Bill of Lading Draft Check: SI, VGM, UCP 600, US ISF and EU ICