Global Market) and the United Kingdom, some as influenced by the Model Law or limited in scope. [3] Q: Has the United Kingdom adopted the MLETR? A: UNCITRAL lists the United Kingdom's 2023 legislation as influenced by the Model Law and its principles. [3] The Electronic Trade Documents Act 2023 lets electronic trade documents, including bills of lading, be possessed and indorsed where a reliable system meets the requirements of section 2. [5] Q: What is control under the MLETR? A: Under article 11, control is the functional equivalent of possession: a reliable method must establish a person's exclusive control of the record and identify that person as the one in control. [1] Q: Does the MLETR require blockchain? A: No. The Explanatory Note says the Model Law is technology neutral and can accommodate registry, token, distributed ledger or other models. [1] Sources: [1] [UNCITRAL Model Law on Electronic Transferable Records (with General Assembly resolution 72/114, UNCITRAL decision and Explanatory Note)](https://uncitral.un.org/sites/default/files/media-documents/uncitral/en/mletr_ebook_e.pdf) — United Nations Commission on International Trade Law (UNCITRAL) [2] [UNCITRAL Model Law on Electronic Transferable Records (2017)](https://uncitral.un.org/en/texts/ecommerce/modellaw/electronic_transferable_records) — United Nations Commission on International Trade Law (UNCITRAL) [3] [Status: UNCITRAL Model Law on Electronic Transferable Records (2017)](https://uncitral.un.org/en/texts/ecommerce/modellaw/electronic_transferable_records/status) — United Nations Commission on International Trade Law (UNCITRAL) [4] [A/RES/72/114 — Model Law on Electronic Transferable Records of the United Nations Commission on International Trade Law](https://undocs.org/A/RES/72/114) — United Nations General Assembly [5] [Electronic Trade Documents Act 2023 (c. 38), as enacted](https://www.legislation.gov.uk/ukpga/2023/38/enacted) — legislation.gov.uk (The National Archives) [6] [Electronic Transactions Act 2010 (2020 Revised Edition)](https://sso.agc.gov.sg/Act/ETA2010) — Attorney-General's Chambers of Singapore, Singapore Statutes Online [7] [Electronic Transactions (Amendment) Act 2021 (No. 5 of 2021)](https://sso.agc.gov.sg/Acts-Supp/5-2021/) — Attorney-General's Chambers of Singapore, Singapore Statutes Online (Government Gazette Acts Supplement No. 6) [8] [Electronic Transactions Act amended to facilitate transactions, provide convenience & boost trade](https://www.mddi.gov.sg/newsroom/eta-amended-to-facilitate-transactions-provide-convenience-boost-trade/) — Ministry of Digital Development and Information, Singapore (joint MCI–IMDA press release) [9] [Dossier législatif : Loi visant à accroître le financement des entreprises et l'attractivité de la France (Loi n° 2024-537 du 13 juin 2024)](https://www.senat.fr/dossier-legislatif/ppl23-536.html) — Sénat (France) [10] [中华人民共和国海商法（2025修订） (Maritime Code of the People's Republic of China, 2025 revision)](https://policy.mofcom.gov.cn/claw/clawContent.shtml?id=104015) — Ministry of Commerce of the People's Republic of China (source: National Database of Laws and Regulations) [11] [Wet van 1 april 2026 tot wijziging van Boek 8 van het Burgerlijk Wetboek in verband met de invoering van het elektronisch cognossement (Stb. 2026, 86)](https://zoek.officielebekendmakingen.nl/stb-2026-86.html) — Staatsblad van het Koninkrijk der Nederlanden [12] [Memorie van toelichting, Kamerstuk 36 743 (Wet invoering elektronisch cognossement)](https://www.eerstekamer.nl/behandeling/20250512/memorie_van_toelichting/document3/f=/vmnd310dhoyt.pdf) — Eerste Kamer der Staten-Generaal [13] [Besluit van 8 juni 2026 tot vaststelling van het tijdstip van inwerkingtreding van de Wet invoering elektronisch cognossement (Stb. 2026, 140)](https://zoek.officielebekendmakingen.nl/stb-2026-140.html) — Staatsblad van het Koninkrijk der Nederlanden [14] [IG approved electronic bill of lading systems](https://www.igpandi.org/article/ig-approved-electronic-bill-of-lading-systems/) — International Group of P&I Clubs ## The UK Electronic Trade Documents Act 2023 explained URL: https://www.ebl.com/law/uk-etda Last verified: 18 Oct 2026 The Electronic Trade Documents Act 2023 is a United Kingdom statute, passed on 20 July 2023 and in force since 20 September 2023, under which a trade document held on a reliable electronic system can be possessed, indorsed and transferred with the same effect as its paper equivalent. [1] It covers documents whose function depends on possession, including the bill of lading, and it extends to England and Wales, Scotland and Northern Ireland. [1] ### Why the Act was needed Before the Act, the law of England and Wales did not recognise possession of an electronic document, because possession was associated only with tangible things. [5] [2] The Law Commission called this the "possession problem". [5] The industry worked around this with multipartite contracts, or rulebooks, under which every user agrees to treat an electronic transfer like a transfer of the paper document. [5] The Law Commission identified three shortcomings: added complexity; rights enforceable only against contractual counterparties, whereas paper documents are more consistently recognised globally; and a position untested in court. [5] The Commission consulted from 30 April 2021 and published Electronic trade documents: Report and Bill (Law Com No 405, HC 1188), ordered to be printed on 15 March 2022. [6] [5] The Government accepted the recommendations and used the special parliamentary procedure for Law Commission bills. [11] The Bill was introduced in the House of Lords on 12 October 2022; every section except section 6 (regulations) corresponds to a clause of the Bill as introduced. [2] [6] Royal Assent followed on 20 July 2023. [1] [10] ### Which documents the Act covers Section 1 defines a "paper trade document" by three tests: it is in paper form; it is of a type commonly used in at least one part of the United Kingdom in connection with trade in or transport of goods, or financing it; and possession of it is required, "as a matter of law or commercial custom, usage or practice", to claim performance of an obligation. [1] Section 1(2) gives a non-exhaustive list of examples: a bill of exchange, a promissory note, a bill of lading, a ship's delivery order, a warehouse receipt, a mate's receipt, a marine insurance policy and a cargo insurance certificate. [1] [4] The Explanatory Notes say "bill of lading" covers shipped, straight and multimodal bills, which fall within the Act if possession is a necessary part of their function; a listed document must still meet the section 1(1) tests. [4] A sea waybill is outside the Act in practice: the Explanatory Notes say sea waybills are not transferable, so their electronic use is unaffected, although section 1(1)(c) would apply if possession ever became relevant to one. [4] ### What a reliable system must do Under section 2, information in electronic form that would, on paper, make a paper trade document is an "electronic trade document" only if a reliable system is used to: identify the document so that it can be distinguished from any copies; protect it against unauthorised alteration; secure that no more than one person can exercise control of it at any one time; allow a person able to exercise control to demonstrate that ability; and secure that a transfer deprives the transferor of control. [1] A person exercises control by using, transferring or otherwise disposing of the document, whether or not they have a legal right to do so; persons acting jointly count as one, and reading or viewing is not of itself use. [1] The Explanatory Notes call the divestment requirement "the electronic equivalent of handing over a piece of paper". [2] Section 2(5) lists matters a court may take into account when judging reliability: the system's rules, integrity and access-control measures, hardware and software security, independent audit, any assessment by a supervisory or regulatory body, and any applicable voluntary scheme or industry standard. [1] The Explanatory Notes say this list is "based loosely on article 12" of the UNCITRAL Model Law and that the Act "does not prescribe or endorse any particular type of technology". [4] [2] There is no accreditation regime: the Law Commission rejected one as burdensome, preferring industry standards. [5] P&I approval is an insurance matter, not a requirement of the Act. ### Possession, indorsement and effect Section 3(1) provides that a person "may possess, indorse and part with possession of an electronic trade document". [1] Section 3(2) and (3) give it, and anything done in relation to it, the same effect as for an equivalent paper trade document. [1] Possession is then a common-law question of fact, turning on control and intention, and a transfer is a transfer of possession rather than an assignment. [4] Because an electronic document may have no "back", an electronic indorsement is valid wherever it appears. [4] Section 3(4), Scotland only, treats an electronic trade document as corporeal moveable property for Scottish pledge legislation. [1] Worked example. A seller in Felixstowe ships goods to a buyer in Singapore and the carrier issues an electronic bill of lading on a system that meets section 2. The seller indorses it to its bank and transfers control; the bank, once paid, transfers control to the buyer, who presents it to the carrier for delivery. Under section 3, each step has the effect it would have had with a paper bill governed by the same law. [1] How a court or bank in Singapore treats the record depends on Singapore law. ### Change of form Section 4 allows a paper trade document to be converted into an electronic one and vice versa, "if (and only if)" a statement that the document has been converted is included in the new form and any contractual or other requirements for the conversion are met. [1] On a valid conversion the old form ceases to have effect and all rights and liabilities continue in the new form. [1] The Explanatory Notes say the statement puts the transferee on notice and keeps an audit trail, and that the issuer and the person in possession would generally need to agree. [4] An invalid conversion leaves the old form in effect, so the obligor's liability could be duplicated unless the old document is cancelled. [4] This change of medium rule differs from MLETR articles 17 and 18, which also require a reliable method for the change. [8] [1] ### Exclusions, consequential changes and extent Section 5 lets parties opt out: if an intention that section 3 should not apply appears in, or can reasonably be inferred from, the document or its terms, neither section 3 nor section 4 applies. [1] Sections 1 to 4 do not apply to uncertificated securities under the Uncertificated Securities Regulations 2001, or to document types specified in regulations made under the affirmative procedure. [1] Section 7 excludes electronic trade documents from the electronic-presentment provisions of the Bills of Exchange Act 1882 and repeals section 1(5) and (6) of the Carriage of Goods by Sea Act 1992, a power to make regulations for the electronic use of bills of lading, sea waybills and ship's delivery orders; the 1992 Act's revised text shows both subsections omitted from 20 September 2023. [1] [4] [9] Section 8 extends the Act to England and Wales, Scotland and Northern Ireland, except that section 3(4) extends only to Scotland. [1] The Law Commission can recommend only for England and Wales; the Government extended the Act UK-wide because much of the relevant legislation already applies across the UK and the common law is similar. [5] [3] The Act came into force two months after it was passed, on 20 September 2023; sections 3 and 4 do not apply to documents issued before that day. [1] [10] ### How the Act relates to the MLETR UNCITRAL lists the United Kingdom on its MLETR status page with the year 2023 and a footnote that the legislation "is influenced by the Model Law and the principles on which it is based". [7] The Law Commission considered the Model Law "sound in principle" and sought alignment "insofar as possible", while tailoring its recommendations to the law of England and Wales. [5] The main difference is conceptual. MLETR article 11 treats a reliable method establishing exclusive control as meeting a requirement of possession. [8] The Act instead makes the electronic document itself possessable, so the common law of possession applies to it; control appears only in the section 2 gateway test. [5] [1] Other differences: the Act omits the MLETR's article 12(b) "safe harbour" for a method proven in fact to have worked; [5] [8] it has no counterpart to article 19 on records issued abroad, because the Commission knew of no rule under which English law would deny recognition to a document solely because it was issued abroad; [5] [8] and its change-of-form rule requires no reliable method for the conversion. [1] [8] See the MLETR explainer and the legal tracker. ### Frequently asked questions Q: When did the Electronic Trade Documents Act 2023 come into force? A: On 20 September 2023, at the end of two months beginning with Royal Assent on 20 July 2023 (section 8(2)). [1] [10] Sections 3 and 4 do not apply to documents issued before that date. [1] Q: Does the Act apply in Scotland and Northern Ireland? A: Yes. Section 8(1) extends the Act to England and Wales, Scotland and Northern Ireland; only section 3(4), on Scottish pledges, is limited to Scotland. [1] Q: Does the Act require a platform to be approved or accredited? A: No. Section 2 requires a reliable system and lists factors a court may consider, including independent audit and industry standards, but sets up no accreditation scheme. [1] The Law Commission rejected an accreditation regime as burdensome. [5] Q: Does the Act cover sea waybills? A: In practice no. The Explanatory Notes say sea waybills are not transferable, so their electronic use is not affected, though a document would be caught if possession of it were required to claim performance. [4] [1] Q: Is the UK Act an enactment of the MLETR? A: UNCITRAL lists it as "influenced by the Model Law and the principles on which it is based". [7] It uses possession rather than control as the operative concept and has no counterpart to MLETR article 19 or the article 12(b) safe harbour. [5] [1] [8] Q: Does an eBL under the UK Act have to be recognised in other countries? A: The Act governs the position under UK law only; it contains no provision on recognition abroad. [1] [5] Whether another country, a bank or a court at the port of discharge treats the record as a bill of lading depends on that country's law and the governing law of the document. See the legal tracker. Sources: [1] [Electronic Trade Documents Act 2023 (c. 38), full text with commencement annotations (ss. 1-8)](https://www.legislation.gov.uk/ukpga/2023/38/data.xml) — legislation.gov.uk (The National Archives) [2] [Electronic Trade Documents Act 2023: Explanatory Notes (PDF), incl. Overview paras 1-2, commentary, Annex B (Hansard references) and Annex C (progress of Bill table)](https://www.legislation.gov.uk/ukpga/2023/38/pdfs/ukpgaen_20230038_en.pdf) — legislation.gov.uk (Department for Science, Innovation and Technology) [3] [Electronic Trade Documents Act 2023: Explanatory Notes, Legal background (paras 7-13)](https://www.legislation.gov.uk/ukpga/2023/38/notes/division/4/index.htm) — legislation.gov.uk (Department for Science, Innovation and Technology) [4] [Electronic Trade Documents Act 2023: Explanatory Notes, Commentary on provisions of Act (paras 20-95)](https://www.legislation.gov.uk/ukpga/2023/38/notes/division/6/index.htm) — legislation.gov.uk (Department for Science, Innovation and Technology) [5] [Electronic trade documents: Report and Bill (Law Com No 405, HC 1188), paras 1.4, 1.35-1.36, 2.12, 2.34, 2.112, 6.46-6.47, 6.53, 8.116](https://cdn.websitebuilder.service.justice.gov.uk/uploads/sites/54/2025/12/Electronic-Trade-Documents-final-report-ACCESSIBLE-1.pdf) — Law Commission of England and Wales [6] [Electronic trade documents (project page)](https://lawcom.gov.uk/project/electronic-trade-documents/) — Law Commission of England and Wales [7] [Status: UNCITRAL Model Law on Electronic Transferable Records (2017)](https://uncitral.un.org/en/texts/ecommerce/modellaw/electronic_transferable_records/status) — United Nations Commission on International Trade Law (UNCITRAL) [8] [UNCITRAL Model Law on Electronic Transferable Records (2017) with Explanatory Note: arts 11, 12, 17, 18, 19](https://uncitral.un.org/sites/default/files/media-documents/uncitral/en/mletr_ebook_e.pdf) — United Nations Commission on International Trade Law (UNCITRAL) [9] [Carriage of Goods by Sea Act 1992 (c. 50), s. 1, latest available revised text with amendment annotations](https://www.legislation.gov.uk/ukpga/1992/50/data.xml) — legislation.gov.uk (The National Archives) [10] [UK economy to receive £1 billion boost through innovative trade digitalisation act (press release)](https://www.gov.uk/government/news/uk-economy-to-receive-1-billion-boost-through-innovative-trade-digitalisation-act) — Department for Science, Innovation and Technology (GOV.UK) [11] [Report on the implementation of Law Commission recommendations (May 2025, HC 850), paras 4-6 and p. 3](https://assets.publishing.service.gov.uk/media/681352eab0ef2c98505253fa/implementation-law-commission-recommendations-2023-2024.pdf) — Ministry of Justice (GOV.UK) ## Legal status of electronic bills of lading by jurisdiction Status values: In force (a law giving electronic bills of lading or transferable records paper-equivalent effect is in force); Enacted (passed, not yet in force); Bill tabled; Consultation (official reform project, no bill); No framework. MLETR-based: Yes = listed by UNCITRAL as adopting the Model Law without qualification; Partial = listed as influenced by it or limited in scope, or the government says the law follows it in part; No = not based on it. ### Electronic bills of lading in the Abu Dhabi Global Market (ADGM) URL: https://www.ebl.com/law/abu-dhabi-global-market Status: In force Instrument: Electronic Transactions Regulations 2021 MLETR-based: Yes Enacted: 25 Feb 2021 In force since: 28 Feb 2021 Last verified: 16 Oct 2026 Abu Dhabi Global Market (ADGM), a financial free zone in the Emirate of Abu Dhabi, United Arab Emirates, recognises electronic transferable records through Part 5 of its Electronic Transactions Regulations 2021. Section 16 gives an electronic transferable record the same legal effect, validity and enforceability as its paper form; a reliable method must identify the record, make it subject to control and preserve its integrity, and exclusive control takes the place of possession. The ADGM Board enacted the Regulations on 25 February 2021 and they came into force on publication on 28 February 2021. UNCITRAL lists ADGM, under the United Arab Emirates, as having adopted legislation based on the Model Law on Electronic Transferable Records in 2021. Scope: Part 5 (sections 16 to 23) applies to any transferable document or instrument required or permitted by an ADGM enactment, defined generically as a document entitling the holder to claim performance and to transfer that right by transferring the document; bills of lading are not named but fall within the generic definition. The Part 7 exclusions (powers of attorney, wills, long-term immovable-property dealings, notarised documents) are stated to apply to Parts 1 to 4 only. What remains unclear: The Regulations apply only within ADGM and only where an ADGM enactment requires or permits a transferable document or instrument; bills of lading are not named and rely on the generic definition. They do not address documents governed by UAE federal law outside ADGM. Sources: - [Electronic Transactions Regulations 2021, s. 17 Transferable Document or Instrument](https://en.adgm.thomsonreuters.com/rulebook/17-transferable-document-or-instrument) — Abu Dhabi Global Market - [Electronic Transactions Regulations 2021, s. 28 Interpretation](https://en.adgm.thomsonreuters.com/rulebook/28-interpretation-certain-words-and-expressions) — Abu Dhabi Global Market - [Electronic Transactions Regulations 2021, s. 25 Excluded matters](https://en.adgm.thomsonreuters.com/rulebook/25-excluded-matters) — Abu Dhabi Global Market - [Electronic Transactions Regulations 2021, s. 16 Electronic Transferable Records](https://en.adgm.thomsonreuters.com/rulebook/16-electronic-transferable-records) — Abu Dhabi Global Market - [Electronic Transactions Regulations 2021, s. 18 Control of Electronic Transferable Records](https://en.adgm.thomsonreuters.com/rulebook/18-control-electronic-transferable-records) — Abu Dhabi Global Market - [28 February — Commercial Regulations (Electronic Transactions) [publication notice]](https://adgmen.thomsonreuters.com/rulebook/28-february-commercial-regulations-electronic-transactions) — Abu Dhabi Global Market - [Status: UNCITRAL Model Law on Electronic Transferable Records (2017)](https://uncitral.un.org/en/texts/ecommerce/modellaw/electronic_transferable_records/status) — UNCITRAL - [Electronic Transactions Regulations 2021](https://en.adgm.thomsonreuters.com/rulebook/electronic-transactions-regulations-2021) — Abu Dhabi Global Market (ADGM Legal Framework rulebook) - [Electronic Transactions Regulations 2021, s. 32 Short title, extent and commencement](https://en.adgm.thomsonreuters.com/rulebook/32-short-title-extent-and-commencement) — Abu Dhabi Global Market ### Electronic bills of lading in Bahrain URL: https://www.ebl.com/law/bahrain Status: In force Instrument: Decree-Law No. (55) of 2018 with respect to Electronic Transferable Records MLETR-based: Yes Enacted: 28 Nov 2018 Last verified: 16 Oct 2026 Bahrain gives legal effect to electronic transferable records, including electronic bills of lading, under Decree-Law No. (55) of 2018 with respect to Electronic Transferable Records. The decree-law was issued on 28 November 2018 and published in Official Gazette issue 3395 on 29 November 2018. Under Article 19 it took effect on the first day of the month following 60 days after that publication. UNCITRAL lists Bahrain (2018) as having adopted legislation based on the Model Law on Electronic Transferable Records. Scope: Applies to electronic transferable records whether or not an operator is used. Covered documents are bills of lading, letters of credit and warehouse receipts, plus other documents of title specified by regulation of the Minister for Transportation after consulting the Governor of the Central Bank; covered instruments are cheques, bills of exchange and promissory notes, plus others specified by regulation of the Governor. What remains unclear: No official Bahraini source found states the exact commencement date; Article 19 fixes it by formula rather than by date. The law lets the Minister for Transportation and the Governor of the Central Bank of Bahrain add further documents and instruments by regulation; whether any have been issued is not confirmed here. Sources: - [مرسوم بقانون رقم (55) لسنة 2018 بشأن السجلات الإلكترونية القابلة للتداول (Official Gazette No. 3395)](https://www.lloc.gov.bh/PDF/L5518.pdf) — Legislation and Legal Opinion Commission, Kingdom of Bahrain - [Law No. (55) of 2018 with respect to Electronic Transferable Records (English guidance version)](https://www.lloc.gov.bh/FullEn/L5518.docx) — Legislation and Legal Opinion Commission, Kingdom of Bahrain - [Status: UNCITRAL Model Law on Electronic Transferable Records (2017)](https://uncitral.un.org/en/texts/ecommerce/modellaw/electronic_transferable_records/status) — UNCITRAL - [Decree-Law No. (55) of 2018 (HTML text)](https://lloc.gov.bh/Legislation/HTM/L5518) — Legislation and Legal Opinion Commission, Kingdom of Bahrain ### Electronic bills of lading in Belize URL: https://www.ebl.com/law/belize Status: In force Instrument: Electronic Transactions Act, 2021 (Act No. 25 of 2021) MLETR-based: Yes Enacted: 5 Oct 2021 In force since: 5 Oct 2021 Last verified: 16 Oct 2026 Belize recognises electronic transferable records through Part VII of the Electronic Transactions Act, 2021 (Act No. 25 of 2021), which repealed the earlier Electronic Transactions Act (Cap. 229:03). A legal requirement for a transferable document or instrument is met by an electronic record where a reliable method identifies the record, makes it subject to control and preserves its integrity, and possession is met by exclusive control. The Act contains no commencement provision, so under section 41 of the Interpretation Act it took effect on the Governor-General's assent on 5 October 2021; it was gazetted on 9 October 2021. UNCITRAL lists Belize as having adopted legislation based on the Model Law on Electronic Transferable Records in 2021. Scope: Part VII (sections 30 to 40) applies to any transferable document or instrument, defined generically as a paper document entitling the holder to claim performance of an obligation and to transfer that right by transferring the document; bills of lading are not named but fall within the definition. Securities such as shares and bonds and other investment instruments are excluded, and other rules of law governing transferable documents, including consumer protection, continue to apply. What remains unclear: Section 53 allows the Minister to exclude specific written laws from the Act by Order, and section 54 allows implementing Regulations; no Order or Regulations affecting Part VII were identified. No amendment to the Act after 2021 was identified as of 16 October 2026. Sources: - [Electronic Transactions Act, 2021 (Act No. 25 of 2021)](https://www.belipo.bz/wp-content/uploads/2024/01/Act-No.-25-of-2021-Electronic-Transactions-Act-2021.pdf) — Government of Belize (copy hosted by the Belize Intellectual Property Office) - [Status: UNCITRAL Model Law on Electronic Transferable Records (2017)](https://uncitral.un.org/en/texts/ecommerce/modellaw/electronic_transferable_records/status) — UNCITRAL - [Interpretation Act, Chapter 1, Substantive Laws of Belize, Revised Edition 2020](https://www.agm.gov.bz/uploads/laws/63bdc09762564_Cap_01_Interpretation_Act.pdf) — Attorney General's Ministry, Government of Belize ### Electronic bills of lading in China URL: https://www.ebl.com/law/china Status: In force Instrument: Maritime Code of the People's Republic of China (中华人民共和国海商法), as revised on 28 October 2025 (Presidential Order No. 58) MLETR-based: Partial Enacted: 28 Oct 2025 In force since: 1 May 2026 Last verified: 16 Oct 2026 Under the revised Maritime Code, adopted on 28 October 2025 and in force from 1 May 2026, China gives electronic transport records that meet the statutory conditions the same legal effect as paper transport documents. Articles 82–86 let carrier and shipper agree to use electronic records; a transferable record must use a reliable method or system that keeps it unique and gives the holder exclusive control. UNCITRAL lists China as a 2025 enactment influenced by the MLETR and applying only to bills of lading. Provisions on electronic documents issued on 17 April 2026 by the Cyberspace Administration of China and nine other departments, in force from 1 September 2026, set requirements for reliable electronic document systems. Scope: Chapter IV, Section 5 (Articles 82–86) of the revised Code covers electronic transport records issued under contracts for the carriage of goods by sea, both transferable and non-transferable, and so covers electronic bills of lading and sea waybills; it does not cover bills of exchange, promissory notes or warehouse receipts. Separate Provisions on Promoting and Regulating the Application of Electronic Documents (CAC Order No. 22, in force 1 September 2026) apply more widely, including to electronic warehouse receipts and cargo insurance policies. What remains unclear: Article 85 of the revised Code leaves the standards for transfer, exclusive control, form conversion and reliable systems for transferable electronic transport records to be set separately by the national cyberspace authority together with the State Council transport department. CAC Order No. 22 (in force 1 September 2026) cites the Maritime Code as one of its legal bases and sets functions for systems serving transferable electronic documents, but it does not say that it is the Article 85 standard. Whether further standards will be issued is not yet clear. Sources: - [Status: UNCITRAL Model Law on Electronic Transferable Records (2017)](https://uncitral.un.org/en/texts/ecommerce/modellaw/electronic_transferable_records/status) — UNCITRAL - [中华人民共和国海商法（2025修订）](https://policy.mofcom.gov.cn/claw/clawContent.shtml?id=104015) — Ministry of Commerce of the PRC (regulations database, sourced from the National Database of Laws and Regulations) - [促进和规范电子单证应用规定 (Order No. 22)](https://www.cac.gov.cn/2026-04/17/c_1778166821092785.htm) — Cyberspace Administration of China and nine other central departments - [Supreme People's Court announcement of the judicial interpretation on the temporal effect of the Maritime Code (法释〔2026〕8号)](https://www.court.gov.cn/zixun/xiangqing/498581.html) — Supreme People's Court of the PRC ### Electronic bills of lading in France URL: https://www.ebl.com/law/france Status: In force Instrument: Loi n° 2024-537 du 13 juin 2024 visant à accroître le financement des entreprises et l'attractivité de la France (Titre II, articles 14 à 17) MLETR-based: Yes Enacted: 13 Jun 2024 In force since: 14 Mar 2025 Last verified: 16 Oct 2026 France gives electronic transferable records the same effects as paper under Title II (articles 14 to 17) of Law No. 2024-537 of 13 June 2024, which created the 'titre transférable électronique'. An electronic title has the same effects as its paper equivalent where a reliable method ensures uniqueness, exclusive control, identification of signatories and holders, and integrity; the law also amends article L. 5422-3 of the Code des transports so that a maritime bill of lading may be issued, signed, transferred, amended, kept and delivered electronically. Title II took effect on 14 March 2025, and Decree No. 2025-811 of 12 August 2025, in force from 15 August 2025, sets the conditions for the reliable method, including independent certification. UNCITRAL lists France (2024) as having adopted legislation based on the Model Law on Electronic Transferable Records. Scope: Title II defines the 'titre transférable' and lets it be issued electronically. It covers bills of exchange and promissory notes, warehouse receipts and warrants, maritime bills of lading to order or bearer, negotiable inland-waterway bills of lading under the CMNI, insurance policies to order or bearer (including cargo and transport policies), assignable professional-receivables slips to order, and any other writing to order or bearer that meets the definition. Seven categories are excluded, including financial instruments, cheques and bons de caisse, and Title II does not apply to titles issued before it came into force. What remains unclear: Title II took effect on 14 March 2025, but the decree defining the reliable method took effect only on 15 August 2025, so it is unclear how the equivalence applied in between. Under the decree a method must be certified by an independent evaluation body; no public list of certified methods has been identified. Sources: - [LOI n° 2024-537 du 13 juin 2024 visant à accroître le financement des entreprises et l'attractivité de la France (JORFTEXT000049707573), articles 14, 16 and 29](https://www.legifrance.gouv.fr/eli/loi/2024/6/13/2024-537/jo/texte) — Légifrance (DILA) - [Code des transports, article L5422-3 (version en vigueur depuis le 14 mars 2025)](https://www.legifrance.gouv.fr/codes/article_lc/LEGIARTI000049720450/2025-03-14) — Légifrance (DILA) - [Status: UNCITRAL Model Law on Electronic Transferable Records (2017)](https://uncitral.un.org/en/texts/ecommerce/modellaw/electronic_transferable_records/status) — UNCITRAL - [Décret n° 2025-811 du 12 août 2025 relatif à la définition de la méthode fiable pour la dématérialisation des titres transférables et portant diverses dispositions relatives aux instruments pour le commerce extérieur (JORFTEXT000052097141)](https://www.legifrance.gouv.fr/eli/decret/2025/8/12/2025-811/jo/texte) — Journal officiel de la République française n° 0188 du 14 août 2025 (DILA) - [Dossier législatif : Loi visant à accroître le financement des entreprises et l'attractivité de la France](https://www.senat.fr/dossier-legislatif/ppl23-536.html) — Sénat (France) - [État d'application de la loi n° 2024-537 du 13 juin 2024](https://www.senat.fr/application-des-lois/ppl23-536.html) — Sénat (France) ### Electronic bills of lading in Germany URL: https://www.ebl.com/law/germany Status: In force Instrument: Handelsgesetzbuch (HGB), § 516 Abs. 2 (elektronisches Konnossement), inserted by the Gesetz zur Reform des Seehandelsrechts vom 20. April 2013 (BGBl. I S. 831) MLETR-based: No Enacted: 20 Apr 2013 In force since: 25 Apr 2013 Last verified: 16 Oct 2026 Germany recognises electronic bills of lading under § 516(2) of the Handelsgesetzbuch (HGB), which treats an electronic record performing the same functions as a paper bill of lading as equivalent to it, provided its authenticity and integrity are safeguarded. The provision was inserted by the Gesetz zur Reform des Seehandelsrechts of 20 April 2013, in force from 25 April 2013; the government's explanatory memorandum says it followed the Rotterdam Rules, and it predates the UNCITRAL Model Law on Electronic Transferable Records (2017). The Federal Ministry of Justice may set detailed rules on issue, presentation, return and transfer by regulation (§ 516(3)), but no such regulation appears in the federal law database. Germany is not listed on the UNCITRAL Model Law status page. Scope: The German Commercial Code treats an electronic record that performs the same functions as the paper document, with authenticity and integrity safeguarded, as equivalent to a bill of lading (§ 516(2) HGB), a land-transport Ladeschein (§ 443(3)) and a warehouse receipt, Lagerschein (§ 475c(4)); the same 2013 Act also allowed an electronic consignment note, Frachtbrief (§ 408(3)), which is not a document of title. Bills of exchange and other negotiable instruments are not covered by these provisions. What remains unclear: No regulation under § 516(3) HGB had been issued as of 16 October 2026, so the law does not specify how control and transfer of an electronic bill of lading are to be evidenced. No government bill or ministry draft implementing the Model Law or a broader electronic trade documents regime had been found as of the same date. Sources: - [§ 516 HGB – Form des Konnossements. Verordnungsermächtigung](https://www.gesetze-im-internet.de/hgb/__516.html) — Bundesministerium der Justiz / Bundesamt für Justiz (gesetze-im-internet.de) - [§ 443 HGB – Ladeschein. Verordnungsermächtigung](https://www.gesetze-im-internet.de/hgb/__443.html) — Bundesministerium der Justiz / Bundesamt für Justiz (gesetze-im-internet.de) - [§ 475c HGB – Lagerschein. Verordnungsermächtigung](https://www.gesetze-im-internet.de/hgb/__475c.html) — Bundesministerium der Justiz / Bundesamt für Justiz (gesetze-im-internet.de) - [Gesetz zur Reform des Seehandelsrechts vom 20. April 2013, BGBl. 2013 Teil I Nr. 19, S. 831](https://www.bgbl.de/xaver/bgbl/start.xav?startbk=Bundesanzeiger_BGBl&jumpTo=bgbl113s0831.pdf) — Bundesgesetzblatt (Bundesanzeiger Verlag for the Federal Ministry of Justice) - [Status: UNCITRAL Model Law on Electronic Transferable Records (2017)](https://uncitral.un.org/en/texts/ecommerce/modellaw/electronic_transferable_records/status) — UNCITRAL - [Drucksache 17/10309: Entwurf eines Gesetzes zur Reform des Seehandelsrechts (Gesetzentwurf der Bundesregierung)](https://dserver.bundestag.de/btd/17/103/1710309.pdf) — Deutscher Bundestag - [Gesetze im Internet – table of contents of federal laws and regulations](https://www.gesetze-im-internet.de/gii-toc.xml) — Bundesministerium der Justiz / Bundesamt für Justiz - [Einführungsgesetz zum Handelsgesetzbuch, Art. 71 (Übergangsvorschrift zum Gesetz zur Reform des Seehandelsrechts)](https://www.gesetze-im-internet.de/hgbeg/BJNR004370897.html) — Bundesministerium der Justiz / Bundesamt für Justiz (gesetze-im-internet.de) ### Electronic bills of lading in India URL: https://www.ebl.com/law/india Status: Consultation Instrument: The Digital Trade Facilitation Bill, 2026 (draft) MLETR-based: not established Last verified: 16 Oct 2026 India has no statute in force that gives electronic bills of lading the same legal effect as paper; the Directorate General of Foreign Trade published a draft Digital Trade Facilitation Bill, 2026 for public comment on 9 February 2026. The draft would recognise electronic trade documents, treat control by a reliable method as possession, and allow change of medium between paper and electronic form, in terms close to the UNCITRAL Model Law on Electronic Transferable Records, though it does not name the Model Law. The Bills of Lading Act 2025 (Act No. 18 of 2025), in force since 10 September 2025, replaced the Indian Bills of Lading Act 1856 but contains no provision on electronic form. India is not listed on the UNCITRAL Model Law status page. Scope: The draft bill would apply to electronic trade documents listed in its First Schedule, which is blank in the consultation draft, so it is not yet confirmed that bills of lading are covered; it would also amend the Negotiable Instruments Act 1881 to cover promissory notes, bills of exchange and cheques in electronic form and omit the negotiable-instrument exclusion (Sl. No. 1) from the First Schedule to the Information Technology Act 2000. The Bills of Lading Act 2025 in force does not mention electronic bills of lading. What remains unclear: No Cabinet approval or introduction in Parliament of the draft Digital Trade Facilitation Bill, 2026 had been found by 16 October 2026, after a 30-day consultation that opened on 9 February 2026. The draft's First Schedule, which will list the documents covered, is blank, so it is not yet clear whether bills of lading will be included. No primary source found settles whether the Information Technology Act 2000 alone allows an electronic bill of lading to operate as a document of title. Sources: - [The Bills of Lading Act, 2025 (Act No. 18 of 2025)](https://www.indiacode.nic.in/bitstream/123456789/21919/1/a2025-18.pdf) — India Code, Legislative Department, Government of India - [Notification S.O. 4720(E) amending the First Schedule to the Information Technology Act, 2000](https://www.cca.gov.in/sites/files/pdf/ACT/SO4720.pdf) — Ministry of Electronics and Information Technology (Controller of Certifying Authorities), Government of India - [Trade Notice No. 24/2025-26: Request for comments on the draft of 'The Digital Trade Facilitation Bill, 2026'](https://content.dgft.gov.in/Website/dgftprod/cb2fc214-b604-4cb8-a924-c3a439ad7a14/Trade%20Notice%2024%20dated%2009.02.2026.pdf) — Directorate General of Foreign Trade, Ministry of Commerce and Industry, Government of India - [Status: UNCITRAL Model Law on Electronic Transferable Records (2017)](https://uncitral.un.org/en/texts/ecommerce/modellaw/electronic_transferable_records/status) — UNCITRAL ### Electronic bills of lading in Japan URL: https://www.ebl.com/law/japan Status: Consultation Instrument: 商法（船荷証券等関係）等の改正に関する要綱 (Outline for Amendment of the Commercial Code (Bills of Lading, etc.) and Related Laws), adopted by the Legislative Council of the Ministry of Justice MLETR-based: Partial Last verified: 16 Oct 2026 Japan has no statute in force giving electronic bills of lading the same effect as paper; reform is at the outline stage. On 9 September 2024 the Legislative Council of the Ministry of Justice adopted an outline for amending the Commercial Code to create electronic bill of lading records, prepared with reference to the UNCITRAL Model Law on Electronic Transferable Records. The Ministry of Justice's tax-reform request for fiscal year 2027 still describes the Commercial Code amendment as planned. As at 16 October 2026, no such bill appears among the cabinet bills of the 221st Diet session (18 February to 25 July 2026) or the 222nd session that opened on 5 October 2026. Scope: The outline would create electronic bill of lading records (電子船荷証券記録) with the same effect as paper bills, using 'control' (支配) and 'provision' (提供) of the record in place of possession and delivery, together with electronic endorsement and conversion between paper and electronic form. Part 2 applies the same approach to multimodal transport documents and warehouse receipts; technical requirements for the systems used are left to a Ministry of Justice ordinance. What remains unclear: No Commercial Code amendment bill had been submitted to the Diet as at 16 October 2026; the status will change if one is introduced. The Legislative Council resolved on 9 September 2024 to report the outline to the Minister of Justice immediately, but the exact date of the report is not published. The technical requirements for qualifying systems are left to a future Ministry of Justice ordinance. Sources: - [部会資料16-1 商法（船荷証券等関係）等の改正に関する要綱案](https://www.moj.go.jp/content/001423391.pdf) — 法務省 (Ministry of Justice) - [法制審議会商法（船荷証券等関係）部会 第16回会議 議事録](https://www.moj.go.jp/content/001438683.pdf) — 法務省 (Ministry of Justice) - [法制審議会第200回会議 議事録（令和6年9月9日）](https://www.moj.go.jp/content/001425711.pdf) — 法務省 (Ministry of Justice) - [令和9年度税制改正要望事項（船荷証券等の電子化に伴う所要の整備）](https://www.mof.go.jp/tax_policy/tax_reform/outline/fy2027/request/moj/09y_moj_k_02.pdf) — 財務省 / 法務省民事局 (Ministry of Finance / Ministry of Justice Civil Affairs Bureau) - [第221回国会 議案の一覧](https://www.shugiin.go.jp/Internet/itdb_gian.nsf/html/gian/kaiji221.htm) — 衆議院 (House of Representatives) - [第222回国会 議案の一覧](https://www.shugiin.go.jp/Internet/itdb_gian.nsf/html/gian/kaiji222.htm) — 衆議院 (House of Representatives) - [国会会期一覧](https://www.shugiin.go.jp/internet/itdb_annai.nsf/html/statics/shiryo/kaiki.htm) — 衆議院 (House of Representatives) - [Status: UNCITRAL Model Law on Electronic Transferable Records (2017)](https://uncitral.un.org/en/texts/ecommerce/modellaw/electronic_transferable_records/status) — UNCITRAL - [法制審議会第194回会議（令和4年2月14日開催）](https://www.moj.go.jp/shingi1/shingi03500043.html) — 法務省 (Ministry of Justice) - [国会提出主要法案 第222回国会（臨時会）](https://www.moj.go.jp/hisho/kouhou/houan222.html) — 法務省 (Ministry of Justice) - [国会提出主要法案 第221回国会（特別会）](https://www.moj.go.jp/hisho/kouhou/houan221.html) — 法務省 (Ministry of Justice) - [法制審議会第200回会議（令和6年9月9日開催）](https://www.moj.go.jp/shingi1/shingi03500044_00004.html) — 法務省 (Ministry of Justice) ### Electronic bills of lading in Morocco URL: https://www.ebl.com/law/morocco Status: No framework Instrument: Loi n° 43-20 relative aux services de confiance pour les transactions électroniques (promulgated by Dahir n° 1-20-100 of 31 December 2020) MLETR-based: No Enacted: 31 Dec 2020 Last verified: 16 Oct 2026 Morocco has no specific law giving electronic bills of lading or other electronic transferable records the same effect as paper. Its general framework is Law 43-20 on trust services for electronic transactions, promulgated on 31 December 2020. Law 43-20 replaced parts of Law 53-05 of 2007 on the electronic exchange of legal data and regulates electronic signatures and related trust services, but not transferability. Morocco is not listed on UNCITRAL's MLETR status page. Scope: Law 43-20 is a general trust-services law. It covers electronic signatures, seals, time-stamps, registered electronic delivery and certificates, and it amends the Code of Obligations and Contracts. It has no provisions on electronic transferable records, exclusive control or the transfer of documents of title such as bills of lading. What remains unclear: Law 43-20 enters into force on publication of its implementing texts in the Bulletin officiel (Art. 84); Decree No. 2-22-687 of 16 November 2022 was published in the Bulletin officiel of 19 January 2023, but the exact in-force date has not been confirmed. No bill or official reform project on electronic transferable records has been identified. It has not been confirmed whether the maritime commerce code of 1919 or the Code of Obligations and Contracts contains any rule affecting electronic bills of lading. Sources: - [Loi n° 43-20 relative aux services de confiance pour les transactions électroniques (Dahir n° 1-20-100 du 31 décembre 2020)](https://adala.justice.gov.ma/api/uploads/2024/03/20/Service%20de%20Confiance%20pour%20les%20transactions%20%C3%A9l%C3%A9ctroniques-1710937527202.pdf) — Ministère de la Justice du Royaume du Maroc (Adala portal) - [Status: UNCITRAL Model Law on Electronic Transferable Records (2017)](https://uncitral.un.org/en/texts/ecommerce/modellaw/electronic_transferable_records/status) — UNCITRAL ### Electronic bills of lading in the Netherlands URL: https://www.ebl.com/law/netherlands Status: In force Instrument: Wet van 1 april 2026 tot wijziging van Boek 8 van het Burgerlijk Wetboek in verband met de invoering van het elektronisch cognossement (Wet invoering elektronisch cognossement), Stb. 2026, 86 MLETR-based: Partial Enacted: 1 Apr 2026 In force since: 1 Jul 2026 Last verified: 16 Oct 2026 The Netherlands gives electronic bills of lading the same legal effect as paper ones under the Act of 1 April 2026 amending Book 8 of the Civil Code (Wet invoering elektronisch cognossement), published in Staatsblad 2026, 86 on 22 April 2026. A Royal Decree of 8 June 2026 brought the Act into force on 1 July 2026. The Act is limited to sea bills of lading; the explanatory memorandum says it follows the UNCITRAL Model Law on Electronic Transferable Records as closely as possible, but the Netherlands is not listed on UNCITRAL's MLETR status page. Scope: Covers electronic bills of lading (elektronisch cognossement) for the carriage of goods by sea only, via new articles 8:400–8:402 of the Civil Code and a conflict-of-laws amendment to article 10:162; the Act applies to bills of lading issued after it entered into force (Article IV). Electronic combined transport (CT) documents, consignment notes, bills of exchange and cheques are not covered; the government deferred CT documents pending international rules and provided for a report on the Act's effects within three years. What remains unclear: The Netherlands does not appear on UNCITRAL's MLETR status page; the 'partial' classification rests on the explanatory memorandum, which says the Act follows the Model Law as far as possible and is limited to sea bills of lading. Electronic combined transport documents may be addressed after the three-year evaluation under Article III. Sources: - [Memorie van toelichting, Kamerstuk 36 743](https://www.eerstekamer.nl/behandeling/20250512/memorie_van_toelichting/document3/f=/vmnd310dhoyt.pdf) — Ministerie van Justitie en Veiligheid / Staten-Generaal - [Wet van 1 april 2026 tot wijziging van Boek 8 van het Burgerlijk Wetboek in verband met de invoering van het elektronisch cognossement (Stb. 2026, 86)](https://zoek.officielebekendmakingen.nl/stb-2026-86.html) — Staatsblad van het Koninkrijk der Nederlanden - [Status: UNCITRAL Model Law on Electronic Transferable Records (2017)](https://uncitral.un.org/en/texts/ecommerce/modellaw/electronic_transferable_records/status) — UNCITRAL - [Besluit van 8 juni 2026 tot vaststelling van het tijdstip van inwerkingtreding van de Wet van 1 april 2026 (Stb. 2026, 140)](https://zoek.officielebekendmakingen.nl/stb-2026-140.html) — Staatsblad van het Koninkrijk der Nederlanden - [36.743 Wet invoering elektronisch cognossement](https://www.eerstekamer.nl/wetsvoorstel/36743_wet_invoering_elektronisch) — Eerste Kamer der Staten-Generaal ### Electronic bills of lading in Paraguay URL: https://www.ebl.com/law/paraguay Status: In force Instrument: Ley N° 6822 de los servicios de confianza para las transacciones electrónicas, del documento electrónico y los documentos transmisibles electrónicos MLETR-based: Yes Enacted: 30 Dec 2021 In force since: 1 May 2022 Last verified: 16 Oct 2026 Paraguay gives electronic transferable documents the same legal effect as paper under Ley N° 6822, promulgated on 30 December 2021 and in force from 1 May 2022; the law covers transferable documents generally and does not name bills of lading. Title IV follows the UNCITRAL Model Law on Electronic Transferable Records: an electronic document satisfies a paper requirement where a reliable method ensures its identification, control and integrity, and control takes the place of possession and its transfer. Paraguay is listed on the UNCITRAL MLETR status page with the year 2021. Unlike the Model Law, signatures on electronic transferable documents must be qualified electronic signatures, and the Ministry of Industry and Commerce is the enforcement authority. Scope: Title IV (arts. 78–95) applies to electronic transferable documents generally: any electronic equivalent of a paper transferable document or title that entitles the holder to claim performance of the obligation it states, which in principle includes bills of lading, bills of exchange and promissory notes (none is listed by name). Article 80 excludes publicly offered securities and other investment instruments. What remains unclear: Articles 87 and 95 require the Ministry of Industry and Commerce to issue rules on reliability and on the supervision and accreditation body for electronic transferable documents; it is not clear whether such rules have been issued beyond Decreto N° 7576/2022. Article 104 sets entry into force four months after promulgation, and the Poder Judicial gives that date as 1 May 2022. Sources: - [Ley Nº 6822 / De los servicios de confianza para las transacciones electrónicas, del documento electrónico y los documentos transmisibles electrónicos](https://www.bacn.gov.py/leyes-paraguayas/10318/ley-n-6822-de-los-servicios-de-confianza-para-las-transacciones-electr-nicas-del-documento-electr-nico-y-los-documentos-transmisibles-electr-nicos) — Biblioteca y Archivo Central del Congreso de la Nación (BACN), Paraguay - [Status: UNCITRAL Model Law on Electronic Transferable Records (2017)](https://uncitral.un.org/en/texts/ecommerce/modellaw/electronic_transferable_records/status) — UNCITRAL - [Desde hoy entra en vigencia Ley N° 6822/21](https://www.pj.gov.py/notas/21950-desde-hoy-entraen-vigencia-ley-n-682221) — Poder Judicial de la República del Paraguay ### Electronic bills of lading in Singapore URL: https://www.ebl.com/law/singapore Status: In force Instrument: Electronic Transactions Act 2010 (as amended by the Electronic Transactions (Amendment) Act 2021) MLETR-based: Yes Enacted: 25 Feb 2021 In force since: 19 Mar 2021 Last verified: 16 Oct 2026 Singapore gives electronic transferable records, including electronic bills of lading, legal effect through Part 2A of the Electronic Transactions Act 2010, inserted by the Electronic Transactions (Amendment) Act 2021. The amendments adopt the UNCITRAL Model Law on Electronic Transferable Records with modifications. Parliament passed the amending Act on 1 February 2021, the President assented on 25 February 2021 and it came into force on 19 March 2021. UNCITRAL lists Singapore (2021) as having adopted legislation based on the Model Law. Scope: Part 2A of the Electronic Transactions Act 2010 (sections 16A to 16S) covers electronic transferable records equivalent to a 'transferable document or instrument', defined as a paper document or instrument entitling the holder to claim performance and to transfer that right by transferring it, expressly including bills of exchange, promissory notes and bills of lading (including those under foreign law). Matters listed in the Act's First Schedule remain excluded under section 4; the 2021 amending Act removed one item from that list. What remains unclear: Division 6 of Part 2A allows regulations on the accreditation of providers of electronic transferable records management systems; whether any have been made is not confirmed here. Some matters remain on the Act's First Schedule exclusion list. Sources: - [Electronic Transactions Act 2010 (2020 Revised Edition, incorporating amendments up to 1 December 2021)](https://sso.agc.gov.sg/Act/ETA2010) — Attorney-General's Chambers, Singapore Statutes Online - [Electronic Transactions (Amendment) Act 2021 (No. 5 of 2021), Government Gazette Acts Supplement No. 6, 12 March 2021](https://sso.agc.gov.sg/Acts-Supp/5-2021/) — Attorney-General's Chambers, Singapore Statutes Online - [Status: UNCITRAL Model Law on Electronic Transferable Records (2017)](https://uncitral.un.org/en/texts/ecommerce/modellaw/electronic_transferable_records/status) — UNCITRAL - [Electronic Transactions Act amended to facilitate transactions, provide convenience & boost trade](https://www.mddi.gov.sg/newsroom/eta-amended-to-facilitate-transactions-provide-convenience-boost-trade/) — Ministry of Digital Development and Information (MCI/IMDA joint release) - [Electronic Transactions (Amendment) Bill (Bill No. 1/2021)](https://www.parliament.gov.sg/docs/default-source/default-document-library/electronic-transactions-(amendment)-bill-1-2021.pdf) — Parliament of Singapore ### Electronic bills of lading in Spain URL: https://www.ebl.com/law/spain Status: In force Instrument: Ley 14/2014, de 24 de julio, de Navegación Marítima MLETR-based: No Enacted: 24 Jul 2014 In force since: 25 Sept 2014 Last verified: 16 Oct 2026 Spain's Maritime Navigation Act (Ley 14/2014 de Navegación Marítima), in force since 25 September 2014, expressly allows electronic bills of lading. Under Articles 262–266, a bill may be issued electronically if shipper and carrier agree in writing before loading, and their contract must set out the issue and transfer system, security and how the holder is identified. Article 264 gives an electronic bill the same regime and effects as a paper one. The regime predates the UNCITRAL MLETR and relies on contract rather than a statutory reliable-system test; Spain is not listed on UNCITRAL's MLETR status page. Scope: Articles 262–266 (Subsection 2, 'Del conocimiento de embarque en soporte electrónico') cover the bill of lading: it may be issued electronically if shipper and carrier agree in writing before loading, and it may be switched between paper and electronic form by written agreement between the lawful holder and the carrier. Article 267 applies the Act's bill of lading rules to multimodal transport documents issued by a carrier; the rules do not reach other transferable documents such as bills of exchange or warehouse receipts. What remains unclear: No Spanish bill, draft or official consultation to implement the UNCITRAL Model Law on Electronic Transferable Records has been identified, and the official BOE record shows no amendment to Articles 262–266 since the Act was passed in 2014. The Act does not settle how the contractual regime applies to later holders who were not parties to the agreement between shipper and carrier. Sources: - [Ley 14/2014, de 24 de julio, de Navegación Marítima (texto consolidado)](https://www.boe.es/buscar/act.php?id=BOE-A-2014-7877) — Agencia Estatal Boletín Oficial del Estado - [Status: UNCITRAL Model Law on Electronic Transferable Records (2017)](https://uncitral.un.org/en/texts/ecommerce/modellaw/electronic_transferable_records/status) — UNCITRAL - [Ley 14/2014, de 24 de julio, de Navegación Marítima — análisis (referencias posteriores)](https://www.boe.es/buscar/doc.php?id=BOE-A-2014-7877) — Agencia Estatal Boletín Oficial del Estado ### Electronic bills of lading in the United Kingdom URL: https://www.ebl.com/law/united-kingdom Status: In force Instrument: Electronic Trade Documents Act 2023 MLETR-based: Partial Enacted: 20 Jul 2023 In force since: 20 Sept 2023 Last verified: 16 Oct 2026 In the United Kingdom, the Electronic Trade Documents Act 2023 gives electronic trade documents, including electronic bills of lading, the same effect as their paper equivalents, provided a reliable system ensures that only one person can control the document at a time. The Act received Royal Assent on 20 July 2023 and came into force on 20 September 2023. It extends to England and Wales, Scotland and Northern Ireland. UNCITRAL lists the United Kingdom (2023) as having legislation influenced by the Model Law on Electronic Transferable Records and the principles on which it is based, rather than enacting it directly. Scope: Covers any electronic equivalent of a paper trade document whose possession is required to claim performance, with listed examples including bills of lading, bills of exchange, promissory notes, ship's delivery orders, warehouse receipts, mate's receipts, marine insurance policies and cargo insurance certificates. The electronic document must be held in a reliable system that ensures exclusive control and transfer; the Act does not apply to documents issued before it came into force. What remains unclear: The Act does not apply to electronic trade documents issued before 20 September 2023. Whether a document that qualifies under the Act is recognised in another country depends on the governing law and the law of that country, not on the Act alone. Sources: - [Electronic Trade Documents Act 2023 (c. 38)](https://www.legislation.gov.uk/ukpga/2023/38/data.htm) — The National Archives (legislation.gov.uk) - [Status: UNCITRAL Model Law on Electronic Transferable Records (2017)](https://uncitral.un.org/en/texts/ecommerce/modellaw/electronic_transferable_records/status) — UNCITRAL - [Electronic Trade Documents Act 2023 (Bill 3344): bill stages](https://bills.parliament.uk/bills/3344) — UK Parliament ### Electronic bills of lading in the United States URL: https://www.ebl.com/law/united-states Status: In force Instrument: Uniform Commercial Code Article 7 (Documents of Title), 2003 revision, as enacted by the states MLETR-based: No Last verified: 16 Oct 2026 In the United States, electronic bills of lading derive legal effect from state law: the 2003 revision of Uniform Commercial Code Article 7, enacted state by state, recognises electronic documents of title and uses 'control' of the electronic record in place of possession of paper. State codes such as those of Nebraska, Ohio and Vermont set out the control test in section 7-106. There is no statute based on the UNCITRAL Model Law on Electronic Transferable Records, and the federal bills of lading statute (49 U.S.C. chapter 801) defines a holder by possession and does not address electronic records. Scope: Revised UCC Article 7, enacted state by state, covers documents of title, including bills of lading and warehouse receipts, in paper or electronic form; section 7-106 sets the test for 'control' of an electronic document of title, which takes the place of possession of a paper document. The federal bills of lading statute (49 U.S.C. chapter 801, sections 80101 et seq.) defines a holder by possession and does not mention electronic records or control. What remains unclear: Revised Article 7 was adopted state by state, so there is no single enactment or in-force date, and a state-by-state list of adoptions has not yet been compiled from primary sources. Several states have since amended section 7-106 (Nebraska Laws 2024, LB94; Vermont Act No. 17 of 2025, effective 1 July 2025; Ohio House Bill 195, effective 6 October 2026), and the effect of these amendments has not yet been reviewed. How federal law on interstate and export bills of lading (49 U.S.C. chapter 801) and the Carriage of Goods by Sea Act apply to electronic bills of lading is not settled by the statutes reviewed. Sources: - [Uniform Commercial Code — Article 7, Documents of Title; 2022 Amendments](https://my.uniformlaws.org/acts/ucc) — Uniform Law Commission - [9A V.S.A. § 7-106. Control of electronic document of title](https://legislature.vermont.gov/statutes/section/09A/007/00106) — Vermont General Assembly - [49 U.S.C. § 80101 Definitions (Bills of Lading)](https://www.govinfo.gov/content/pkg/USCODE-2020-title49/html/USCODE-2020-title49-subtitleX-chap801-sec80101.htm) — U.S. Government Publishing Office - [Status: UNCITRAL Model Law on Electronic Transferable Records (2017)](https://uncitral.un.org/en/texts/ecommerce/modellaw/electronic_transferable_records/status) — UNCITRAL - [Nebraska UCC 7-106. Control of electronic document of title](https://nebraskalegislature.gov/laws/ucc.php?code=7-106) — Nebraska Legislature - [Ohio Revised Code § 1307.106 Control of electronic document of title](https://codes.ohio.gov/ohio-revised-code/section-1307.106) — Ohio Legislative Service Commission - [UCC Article 7, Documents of Title](https://www.uniformlaws.org/committees/community-home?CommunityKey=9893636e-0046-498a-8ed9-3d57c192489a) — Uniform Law Commission ## Electronic bill of lading platforms P&I approved: listed by the International Group of P&I Clubs as an approved eBL system (fully reviewed or deemed approved). DCSA interoperability: Yes = DCSA names the platform, or its approved terms include the DCSA interoperability annex; Partial = it connects to other platforms through its own, non-DCSA arrangements. Legal basis: contractual rulebook, statute, or both. ### AEOTrade-eBL Platform URL: https://www.ebl.com/platforms/aeotrade-ebl Operator: AEOTrade (Beijing) Technology Co., Ltd. Legal basis: not established P&I approved: Yes DCSA interoperability: not established Last verified: 16 Oct 2026 AEOTrade-eBL Platform is an electronic bill of lading system operated by AEOTrade (Beijing) Technology Co., Ltd. It is listed by the International Group of P&I Clubs among its 'deemed approved' systems, under the platform's Terms and Conditions (version 202512). No DCSA interoperability arrangement for the platform was found in DCSA or International Group sources. Sources: - [IG approved electronic bill of lading systems](https://www.igpandi.org/article/ig-approved-electronic-bill-of-lading-systems/) — International Group of P&I Clubs - [Five eBL platforms adopt DCSA Standard Annex v.2 with IGP&I approval, enabling global, cross-platform eBL exchange](https://dcsa.org/newsroom/five-ebl-platforms-adopt-dcsa-interoperability-annex) — Digital Container Shipping Association (DCSA) - [Electronic Bills of Lading: Notification of New Process](https://www.igpandi.org/article/electronic-bills-of-lading-notification-of-new-process/) — International Group of P&I Clubs - [IMDA's TradeTrust Steps Up Efforts to Accelerate Global Digital Trade Transformation](https://www.imda.gov.sg/resources/press-releases-factsheets-and-speeches/press-releases/2026/imda-tradetrust-steps-up-efforts) — Infocomm Media Development Authority (IMDA), Singapore ### BlockPeer Trade URL: https://www.ebl.com/platforms/blockpeer-trade Operator: BlockPeer Technologies, Inc. Legal basis: not established P&I approved: Yes DCSA interoperability: not established Last verified: 16 Oct 2026 BlockPeer Trade is an electronic bill of lading system operated by BlockPeer Technologies, Inc., a company registered in Delaware, United States. It is listed by the International Group of P&I Clubs among its 'deemed approved' systems, under the BlockPeer eBL Platform terms and conditions dated 26 June 2025 (version 2). No DCSA interoperability arrangement for the platform was found in DCSA or International Group sources. Sources: - [IG approved electronic bill of lading systems](https://www.igpandi.org/article/ig-approved-electronic-bill-of-lading-systems/) — International Group of P&I Clubs - [LEI record 9845000P44AD0914XE12 — BLOCKPEER TECHNOLOGIES, INC.](https://api.gleif.org/api/v1/lei-records/9845000P44AD0914XE12) — Global Legal Entity Identifier Foundation (GLEIF) - [Electronic Bills of Lading: Notification of New Process](https://www.igpandi.org/article/electronic-bills-of-lading-notification-of-new-process/) — International Group of P&I Clubs - [IMDA's TradeTrust Steps Up Efforts to Accelerate Global Digital Trade Transformation](https://www.imda.gov.sg/resources/press-releases-factsheets-and-speeches/press-releases/2026/imda-tradetrust-steps-up-efforts) — Infocomm Media Development Authority (IMDA), Singapore ### The Bolero System URL: https://www.ebl.com/platforms/bolero Operator: Bolero International Ltd Headquarters: London, United Kingdom Legal basis: Contractual rulebook P&I approved: Yes DCSA interoperability: not established Website: https://www.bolero.net/bolero-ebl-as-a-service/ Last verified: 16 Oct 2026 The Bolero System is an electronic bill of lading system operated by Bolero International Ltd, a UK company with its head office in London. Legal effect rests on the Bolero Rulebook, a multilateral contract governed by English law that users accept, with a Title Registry recording the holder of each Bolero bill of lading. The system is on the International Group of P&I Clubs' list of approved systems; as at 16 October 2026, neither DCSA nor the International Group lists it as using the DCSA interoperability annex. Sources: - [IG approved electronic bill of lading systems](https://www.igpandi.org/article/ig-approved-electronic-bill-of-lading-systems/) — International Group of P&I Clubs - [Contact us | Bolero](https://www.bolero.net/contact/) — Bolero International Ltd - [Bolero Rulebook & Title Registry Record in Trade Transactions](https://www.bolero.net/rulebook-and-title-registry/) — Bolero International Ltd - [Bolero Rulebook (First Edition, September 1999)](https://www.cargowise.com/media/k5hpl0m2/bolero-rulebook.pdf) — Bolero International Ltd (copy hosted on cargowise.com) - [Five eBL platforms adopt DCSA Standard Annex v.2 with IGP&I approval, enabling global, cross-platform eBL exchange](https://dcsa.org/newsroom/five-ebl-platforms-adopt-dcsa-interoperability-annex) — Digital Container Shipping Association (DCSA) - [BOLERO INTERNATIONAL LIMITED overview (company 03523400)](https://find-and-update.company-information.service.gov.uk/company/03523400) — Companies House (UK) - [Electronic Bills of Lading (Galileo eBL)](https://www.bolero.net/bolero-ebl-as-a-service/) — Bolero International Ltd ### BRITC eBL URL: https://www.ebl.com/platforms/britc-ebl Operator: BRITC ETRADE SOLUTION CO., Ltd Legal basis: not established P&I approved: Yes DCSA interoperability: not established Last verified: 16 Oct 2026 BRITC eBL is an electronic bill of lading system provided by BRITC ETRADE SOLUTION CO., Ltd. The International Group of P&I Clubs lists it as an approved system under the BRITC eBL Terms and Conditions and a Contract of Use, both version 1.01 dated March 2024. As at 16 October 2026, neither DCSA nor the International Group lists it as using the DCSA interoperability annex. Sources: - [IG approved electronic bill of lading systems](https://www.igpandi.org/article/ig-approved-electronic-bill-of-lading-systems/) — International Group of P&I Clubs - [Five eBL platforms adopt DCSA Standard Annex v.2 with IGP&I approval, enabling global, cross-platform eBL exchange](https://dcsa.org/newsroom/five-ebl-platforms-adopt-dcsa-interoperability-annex) — Digital Container Shipping Association (DCSA) ### CargoX URL: https://www.ebl.com/platforms/cargox Operator: CargoX, poslovne rešitve in svetovanje d.o.o. Headquarters: Ljubljana, Slovenia Launched: 2018 Legal basis: Contractual rulebook P&I approved: Yes DCSA interoperability: Yes Pricing model: Subscription plans and prepaid usage units; price list available only after registration Website: https://cargox.io/electronic-bill-of-lading-software Last verified: 16 Oct 2026 CargoX is an electronic trade document platform, including electronic bills of lading, operated by CargoX d.o.o. (CargoX Ltd.) of Ljubljana, Slovenia. Legal effect rests on CargoX's Special Terms and Conditions for eBLs, a user agreement accepted by the issuing user and each subsequent user; version 1, dated 10 February 2020, is governed by English law. The International Group of P&I Clubs lists it as an approved system, and on 4 June 2026 DCSA named it among five platforms that had implemented the DCSA Standard Annex for eBL Platform Interoperability v.2. Sources: - [IG approved electronic bill of lading systems](https://www.igpandi.org/article/ig-approved-electronic-bill-of-lading-systems/) — International Group of P&I Clubs - [Five eBL platforms adopt DCSA Standard Annex v.2 with IGP&I approval, enabling global, cross-platform eBL exchange](https://dcsa.org/newsroom/five-ebl-platforms-adopt-dcsa-interoperability-annex) — Digital Container Shipping Association (DCSA) - [About CargoX (company details)](https://cargox.io/company) — CargoX d.o.o. - [CargoX Blockchain Based Smart Bill of Lading Solutions Special Terms and Conditions 1.0](https://www.skuld.com/contentassets/9570cd183e8d4cdca6a52bced54f8002/cargox_special_terms_conditions_v1_10_february_2020.pdf) — CargoX d.o.o. (copy hosted by Skuld) - [CargoX terms and conditions (General Terms and Conditions, effective 6 July 2025)](https://cargox.io/terms-and-conditions) — CargoX d.o.o. - [CargoX Platform adopts new DCSA standard recently approved by IG P&I in major leap forward for shipping digitalisation with eBL interoperability](https://cargox.io/content-hub/cargox-platform-adopts-new-dcsa-standard-recently-approved-by-ig-pandi-in-major-l) — CargoX d.o.o. - [Electronic bill of lading software](https://cargox.io/electronic-bill-of-lading-software) — CargoX d.o.o. ### ChainDoX (CDX) URL: https://www.ebl.com/platforms/chaindox Operator: ChainDoX Pte Pty Legal basis: not established P&I approved: Yes DCSA interoperability: not established Website: https://chaindox.com/ Last verified: 16 Oct 2026 ChainDoX (CDX) is a trade document platform built on the XDC blockchain that issues electronic transferable records, including electronic bills of lading. The International Group of P&I Clubs lists it among its 'deemed approved' systems under the provider name 'ChainDoX Pte Pty' and the ChainDoX terms and conditions. No DCSA interoperability arrangement for the platform was found in DCSA or International Group sources. Sources: - [IG approved electronic bill of lading systems](https://www.igpandi.org/article/ig-approved-electronic-bill-of-lading-systems/) — International Group of P&I Clubs - [ChainDoX — Making Trade Documents Digital](https://chaindox.com/) — ChainDoX - [Electronic Bills of Lading: Notification of New Process](https://www.igpandi.org/article/electronic-bills-of-lading-notification-of-new-process/) — International Group of P&I Clubs ### Covantis eBL powered by Secro URL: https://www.ebl.com/platforms/covantis Operator: Covantis SA Headquarters: Geneva, Switzerland Launched: 2025 Legal basis: not established P&I approved: Yes DCSA interoperability: not established Website: https://covantis.io/ebl/ Last verified: 16 Oct 2026 Covantis eBL powered by Secro is an electronic bill of lading service for agricultural commodity trade, operated by Covantis SA of Geneva, Switzerland, in partnership with Secro Inc.; Covantis announced its launch on 5 February 2025. The International Group of P&I Clubs lists it as an approved system under the Covantis Service Agreement, amendment agreement and General Terms and Conditions (versions dated 15 October 2024 and 12 February 2025) and a Covantis Interoperability Annex (v.20250603). As at 16 October 2026, DCSA does not name it among platforms that have implemented the DCSA Standard Annex for eBL Platform Interoperability. Sources: - [IG approved electronic bill of lading systems](https://www.igpandi.org/article/ig-approved-electronic-bill-of-lading-systems/) — International Group of P&I Clubs - [Privacy notice - Covantis](https://covantis.io/privacy-notice/) — Covantis SA - [Covantis and Secro Announce Partnership to enable the transition from paper to electronic documents for the Agri industry.](https://covantis.io/covantis-and-secro-announce-partnership-to-enable-the-transition-from-paper-to-electronic-documents-for-the-agri-industry/) — Covantis SA - [Five eBL platforms adopt DCSA Standard Annex v.2 with IGP&I approval, enabling global, cross-platform eBL exchange](https://dcsa.org/newsroom/five-ebl-platforms-adopt-dcsa-interoperability-annex) — Digital Container Shipping Association (DCSA) - [Upcoming Covantis eBL has been Approved by the International Group of P&I Clubs](https://covantis.io/upcoming-covantis-ebl-has-been-approved-by-the-international-group-of-pi-clubs/) — Covantis SA - [eBL - Covantis](https://covantis.io/ebl/) — Covantis SA - [Contact us - Covantis](https://covantis.io/contact-us/) — Covantis SA ### Credore URL: https://www.ebl.com/platforms/credore Operator: Trustless Private Limited Headquarters: Pune, India Legal basis: not established P&I approved: Yes DCSA interoperability: not established Website: https://credore.xyz/ Last verified: 16 Oct 2026 Credore is an electronic trade document platform, including electronic bills of lading, operated by Trustless Private Limited, a company incorporated in India. The International Group of P&I Clubs lists it among its 'deemed approved' systems, with two versions of its eBL terms and conditions titled 'Singapore Law' and 'English Law / UK ETDA'. No DCSA interoperability arrangement for the platform was found in DCSA or International Group sources. Sources: - [IG approved electronic bill of lading systems](https://www.igpandi.org/article/ig-approved-electronic-bill-of-lading-systems/) — International Group of P&I Clubs - [Credore Terms of Use](https://credore.xyz/assets/files/Credore-Terms-Of-Use.pdf) — Trustless Private Limited (Credore) - [Five eBL platforms adopt DCSA Standard Annex v.2 with IGP&I approval, enabling global, cross-platform eBL exchange](https://dcsa.org/newsroom/five-ebl-platforms-adopt-dcsa-interoperability-annex) — Digital Container Shipping Association (DCSA) - [Offerings Overview](https://credore.xyz/offerings_overview) — Trustless Private Limited (Credore) - [Electronic Bills of Lading: Notification of New Process](https://www.igpandi.org/article/electronic-bills-of-lading-notification-of-new-process/) — International Group of P&I Clubs - [IMDA's TradeTrust Steps Up Efforts to Accelerate Global Digital Trade Transformation](https://www.imda.gov.sg/resources/press-releases-factsheets-and-speeches/press-releases/2026/imda-tradetrust-steps-up-efforts) — Infocomm Media Development Authority (IMDA), Singapore - [Welcome to Credore - Revolutionary Fintech Transforming Financial Supply Chain Management with Blockchain Technology](https://credore.xyz/) — Trustless Private Limited (Credore) ### DocuTrade URL: https://www.ebl.com/platforms/docutrade Operator: Yodaplus Technologies Pvt. Ltd Headquarters: Mumbai, India Legal basis: not established P&I approved: Yes DCSA interoperability: not established Website: https://www.docutrade.io/ Last verified: 16 Oct 2026 DocuTrade is a blockchain-based platform for electronic trade documents, including bills of lading, operated by Yodaplus Technologies Private Limited of Mumbai, India. The International Group of P&I Clubs lists it among its approved systems, on the DocuTrade terms and conditions of October 2025. DocuTrade was not among the five platforms DCSA named on 4 June 2026 as having implemented the DCSA Standard Annex. Sources: - [IG approved electronic bill of lading systems](https://www.igpandi.org/article/ig-approved-electronic-bill-of-lading-systems/) — International Group of P&I Clubs - [Five eBL platforms adopt DCSA Standard Annex v.2 with IGP&I approval, enabling global, cross-platform eBL exchange](https://dcsa.org/newsroom/five-ebl-platforms-adopt-dcsa-interoperability-annex) — Digital Container Shipping Association (DCSA) - [Yodaplus DocuTrade - Transforming Trade Finance with MLETR-Compliant Documentation](https://www.docutrade.io/) — Yodaplus Technologies Private Limited - [Contact - Yodaplus](https://yodaplus.com/contact.html) — Yodaplus Technologies Private Limited ### e-title URL: https://www.ebl.com/platforms/e-title Operator: E-Title Authority Pte Ltd Headquarters: Singapore, Singapore Legal basis: Contractual rulebook P&I approved: Yes DCSA interoperability: not established Website: https://www.e-title.net/ Last verified: 16 Oct 2026 e-title is a peer-to-peer system for creating and transferring electronic title documents, including bills of lading, operated by E-Title Authority Pte Ltd of Singapore. Its legal effect rests on the Electronic Title User Agreement, a multilateral private contract based on English common law that all users sign. The International Group of P&I Clubs lists it as an approved system; as at 16 October 2026, DCSA does not name it among platforms that have implemented the DCSA Standard Annex for eBL Platform Interoperability. Sources: - [IG approved electronic bill of lading systems](https://www.igpandi.org/article/ig-approved-electronic-bill-of-lading-systems/) — International Group of P&I Clubs - [What is e-title?](https://www.e-title.net/sol_what.php) — E-Title Authority Pte Ltd - [Electronic Title User Agreement](https://www.e-title.net/etug_agreement.php) — E-Title Authority Pte Ltd - [Five eBL platforms adopt DCSA Standard Annex v.2 with IGP&I approval, enabling global, cross-platform eBL exchange](https://dcsa.org/newsroom/five-ebl-platforms-adopt-dcsa-interoperability-annex) — Digital Container Shipping Association (DCSA) - [Circular 05/22: Paperless Trading Electronic Trading Systems Update to E-TITLE – cancellation of R3 ownership](https://www.ukpandi.com/news-and-resources/circulars/article/club-circulars/2022/circular-05-22-paperless-trading-electronic-trading-systems-update-to-e-title-cancellation-of-r3-ownership/) — UK P&I Club - [What does the Electronic Title User Group do?](https://www.e-title.net/etug_what.php) — E-Title Authority Pte Ltd - [Contact Us](https://www.e-title.net/co_contact.php) — E-Title Authority Pte Ltd ### edoxOnline URL: https://www.ebl.com/platforms/edoxonline Operator: Global Share S.A. Legal basis: Contractual rulebook P&I approved: Yes DCSA interoperability: Yes Website: https://web.edoxonline.com/index.php/ebl/ Last verified: 16 Oct 2026 edoxOnline is a web-based trade documentation platform with an electronic bill of lading module, operated by Global Share S.A. The eBL module is governed by the e-BL Terms and Conditions for edoxOnline, which the International Group of P&I Clubs first approved in June 2019 and now lists together with the DCSA Standard Annex for eBL Platform Interoperability v.2. On 4 June 2026 DCSA named edoxOnline among five platforms that had implemented that annex. Sources: - [IG approved electronic bill of lading systems](https://www.igpandi.org/article/ig-approved-electronic-bill-of-lading-systems/) — International Group of P&I Clubs - [Circular No. 18/19: Electronic (paperless) trading: Electronic Shipping Solutions, Bolero International Ltd, E-Title Authority Pte Ltd, Global Share S.A. (edoxOnline platform)](https://www.American-Club.com/files/files/cir_18_19.pdf) — American Steamship Owners Mutual Protection and Indemnity Association (American Club), member of the International Group of P&I Clubs - [edoxOnline Terms and Conditions – Privacy Policy (Version 1.0)](https://web.edoxonline.com/wp-content/uploads/Terms-and-Conditions.pdf) — Global Share S.A. - [eBL - edoxOnline](https://web.edoxonline.com/index.php/ebl/) — Global Share S.A. (edoxOnline) - [Five eBL platforms adopt DCSA Standard Annex v.2 with IGP&I approval, enabling global, cross-platform eBL exchange](https://dcsa.org/newsroom/five-ebl-platforms-adopt-dcsa-interoperability-annex) — Digital Container Shipping Association (DCSA) - [The International Group of P&I Clubs (IGP&I) has recently approved edoxOnline's electronic Bill of Lading (eBL) legal framework for interoperability](https://web.edoxonline.com/index.php/2025/04/03/edoxonline-igpi-approved-ebl/) — Global Share S.A. (edoxOnline) ### eTEU eBL Platform URL: https://www.ebl.com/platforms/eteu Operator: eTEU Technologies Ltd Headquarters: London, United Kingdom Legal basis: Contractual rulebook P&I approved: Yes DCSA interoperability: Yes Pricing model: Per-eBL price in tiered packages; Enterprise package adds a customised monthly subscription fee Website: https://eteu.co.uk/ Last verified: 16 Oct 2026 The eTEU eBL Platform is an electronic bill of lading system operated by eTEU Technologies Ltd, a company with its registered office in London, United Kingdom. Its legal effect rests on the platform's terms and conditions, a multiparty contract between the operator and all users; the published 7 September 2023 edition is governed by the laws of England and Wales. The International Group of P&I Clubs lists it as an approved system, and on 4 June 2026 DCSA named it among five platforms that had implemented the DCSA Standard Annex for eBL Platform Interoperability v.2. Sources: - [IG approved electronic bill of lading systems](https://www.igpandi.org/article/ig-approved-electronic-bill-of-lading-systems/) — International Group of P&I Clubs - [eTEU eBL Platform Terms & Conditions – 7 September 2023 Edition](https://eteu.co.uk/wp-content/uploads/2023/12/eTEU-TCs-7-September-2023-24.pdf) — eTEU Technologies Ltd - [ETEU TECHNOLOGIES LTD – company overview (company number 11739946)](https://find-and-update.company-information.service.gov.uk/company/11739946) — Companies House (UK) - [Five eBL platforms adopt DCSA Standard Annex v.2 with IGP&I approval, enabling global, cross-platform eBL exchange](https://dcsa.org/newsroom/five-ebl-platforms-adopt-dcsa-interoperability-annex) — Digital Container Shipping Association (DCSA) - [Privacy Policy | eTEU](https://eteu.co.uk/legal/) — eTEU Technologies Ltd - [eTEU - Shipping the way it should be done in the 21st century](https://eteu.co.uk/) — eTEU Technologies Ltd - [Platform Pricing | eTEU](https://eteu.co.uk/fees/) — eTEU Technologies Ltd ### ICE CargoDocs URL: https://www.ebl.com/platforms/ice-cargodocs Operator: ICE Digital Trade (formerly essDOCS) Legal basis: Rulebook and statute P&I approved: Yes DCSA interoperability: Partial Pricing model: Charged to exporters and banks via pay-as-you-go or annual prepaid packages Website: https://www.essdocs.com/solutions/ice-cargodocs Last verified: 16 Oct 2026 ICE CargoDocs, formerly DocEx, is an electronic title document system operated by ICE Digital Trade, formerly essDOCS, part of Intercontinental Exchange. Its eBLs take legal effect either under the multilateral Databridge Services & Users Agreement (DSUA) or, since an IG approval announced on 10 November 2023, under the law of a jurisdiction that recognises eBLs, such as the UK Electronic Trade Documents Act 2023. The International Group of P&I Clubs lists it as an approved system; its interoperability with IQAX eBL, live since 19 March 2025, rests on a bilateral liability agreement rather than the DCSA Standard Annex. Sources: - [IG approved electronic bill of lading systems](https://www.igpandi.org/article/ig-approved-electronic-bill-of-lading-systems/) — International Group of P&I Clubs - [Legal Framework & DSUA | ICE Digital Trade](https://www.essdocs.com/dsua-legal-framework) — ICE Digital Trade - [ICE Digital Trade](https://www.ice.com/about/exchanges-clearing/digital-trade) — Intercontinental Exchange, Inc. - [ICE CargoDocs | ICE Digital Trade](https://www.essdocs.com/solutions/ice-cargodocs) — ICE Digital Trade - [eBL Interoperability | ICE Digital Trade](https://www.essdocs.com/ebl-platform-interoperability) — ICE Digital Trade - [Cross-Platform eBLs become a reality as OOCL and a major oil and gas company go live](https://www.essdocs.com/press-room/cross-platform-ebls-become-reality-oocl-and-major-oil-and-gas-company-go-live) — ICE Digital Trade - [Five eBL platforms adopt DCSA Standard Annex v.2 with IGP&I approval, enabling global, cross-platform eBL exchange](https://dcsa.org/newsroom/five-ebl-platforms-adopt-dcsa-interoperability-annex) — Digital Container Shipping Association (DCSA) ### IQAX eBL URL: https://www.ebl.com/platforms/iqax-ebl Operator: IQAX Limited Legal basis: Rulebook and statute P&I approved: Yes DCSA interoperability: Partial Pricing model: Currently charged to carriers only; other users pay no platform fee Website: https://www.iqax.com/en/solutions/ebl/ Last verified: 16 Oct 2026 IQAX eBL is an electronic bill of lading platform built on the GSBN blockchain and operated by IQAX Limited. Its service terms, governed by English law, cover both contract-based eBLs, whose effect rests on the terms agreed by all users, and law-enabled eBLs recognised under statutes such as the UK Electronic Trade Documents Act 2023. The International Group of P&I Clubs lists it as an approved system; its interoperability, including with ICE CargoDocs since 19 March 2025, rests on IQAX's own interoperable addendum and bilateral or multilateral platform agreements rather than the DCSA Standard Annex. Sources: - [IG approved electronic bill of lading systems](https://www.igpandi.org/article/ig-approved-electronic-bill-of-lading-systems/) — International Group of P&I Clubs - [IQAX eBL Service Terms and Conditions with Interoperable addendum (T&C V.2, 11 December 2025; Interoperable Addendum V.2, 11 February 2026)](https://www.iqax.com/ebl_tc.pdf) — IQAX Limited - [Cross-Platform eBLs become a reality as OOCL and a major oil and gas company go live](https://www.essdocs.com/press-room/cross-platform-ebls-become-reality-oocl-and-major-oil-and-gas-company-go-live) — ICE Digital Trade - [IQAX eBL FAQs](https://www.iqax.com/en/solutions/iqax-ebl-faqs/) — IQAX Limited - [eBL Solutions | Blockchain-Based Bill of Lading - IQAX](https://www.iqax.com/en/solutions/ebl/) — IQAX Limited - [Five eBL platforms adopt DCSA Standard Annex v.2 with IGP&I approval, enabling global, cross-platform eBL exchange](https://dcsa.org/newsroom/five-ebl-platforms-adopt-dcsa-interoperability-annex) — Digital Container Shipping Association (DCSA) ### Portalis - Trade and eBL Infrastructure URL: https://www.ebl.com/platforms/portalis Operator: Incubatrix Ltd Legal basis: not established P&I approved: Yes DCSA interoperability: not established Last verified: 16 Oct 2026 Portalis - Trade and eBL Infrastructure is an electronic bill of lading system operated by Incubatrix Ltd under the Portalis Rulebook, which Incubatrix issues and maintains as system provider. The International Group of P&I Clubs lists it among systems 'deemed approved' because they permit only eBLs subject to a governing law that recognises them as equivalent to paper bills of lading. DCSA's interoperability pages do not name it (checked 16 October 2026). Sources: - [IG approved electronic bill of lading systems](https://www.igpandi.org/article/ig-approved-electronic-bill-of-lading-systems/) — International Group of P&I Clubs - [Five eBL platforms adopt DCSA Standard Annex v.2 with IGP&I approval, enabling global, cross-platform eBL exchange](https://dcsa.org/newsroom/five-ebl-platforms-adopt-dcsa-interoperability-annex) — Digital Container Shipping Association (DCSA) - [Electronic Bills of Lading: Notification of New Process](https://www.igpandi.org/article/electronic-bills-of-lading-notification-of-new-process/) — International Group of P&I Clubs ### Secro URL: https://www.ebl.com/platforms/secro Operator: Secro Inc. Legal basis: Rulebook and statute P&I approved: Yes DCSA interoperability: not established Website: https://secro.io/ Last verified: 16 Oct 2026 Secro is a software-as-a-service platform for electronic trade documents, including bills of lading, operated by Secro Inc. Its eBLs are issued under a Customer and User Agreement, with standard e-bills governed either by Singapore law, including the Electronic Transactions (Amendment) Act 2021, or by English law and the Electronic Trade Documents Act 2023. The International Group of P&I Clubs first approved Secro in 2022, and its approved Secro terms include a Secro Interoperability Annex (v.20250603); Secro was not among the five platforms DCSA named on 4 June 2026 as having implemented the DCSA Standard Annex. Sources: - [IG approved electronic bill of lading systems](https://www.igpandi.org/article/ig-approved-electronic-bill-of-lading-systems/) — International Group of P&I Clubs - [Five eBL platforms adopt DCSA Standard Annex v.2 with IGP&I approval, enabling global, cross-platform eBL exchange](https://dcsa.org/newsroom/five-ebl-platforms-adopt-dcsa-interoperability-annex) — Digital Container Shipping Association (DCSA) - [SECRO - Frictionless Global Trade - SECRO](https://secro.io/) — Secro Inc. - [Circular No. 30/22: Electronic (paperless) trading: ... and Secro Inc. (Secro)](https://www.American-Club.com/files/files/cir_30_22.pdf) — American Steamship Owners Mutual Protection and Indemnity Association (American Club), member of the International Group of P&I Clubs - [Circular No. 21/23: Electronic (paperless) trading – update to Secro terms and conditions](https://www.American-Club.com/files/files/cir_21_23.pdf) — American Steamship Owners Mutual Protection and Indemnity Association (American Club), member of the International Group of P&I Clubs ### SGTraDex eBL solution URL: https://www.ebl.com/platforms/sgtradex-ebl Operator: DEX Digital Technologies Pte. Ltd Legal basis: not established P&I approved: Yes DCSA interoperability: Partial Website: https://sgtradex.com/ Last verified: 16 Oct 2026 The SGTraDex eBL solution is an electronic bill of lading service on the Singapore Trade Data Exchange (SGTraDex), operated, according to the International Group of P&I Clubs, by DEX Digital Technologies Pte. Ltd under the SGTraDex Wallet Terms and Conditions and eBL Additional Terms and Conditions. The International Group lists it among systems 'deemed approved' because they permit only eBLs subject to a governing law that recognises them as equivalent to paper bills of lading. DCSA's interoperability pages do not name it; on 25 November 2025 SGTraDex reported a live cross-platform exchange of eBLs with AEOTrade using IMDA's TradeTrust framework. Sources: - [IG approved electronic bill of lading systems](https://www.igpandi.org/article/ig-approved-electronic-bill-of-lading-systems/) — International Group of P&I Clubs - [SGTraDex and IMDA Receive Pro-Enterprise Impact & Partnership Award for Interoperable Digital Documents Against Payment Trade Cooperation (media release)](https://sgtradex.com/files/PEP-SBF%20Awards%20-%202025-11-25%20-%20FOR%20DISSEMINATION.pdf) — SGTraDex - [Five eBL platforms adopt DCSA Standard Annex v.2 with IGP&I approval, enabling global, cross-platform eBL exchange](https://dcsa.org/newsroom/five-ebl-platforms-adopt-dcsa-interoperability-annex) — Digital Container Shipping Association (DCSA) - [Electronic Bills of Lading: Notification of New Process](https://www.igpandi.org/article/electronic-bills-of-lading-notification-of-new-process/) — International Group of P&I Clubs - [TradeTrust Newsletter January 2026](https://www.tradetrust.io/happenings-and-resources/tradetrust-newsletter-january-2026/) — Infocomm Media Development Authority (IMDA), Singapore - [SGTraDex (official website)](https://sgtradex.com/) — SGTraDex - [SGTraDex and TradeGo Establishes Long-Term Strategic Partnership to Broaden Cross-Border Exchange of Electronic Bills of Lading (eBLs)](https://sgtradex.com/images/pdf/SGTD_X_TradeGo_MoU_Media_Release-_FOR_DISSEMINATION_.pdf) — SGTraDex ### trace:original URL: https://www.ebl.com/platforms/trace-original Operator: Enigio AB Headquarters: Stockholm, Sweden Legal basis: not established P&I approved: Yes DCSA interoperability: Yes Pricing model: Monthly document-package or enterprise subscriptions; per-document option; receiving parties need no subscription Website: https://enigio.com/use-cases/bill-of-lading/ Last verified: 16 Oct 2026 trace:original is a system for creating and transferring electronic original documents, including electronic bills of lading, operated by Enigio AB of Stockholm, Sweden. Enigio states that the system is designed to comply with the UNCITRAL Model Law on Electronic Transferable Records (MLETR) and national laws based on it. The International Group of P&I Clubs lists it as an approved system under Enigio's 2026 SaaS terms and conditions, terms of use and Standard Annex, together with the DCSA Standard Annex for eBL Platform Interoperability v.2. Sources: - [IG approved electronic bill of lading systems](https://www.igpandi.org/article/ig-approved-electronic-bill-of-lading-systems/) — International Group of P&I Clubs - [Contact Enigio: Digital trade support & solutions](https://enigio.com/company/contact/) — Enigio AB - [trace:original – Online Purchase Terms (effective 27 June 2025)](https://enigio.com/online-purchase-terms/) — Enigio AB - [trace:original terms of use](https://enigio.com/traceoriginal-terms-of-use/) — Enigio AB - [IG P&I approves trace:original eB/L](https://enigio.com/news/ig-pi-approves-traceoriginal-eb-l/) — Enigio AB - [Electronic bills of lading (eBL): Benefits, compliance & use cases](https://enigio.com/use-cases/bill-of-lading/) — Enigio AB - [Enigio launches the first self-serve online channel for digital original trade documents](https://enigio.com/news/enigio-launches-self-serve-digital-originals-subscription/) — Enigio AB ### TradeGo eBL URL: https://www.ebl.com/platforms/tradego Operator: TradeGo PTE. LTD Legal basis: not established P&I approved: Yes DCSA interoperability: Yes Website: https://www.tradego.com/en/solution/tradedocs Last verified: 16 Oct 2026 TradeGo eBL is an electronic bill of lading system operated by TradeGo Pte. Ltd., a Singapore company, and offered through its TradeDocs service. According to TradeGo, legal effect rests on the TradeGo User Agreement; the second version, dated 12 June 2024, allows interoperable transfers only for eBLs subject to laws that recognise them as equivalent to paper bills. The International Group of P&I Clubs approved the system in January 2023, and on 4 June 2026 DCSA named TradeGo among five platforms that have implemented the DCSA Standard Annex for eBL Platform Interoperability v.2. Sources: - [IG approved electronic bill of lading systems](https://www.igpandi.org/article/ig-approved-electronic-bill-of-lading-systems/) — International Group of P&I Clubs - [Five eBL platforms adopt DCSA Standard Annex v.2 with IGP&I approval, enabling global, cross-platform eBL exchange](https://dcsa.org/newsroom/five-ebl-platforms-adopt-dcsa-interoperability-annex) — Digital Container Shipping Association (DCSA) - [Circular 01/23: Electronic (Paperless) Trading ... TradeGo PTE. LTD (TradeGo eBL)](https://ukpandi.com/fileadmin/uploads/ukpandi/Documents/uk-p-i-club/circulars/2023/uk-circular-01-23.pdf) — UK P&I Club, member of the International Group of P&I Clubs - [8/2024: Electronic (Paperless) Trading – TradeGo PTE. LTD (TradeGo eBL): Approval of second version of TradeGo User Agreement (2024.06.12)](https://gard.no/en/circulars/8-2024-electronic-paperless-trading/) — Gard AS, member of the International Group of P&I Clubs - [TradeDocs - TradeGo](https://www.tradego.com/en/solution/tradedocs) — TradeGo Pte. Ltd. - [TradeGo and WaveBL Launch Bilateral eBL Interoperability](https://www.tradego.com/en/new/company-news/30) — TradeGo Pte. Ltd. ### TradeTrust URL: https://www.ebl.com/platforms/tradetrust Operator: Infocomm Media Development Authority (IMDA), Singapore Headquarters: Singapore Launched: 2019 Legal basis: Statute (MLETR-type law) P&I approved: No DCSA interoperability: Partial Pricing model: Free to use; blockchain transaction fees and third-party integration or subscription costs may apply Website: https://www.tradetrust.io/ Last verified: 16 Oct 2026 TradeTrust is a framework rather than a single eBL platform: a set of standards, model legal terms and open-source software, launched in 2019 by Singapore's Infocomm Media Development Authority (IMDA), that other platforms integrate to issue, verify and transfer electronic trade documents, including bills of lading. Its eBLs are designed to rely on statutes aligned with the UNCITRAL Model Law on Electronic Transferable Records (MLETR), such as Singapore's Electronic Transactions Act as amended in 2021, rather than on a common contractual rulebook. TradeTrust itself is not listed on the International Group of P&I Clubs' approved-systems page and is not named on DCSA's interoperability pages; it uses its own model for moving eBLs between platforms. Sources: - [Who We Are | TradeTrust](https://www.tradetrust.io/about/who-we-are/) — Infocomm Media Development Authority (IMDA), Singapore - [Legality Guide | TradeTrust](https://www.tradetrust.io/about/legality-guide/) — Infocomm Media Development Authority (IMDA), Singapore - [IG approved electronic bill of lading systems](https://www.igpandi.org/article/ig-approved-electronic-bill-of-lading-systems/) — International Group of P&I Clubs - [Five eBL platforms adopt DCSA Standard Annex v.2 with IGP&I approval, enabling global, cross-platform eBL exchange](https://dcsa.org/newsroom/five-ebl-platforms-adopt-dcsa-interoperability-annex) — Digital Container Shipping Association (DCSA) - [Terms of Use | TradeTrust](https://www.tradetrust.io/terms-of-use/) — Infocomm Media Development Authority (IMDA), Singapore - [TradeTrust (official website)](https://www.tradetrust.io/) — Infocomm Media Development Authority (IMDA), Singapore - [What Is TradeTrust | TradeTrust](https://www.tradetrust.io/about/what-is-tradetrust/) — Infocomm Media Development Authority (IMDA), Singapore - [Break the eBL silos: Why interoperability is the missing link in digital trade](https://www.tradetrust.io/happenings-and-resources/break-the-ebl-silos-why-interoperability-is-the-missing-link-in-digital-trade/) — Infocomm Media Development Authority (IMDA), Singapore - [SGTraDex and IMDA Receive Pro-Enterprise Impact & Partnership Award for Interoperable Digital Documents Against Payment Trade Cooperation (media release)](https://sgtradex.com/files/PEP-SBF%20Awards%20-%202025-11-25%20-%20FOR%20DISSEMINATION.pdf) — SGTraDex ### uLogisHub eBL platform URL: https://www.ebl.com/platforms/ulogishub Operator: Korea Trade Network (KTNET) Legal basis: not established P&I approved: Yes DCSA interoperability: not established Website: https://www.ulogishub.com/ Last verified: 16 Oct 2026 The uLogisHub eBL platform is an electronic bill of lading service operated by Korea Trade Network (KTNET), which the Korean government has designated as its National Paperless Trade Infrastructure Provider. The International Group of P&I Clubs lists it among its approved systems, on terms version 1.01. KTNET joined DCSA's DCSA+ partnership programme in October 2025 with a stated focus on eBL interoperability pilots, but was not among the five platforms DCSA named on 4 June 2026 as having implemented the DCSA Standard Annex. Sources: - [IG approved electronic bill of lading systems](https://www.igpandi.org/article/ig-approved-electronic-bill-of-lading-systems/) — International Group of P&I Clubs - [Company Profile](https://www.ktnet.com/board/viewStaticHtmlPage.do?viewName=ktnet_re/comp_prof_en) — Korea Trade Network (KTNET) - [KTNET joins DCSA+ to accelerate global interoperability of electronic Bills of Lading](https://dcsa.org/newsroom/ktnet-joins-dcsa) — Digital Container Shipping Association (DCSA) - [디지털물류플랫폼, KTNET (Digital logistics platform, KTNET)](https://www.ulogishub.com/) — Korea Trade Network (KTNET) ### WAVEBL URL: https://www.ebl.com/platforms/wavebl Operator: OGY Docs Inc. Legal basis: Contractual rulebook P&I approved: Yes DCSA interoperability: Yes Pricing model: Consumption-based annual credit packs; one party pays a single fee per eBL Website: https://wavebl.com/ Last verified: 16 Oct 2026 WAVEBL is an electronic bill of lading platform operated by OGY Docs Inc. as part of the Wave BL Network. Legal effect rests on the WAVE Application and Network Bylaws, a multilateral rulebook binding all users, first approved by the International Group of P&I Clubs in December 2019; version 2.0 came into force on 1 December 2023. On 4 June 2026 DCSA named WaveBL among five platforms that have implemented the DCSA Standard Annex for eBL Platform Interoperability v.2. Sources: - [IG approved electronic bill of lading systems](https://www.igpandi.org/article/ig-approved-electronic-bill-of-lading-systems/) — International Group of P&I Clubs - [Five eBL platforms adopt DCSA Standard Annex v.2 with IGP&I approval, enabling global, cross-platform eBL exchange](https://dcsa.org/newsroom/five-ebl-platforms-adopt-dcsa-interoperability-annex) — Digital Container Shipping Association (DCSA) - [Circular No. 43/19: Electronic (paperless) trading: ... and the Wave Network (WAVE)](https://www.American-Club.com/files/files/cir_43_19.pdf) — American Steamship Owners Mutual Protection and Indemnity Association (American Club), member of the International Group of P&I Clubs - [9/2023: Electronic (Paperless) Trading - WAVE BL: Update to Wave BL Network Bylaws to version 2.0](https://gard.no/en/circulars/9-2023-electronic-paperless-trading-wave-bl-update-to-wave-bl-network-bylaws-to-version-2-0/) — Gard AS, member of the International Group of P&I Clubs - [Wave BL SaaS Platform Terms and Conditions](https://wavebl.com/terms-and-conditions/) — OGY Docs Inc. (WaveBL) - [WaveBL Platform: Electronic Bills of Lading (eBLs) Software App | Blockchain Logistics](https://wavebl.com/) — OGY Docs Inc. (WaveBL) - [FAQ - WaveBL](https://wavebl.com/frequently-asked-questions/) — OGY Docs Inc. (WaveBL) - [Electronic Bill of Lading - WaveBL](https://wavebl.com/electronic-master-bill-of-lading/) — OGY Docs Inc. (WaveBL) - [TradeGo and WaveBL Launch Bilateral eBL Interoperability](https://www.tradego.com/en/new/company-news/30) — TradeGo Pte. Ltd. ## Ocean carriers and electronic bills of lading Issuing eBLs: the carrier's own official pages, or a platform's official announcement naming it, show eBLs offered to customers. Not yet verified: no current official source was found (this does not mean the carrier offers no eBLs). ### CMA CGM URL: https://www.ebl.com/carriers/cma-cgm eBL offering: Issuing eBLs DCSA member: yes Headquarters: Marseille, France Public commitment: With the other DCSA member carriers, committed to converting 50% of original bills of lading to digital within five years and 100% by 2030. (15 Feb 2023) Last verified: 17 Oct 2026 CMA CGM offers a paperless (electronic) bill of lading through its own eBusiness platform, My CMA CGM; on 8 August 2019 it announced that fully electronic bills of lading were available on its eBusiness platforms. CMA CGM is a DCSA member and was one of the nine DCSA carriers that on 15 February 2023 committed to 50% eBL adoption within five years and 100% by 2030. On 2 June 2025 it signed a memorandum of understanding with CargoX, eTEU, ICE and SGTraDex covering feasibility work and pilot trials of TradeTrust-enabled interoperability between eBL platforms. Sources: - [Bill Of Lading Paperless](https://www.cma-cgm.com/services/paperless) — CMA CGM - [Use Paperless bills of lading*](https://www.cma-cgm.com/news/2683/use-paperless-bills-of-lading-) — CMA CGM - [Members](https://dcsa.org/about/members) — Digital Container Shipping Association (DCSA) - [DCSA's member carriers commit to a fully standardised, electronic bill of lading by 2030](https://dcsa.org/newsroom/dcsas-member-carriers-commit-to-a-fully-standardised-electronic-bill-of-lading-by-2030) — Digital Container Shipping Association (DCSA) - [CMA CGM and Partners Ink Memorandum of Understanding to Advance Blockchain-enabled Interoperability of Electronic Bill of Lading](https://www.cma-cgm.com/local/singapore/news/221/cma-cgm-and-partners-ink-memorandum-of-understanding-to-advance-blockchain-enabled-interoperability-of-electronic-bill-of-lading) — CMA CGM - [Legal terms | CMA CGM](https://www.cma-cgm.com/legal-terms) — CMA CGM ### COSCO Shipping Lines URL: https://www.ebl.com/carriers/cosco-shipping-lines eBL offering: Issuing eBLs Platforms: IQAX eBL DCSA member: no Headquarters: Shanghai, China Last verified: 17 Oct 2026 COSCO SHIPPING Lines issues blockchain-based electronic bills of lading through IQAX eBL, which runs on the Global Shipping Business Network (GSBN). On 15 May 2026 it announced linked electronic master and house bills of lading, with the carrier issuing master bills via GSBN to the IQAX eBL platform. It is not a member of the Digital Container Shipping Association (DCSA), and no public eBL adoption target from the carrier was found. Sources: - [COSCO SHIPPING Lines (homepage)](https://lines.coscoshipping.com/) — COSCO SHIPPING Lines Co., Ltd. - [中远海运集运携手哥伦比亚海关与GSBN实现电子提单海关在线核验 (COSCO SHIPPING Lines works with Colombian Customs and GSBN on online eBL verification; Chinese only)](https://lines.coscoshipping.com/home/News/detail/17586812708410948273/50000000000000232) — COSCO SHIPPING Lines Co., Ltd. - [中远海运集运全球首发，采用ISO 5909国际标准实现MBL与HBL全流程数字链接 (COSCO SHIPPING Lines links MBL and HBL digitally under ISO 5909; Chinese only)](https://lines.coscoshipping.com/home/News/detail/17788128233350249615/50000000000000232) — COSCO SHIPPING Lines Co., Ltd. - [Members](https://dcsa.org/about/members) — Digital Container Shipping Association (DCSA) - [IQAX launches IGP&I approved eBL, COSCO SHIPPING Lines and OOCL already onboard](https://www.iqax.com/en/newsroom/iqax-launches-igpi-approved-ebl-cosco-shipping-lines-and-oocl-already-onboard-en/) — IQAX Limited - [COSCO SHIPPING Participates in DLT based Electronic Bill of Lading (eBL) International Standard Passing Key Review Stage](https://lines.coscoshipping.com/home/News/detail/17332050205583082471/50000000000000232) — COSCO SHIPPING Lines Co., Ltd. - [Profile (About COSCO SHIPPING Lines)](https://lines.coscoshipping.com/home/About/about/Profile) — COSCO SHIPPING Lines Co., Ltd. ### Evergreen Line (Evergreen Marine) URL: https://www.ebl.com/carriers/evergreen eBL offering: Issuing eBLs Platforms: CargoX, WAVEBL, The Bolero System DCSA member: yes Public commitment: With the other DCSA member carriers, committed to converting 50% of original bills of lading to digital within five years and 100% by 2030. (15 Feb 2023) Last verified: 17 Oct 2026 Evergreen Line issues DCSA-standard electronic bills of lading via API to three certified platforms, which its ShipmentLink eBL page names as Wave, CargoX and Galileo; it separately offers an i-B/L that is transferable only within its own ShipmentLink system. Bolero's operator announced Evergreen eBLs on Galileo on 1 September 2026, and CargoX announced Evergreen's go-live on 14 October 2026. Evergreen is a founding member of the Digital Container Shipping Association (DCSA) and on 15 February 2023 joined the DCSA member commitment to 50% eBL adoption within five years and 100% by 2030. Sources: - [ShipmentLink - eBL](https://www.shipmentlink.com/ebl1/jsp/EBL1_Information.jsp) — Evergreen Marine Corp. (Taiwan) Ltd. (ShipmentLink) - [Evergreen Line electronic bill of lading goes live on the CargoX Platform](https://cargox.io/content-hub/evergreen-line-ebl-goes-live-on-the-cargox-platform) — CargoX - [Evergreen Line eBLs reach more trade participants through WiseTech Global's Bolero Galileo platform](https://cargowise.com/news/evergreen-line-ebls-reach-more-trade-participants-through-wisetech-global-s-bolero-galileo-platform/) — WiseTech Global (CargoWise) - [Members](https://dcsa.org/about/members) — Digital Container Shipping Association (DCSA) - [DCSA's member carriers commit to a fully standardised, electronic bill of lading by 2030](https://dcsa.org/newsroom/dcsas-member-carriers-commit-to-a-fully-standardised-electronic-bill-of-lading-by-2030) — Digital Container Shipping Association (DCSA) - [Electronic Bills of Lading (Galileo eBL)](https://www.bolero.net/bolero-ebl-as-a-service/) — Bolero International Ltd - [Bolero's Digital Trade Finance Platform](https://www.bolero.net/) — Bolero International Ltd - [Evergreen Marine Corp. (Taiwan) Ltd. 2025 Annual Report](https://www.evergreen-marine.com/doc/financial/pdf/en/annualReports/2025AR.pdf) — Evergreen Marine Corp. (Taiwan) Ltd. ### Hapag-Lloyd URL: https://www.ebl.com/carriers/hapag-lloyd eBL offering: Issuing eBLs Platforms: IQAX eBL, WAVEBL, The Bolero System DCSA member: yes Headquarters: Hamburg, Germany Public commitment: With the other DCSA member carriers, committed to converting 50% of original bills of lading to digital within five years and 100% by 2030. (15 Feb 2023) Last verified: 17 Oct 2026 Hapag-Lloyd offers electronic bills of lading through three partner platforms, IQAX, WaveBL and Galileo (Bolero's eBL service); it first introduced eBLs for customers worldwide in cooperation with WAVE BL. It is a founding member of the Digital Container Shipping Association (DCSA). On 15 February 2023 it joined the DCSA member commitment to 50% eBL adoption within five years and 100% by 2030. Sources: - [Electronic Bill of Lading - Hapag-Lloyd](https://www.hapag-lloyd.com/en/online-business/documentation/electronic-bill-of-lading.html) — Hapag-Lloyd AG - [Electronic Bills of Lading (eBLs): A Modern Solution for Global Trade](https://www.hapag-lloyd.com/en/online-business/digital-insights-dock/insights/2024/12/electronic-bills-of-lading-ebls-a-modern-solution-for-global-tra.html) — Hapag-Lloyd AG - [Hapag-Lloyd introduces worldwide electronic Bills of Lading](https://www.hapag-lloyd.com/en/company/press/releases/2021/09/hapag-lloyd-introduces-worldwide-electronic-bills-of-lading-.html) — Hapag-Lloyd AG - [Members](https://dcsa.org/about/members) — Digital Container Shipping Association (DCSA) - [DCSA's member carriers commit to a fully standardised, electronic bill of lading by 2030](https://dcsa.org/newsroom/dcsas-member-carriers-commit-to-a-fully-standardised-electronic-bill-of-lading-by-2030) — Digital Container Shipping Association (DCSA) - [eBL with Hapag-Lloyd ("Goodbye Paper – Hello Digital!")](https://www.hapag-lloyd.com/content/dam/website/downloads/pdf/eBL_with_Hapag-Lloyd.pdf) — Hapag-Lloyd AG - [Electronic Bills of Lading (Galileo eBL)](https://www.bolero.net/bolero-ebl-as-a-service/) — Bolero International Ltd - [Hapag-Lloyd supports publishing eBLs via Galileo for faster, cheaper, safer exchange of trade documents based on DCSA standards](https://wisetechglobal.com/news/hapag-lloyd-supports-publishing-ebls-via-galileo-for-faster-cheaper-safer-exchange-of-trade-documents-based-on-dcsa-standards/) — WiseTech Global - [Hapag-Lloyd adopts IQAX eBL via GSBN to reach its 100% eBL commitment](https://gsbn.trade/hapag-lloyd-adopts-iqax-ebl-via-gsbn-to-reach-its-100-ebl-commitment/) — Global Shipping Business Network (GSBN) - [Imprint (Hapag-Lloyd Logbook)](https://logbook.hapag-lloyd.com/home/imprint) — Hapag-Lloyd AG ### HMM URL: https://www.ebl.com/carriers/hmm eBL offering: Issuing eBLs Platforms: CargoX DCSA member: yes Public commitment: With the other DCSA member carriers, committed to converting 50% of original bills of lading to digital within five years and 100% by 2030. (15 Feb 2023) Last verified: 17 Oct 2026 HMM offers electronic bills of lading generated in its own digital service system and transferred on the CargoX platform, available to all HMM customers from 8 July 2024 according to the joint HMM and CargoX announcement. HMM is a member of the Digital Container Shipping Association (DCSA), whose member carriers committed on 15 February 2023 to 50% eBL adoption within five years and 100% by 2030. Sources: - [DCSA's member carriers commit to a fully standardised, electronic bill of lading by 2030](https://dcsa.org/newsroom/dcsas-member-carriers-commit-to-a-fully-standardised-electronic-bill-of-lading-by-2030) — Digital Container Shipping Association (DCSA) - [HMM electronic bill of lading on the CargoX Platform](https://cargox.io/hmm-electronic-bill-of-lading-cargox-platform) — CargoX - [HMM and CargoX partner to introduce integrated solution for global electronic BL service to HMM customers](https://cargox.io/content-hub/hmm-and-cargox-partner-to-introduce-electronic-bl) — CargoX (joint release with HMM) - [Members](https://dcsa.org/about/members) — Digital Container Shipping Association (DCSA) - [HMM eBL available on CargoX Platform – TODAY](https://cargox.io/content-hub/hmm-ebl-available-on-cargox-platform-today) — CargoX - [100% eBL by 2030](https://dcsa.org/100-percent-ebl/) — Digital Container Shipping Association (DCSA) ### KMTC (Korea Marine Transport Co.) URL: https://www.ebl.com/carriers/kmtc eBL offering: Not yet verified DCSA member: no Headquarters: Seoul, South Korea Last verified: 17 Oct 2026 No official KMTC source that describes an electronic bill of lading offering could be opened, so KMTC's eBL status is recorded as unknown. No eBL platform's official release names KMTC as an issuer. KMTC is not a member of the Digital Container Shipping Association (DCSA), and no public eBL adoption commitment by KMTC was found. Sources: - [기업개황정보 (company overview): 고려해운 (주) / KOREA MARINE TRANSPORT CO. LTD](https://dart.fss.or.kr/dsae001/selectPopup.ax?selectKey=00103158) — Financial Supervisory Service (Korea), DART electronic disclosure system - [Members](https://dcsa.org/about/members) — Digital Container Shipping Association (DCSA) - [고려해운 감사보고서 (2025.12) — audit report for the 41st fiscal year, 1 January to 31 December 2025](https://dart.fss.or.kr/dsaf001/main.do?rcpNo=20260413001763) — Korea Marine Transport Co., Ltd. (filed on DART, Financial Supervisory Service) ### Maersk URL: https://www.ebl.com/carriers/maersk eBL offering: Not yet verified DCSA member: yes Headquarters: Copenhagen, Denmark Public commitment: With the other DCSA member carriers, committed to converting 50% of original bills of lading to digital within five years and 100% by 2030. (15 Feb 2023) Last verified: 17 Oct 2026 Maersk is a DCSA member and was one of the nine DCSA carriers that on 15 February 2023 committed to converting 50% of original bills of lading to digital within five years and 100% by 2030. On 25 November 2022 Maersk described eBL issuance through TradeLens, which it announced on 29 November 2022 it would discontinue; a joint Singapore and India government release of 25 August 2023 states that Maersk issued an eBL through the TradeTrust portal in a first live transaction. Maersk pages reviewed on 17 October 2026 do not state which eBL service, if any, it currently offers. Sources: - [What are challenges associated with electronic bills of lading](https://www.maersk.com/support/faqs/2023/08/15/electronic-bills-of-lading) — A.P. Moller - Maersk - [Members](https://dcsa.org/about/members) — Digital Container Shipping Association (DCSA) - [DCSA's member carriers commit to a fully standardised, electronic bill of lading by 2030](https://dcsa.org/newsroom/dcsas-member-carriers-commit-to-a-fully-standardised-electronic-bill-of-lading-by-2030) — Digital Container Shipping Association (DCSA) - [Maersk: The ambition to digitize global trade starts with electronic Bill of Lading](https://www.maersk.com/news/articles/2022/11/25/ambition-digitize-global-trade) — A.P. Moller - Maersk - [A.P. Moller - Maersk and IBM to discontinue TradeLens, a blockchain-enabled global trade platform](https://www.maersk.com/news/articles/2022/11/29/maersk-and-ibm-to-discontinue-tradelens) — A.P. Moller - Maersk - [Singapore and India kick off an era of interoperable electronic Bills of Lading for Trade Finance](https://www.mti.gov.sg/-/media/MTI/Newsroom/Press-Releases/2023/08/Press-Release-on-TradeTrust_FINAL.pdf) — Ministry of Trade and Industry (Singapore), NITI Aayog (India) and Infocomm Media Development Authority (IMDA, Singapore) - [A.P. Møller - Mærsk A/S Interim Report Q3 2025 (ESEF filing)](https://filings.xbrl.org/549300D2K6PKKKXVNN73/2025-09-30/ESEF/DK/0/APMM-2025-09-30-en/reports/APMM-2025-09-30-en.xhtml) — A.P. Møller - Mærsk A/S ### MSC (Mediterranean Shipping Company) URL: https://www.ebl.com/carriers/msc eBL offering: Issuing eBLs Platforms: WAVEBL DCSA member: yes Headquarters: Geneva, Switzerland Public commitment: With the other DCSA member carriers, committed to converting 50% of original bills of lading to digital within five years and 100% by 2030. (15 Feb 2023) Last verified: 17 Oct 2026 MSC offers an electronic bill of lading (MSC eBL) that it states is issued through the WAVEBL platform; MSC dates the launch to April 2021, following a pilot in India. MSC is a DCSA member and was one of the nine DCSA carriers that on 15 February 2023 committed to 50% eBL adoption within five years and 100% by 2030. Sources: - [eBL - Simple Digital Solutions | MSC](https://www.msc.com/en/solutions/digital-solutions/ebl) — MSC Mediterranean Shipping Company - [MSC Commits to Achieve 100% Electronic Bill of Lading Adoption by 2030](https://www.msc.com/es/newsroom/news/2023/february/msc-commits-to-achieve-100-percent-electronic-bill-of-lading-adoption-by-2030) — MSC Mediterranean Shipping Company - [Members](https://dcsa.org/about/members) — Digital Container Shipping Association (DCSA) - [DCSA's member carriers commit to a fully standardised, electronic bill of lading by 2030](https://dcsa.org/newsroom/dcsas-member-carriers-commit-to-a-fully-standardised-electronic-bill-of-lading-by-2030) — Digital Container Shipping Association (DCSA) - [Save Time and Reduce Costs with MSC Electronic Bill of Lading (eBL)](https://www.msc.com/en/newsroom/news/2021/april/save-time-and-reduce-costs-with-msc-electronic-bill-of-lading-ebl) — MSC Mediterranean Shipping Company - [eBL Solution in MSC Saudi](https://www.msc.com/en/local-information/middle-east/saudi-arabia/saudi-ebl-solutions) — MSC Mediterranean Shipping Company - [Contact us | MSC](https://www.msc.com/en/contact-us) — MSC Mediterranean Shipping Company ### Ocean Network Express (ONE) URL: https://www.ebl.com/carriers/one eBL offering: Issuing eBLs Platforms: WAVEBL, ICE CargoDocs, The Bolero System DCSA member: yes Headquarters: Singapore, Singapore Public commitment: With the other DCSA member carriers, committed to converting 50% of original bills of lading to digital within five years and 100% by 2030. (15 Feb 2023) Last verified: 17 Oct 2026 Ocean Network Express (ONE) issues electronic bills of lading through partner platforms; its eBL page lists Wave BL, Bolero and ICE Digital Trade (essDOCS) CargoDocs as currently supported. ONE announced the extension of its WAVE BL eBL offering to more customers on 18 October 2021. It is a founding member of the Digital Container Shipping Association (DCSA) and on 15 February 2023 joined the DCSA member commitment to 50% eBL adoption within five years and 100% by 2030. Sources: - [Electronic Bill of Lading (eBL) Solutions | ONE](https://www.one-line.com/en/all-digital-solutions/ebl) — Ocean Network Express Pte. Ltd. - [Ocean Network Express Taps WAVE BL to Advance eBL operations and scale global collaboration in digital trade](https://www.one-line.com/sites/g/files/lnzjqr776/files/2021-10/EN_News%20Release%20-%20ONE%20Taps%20WAVE%20BL%20to%20Advance%20eBL%20operations%20and%20scale%20global%20collaboration%20in%20digital%20trade.pdf) — Ocean Network Express Pte. Ltd. - [Members](https://dcsa.org/about/members) — Digital Container Shipping Association (DCSA) - [DCSA's member carriers commit to a fully standardised, electronic bill of lading by 2030](https://dcsa.org/newsroom/dcsas-member-carriers-commit-to-a-fully-standardised-electronic-bill-of-lading-by-2030) — Digital Container Shipping Association (DCSA) ### OOCL (Orient Overseas Container Line) URL: https://www.ebl.com/carriers/oocl eBL offering: Issuing eBLs Platforms: IQAX eBL DCSA member: no Headquarters: Hong Kong, China Last verified: 17 Oct 2026 OOCL offers electronic bills of lading through IQAX eBL, built on the Global Shipping Business Network (GSBN) blockchain platform; it announced its eBL service on 19 July 2022, and registered customers access eBLs through the IQAX eBL portal. It is not a member of the Digital Container Shipping Association (DCSA), and no public eBL adoption target from the carrier was found. Sources: - [eBL Blockchain Service](https://www.oocl.com/eng/ourservices/eservices/eBL/) — Orient Overseas Container Line Limited - [OOCL Adopts Electronic Bill of Lading to Enhance Supply Chain Efficiency](https://www.oocl.com/eng/pressandmedia/pressreleases/2022/Pages/19Jul2022.aspx) — Orient Overseas Container Line Limited - [Members](https://dcsa.org/about/members) — Digital Container Shipping Association (DCSA) - [Cross-Platform eBLs become a reality as OOCL and a major oil and gas company go live](https://product.iqax.com/en/newsroom/2025/03/cross-platform-ebls-become-a-reality-as-oocl-and-a-major-oil-and-gas-company-go-live/) — IQAX Limited - [OOCL Receives Two Singapore Environment Achievement Awards](https://www.oocl.com/eng/pressandmedia/pressreleases/2026/Pages/31Aug2026.aspx) — Orient Overseas Container Line Limited ### PIL (Pacific International Lines) URL: https://www.ebl.com/carriers/pil eBL offering: Issuing eBLs Platforms: WAVEBL DCSA member: yes Headquarters: Singapore, Singapore Last verified: 17 Oct 2026 Pacific International Lines (PIL) offers electronic bills of lading to customers through WaveBL; it announced the WaveBL partnership on 24 July 2024 and describes the service on its e-Bill of Lading page. PIL joined DCSA as its tenth carrier member, announced on 18 April 2024. No primary source was found for a PIL eBL adoption target. Sources: - [Digital Solutions — E-Bill of Lading](https://www.pilship.com/digital-solutions/?tab=customer&id=ebl) — Pacific International Lines - [PIL upgrades its electronic Bill of Lading solution for customers](https://www.pilship.com/newsroom/pil-upgrades-its-electronic-bill-of-lading-solution-for-customers/) — Pacific International Lines - [PIL joins DCSA to advance container shipping digitalisation standards](https://www.pilship.com/newsroom/pil-joins-dcsa-to-advance-container-shipping-digitalisation-standards/) — Pacific International Lines - [Members](https://dcsa.org/about/members) — Digital Container Shipping Association (DCSA) - [Contact Us](https://www.pilship.com/contact-us/) — Pacific International Lines ### SITC URL: https://www.ebl.com/carriers/sitc eBL offering: Not yet verified DCSA member: no Headquarters: Hong Kong, China Last verified: 17 Oct 2026 No official SITC source that describes an electronic bill of lading offering could be found, so SITC's eBL status is recorded as unknown. No eBL platform's official release names SITC as an issuer. SITC is not a member of the Digital Container Shipping Association (DCSA), and no public eBL adoption commitment by SITC was found. Sources: - [Company Profile_SITC International](https://www.sitc.com/en/list.asp?classid=38) — SITC International Holdings Co., Ltd. - [Members](https://dcsa.org/about/members) — Digital Container Shipping Association (DCSA) ### Wan Hai Lines URL: https://www.ebl.com/carriers/wan-hai eBL offering: Not yet verified DCSA member: no Headquarters: Taipei, Taiwan Last verified: 17 Oct 2026 Bolero International announced on 5 September 2018 that Wan Hai Lines had executed its first electronic bill of lading, using the Bolero ePresentation solution, for a shipment from Taiwan to China; no later official source on continued issuance was found. No Wan Hai page or advisory stating that it issues eBLs to customers today could be opened, so its eBL status is recorded as unknown and no platform is listed. Wan Hai is not a member of the Digital Container Shipping Association (DCSA), and no public eBL adoption commitment by Wan Hai was found. Sources: - [Listed companies basic information (上市公司基本資料), record for company code 2615](https://openapi.twse.com.tw/v1/opendata/t187ap03_L) — Taiwan Stock Exchange (TWSE) open data - [Wan Hai Lines executes first Bolero International electronic bill of lading to accelerate Taiwan-China shipment](https://www.bolero.net/resources/news/wan-hai-lines-executes-first-bolero-international-electronic-bill-of-lading-to-accelerate-taiwan-china-shipment/) — Bolero International - [Members](https://dcsa.org/about/members) — Digital Container Shipping Association (DCSA) - [Company registration basic data (公司登記基本資料), 萬海航運股份有限公司, unified business no. 11395000](https://data.gcis.nat.gov.tw/od/data/api/5F64D864-61CB-4D0D-8AD9-492047CC1EA6?$format=json&$filter=Business_Accounting_NO eq 11395000&$skip=0&$top=5) — Ministry of Economic Affairs (Taiwan), company registry open data (GCIS); registering authority 商業發展署 ### Yang Ming URL: https://www.ebl.com/carriers/yang-ming eBL offering: Not yet verified DCSA member: yes Headquarters: Keelung, Taiwan Public commitment: With the other DCSA member carriers, committed to converting 50% of original bills of lading to digital within five years and 100% by 2030. (15 Feb 2023) Last verified: 17 Oct 2026 Yang Ming is a founding member of the Digital Container Shipping Association (DCSA) and signed the DCSA member carriers' commitment of 15 February 2023 to 100% adoption of eBLs based on DCSA standards by 2030. Its sustainability report for 2025 states that eBL issuance and surrender functions completed testing and validation with third-party platforms during 2025, and sets a 2026 target to promote eBL issuance and surrender services. No official Yang Ming source found as of 17 October 2026 confirms that it issues eBLs to customers or names an eBL platform. Sources: - [Digital Solution — Overview](https://www.yangming.com/en/esolution/digital_solution_ov) — Yang Ming Marine Transport Corporation - [Members](https://dcsa.org/about/members) — Digital Container Shipping Association (DCSA) - [DCSA's member carriers commit to a fully standardised, electronic bill of lading by 2030](https://dcsa.org/newsroom/dcsas-member-carriers-commit-to-a-fully-standardised-electronic-bill-of-lading-by-2030) — Digital Container Shipping Association (DCSA) - [2025 Sustainability Report, Chapter 4: Going Digital - Smart Operations Creating Sustainable Win-Win Situations](https://esg.yangming.com/upload/esg_custom_sustainability_report_document_files/enL_esg_custom_sustainability_report_document_26J14_F3wmJWOucy.pdf) — Yang Ming Marine Transport Corporation - [2025 Sustainability Report, Chapter 1: Strategic Blueprint - Sustainable Operation Strategies](https://esg.yangming.com/upload/esg_custom_sustainability_report_document_files/enL_esg_custom_sustainability_report_document_26J14_ZIDWc2q1tl.pdf) — Yang Ming Marine Transport Corporation - [DCSA's member carriers commit to a fully standardised, electronic bill of lading by 2030](https://www.yangming.com/en/news/notice/14383) — Yang Ming Marine Transport Corporation - [2025 Sustainability Report: Sustainability Leadership (company profile)](https://esg.yangming.com/upload/esg_custom_sustainability_report_document_files/enL_esg_custom_sustainability_report_document_26J14_8AdfjuUUlG.pdf) — Yang Ming Marine Transport Corporation - [Sustainability Report (2024 reporting year): Sustainability Leadership - YANG MING delivers GOOD for life](https://esg.yangming.com/upload/esg_custom_sustainability_report_document_files/enL_esg_custom_sustainability_report_document_26I09_MrfzaofR2x.pdf) — Yang Ming Marine Transport Corporation ### ZIM URL: https://www.ebl.com/carriers/zim eBL offering: Issuing eBLs Platforms: WAVEBL DCSA member: yes Headquarters: Haifa, Israel Public commitment: With the other DCSA member carriers, committed to converting 50% of original bills of lading to digital within five years and 100% by 2030. (15 Feb 2023) Last verified: 17 Oct 2026 ZIM offers electronic bills of lading to customers through WaveBL, a company in which it has invested; ZIM states it began using eBLs on WaveBL in 2017. ZIM is a founding member of DCSA and signed the DCSA member carriers' commitment of 15 February 2023 to 100% adoption of eBLs based on DCSA standards by 2030. Its annual report for 2025 states targets of 50% eBLs by 2027 and 100% by 2030. Sources: - [eB/L Service | ZIM](https://www.zim.com/digital-solutions/ebl-service) — ZIM Integrated Shipping Services Ltd. - [DCSA's member carriers commit to a fully standardised, electronic bill of lading by 2030](https://dcsa.org/newsroom/dcsas-member-carriers-commit-to-a-fully-standardised-electronic-bill-of-lading-by-2030) — Digital Container Shipping Association (DCSA) - [ZIM Integrated Shipping Services Ltd. — Form 20-F annual report for the fiscal year ended 31 December 2025](https://www.sec.gov/Archives/edgar/data/1654126/000117891326000784/zk2634463.htm) — ZIM Integrated Shipping Services Ltd. (filed with U.S. SEC) - [Innovative Shipping Dedicated to You](https://www.zim.com/about-zim/innovative-shipping-dedicated-to-you) — ZIM Integrated Shipping Services Ltd. - [Members](https://dcsa.org/about/members) — Digital Container Shipping Association (DCSA)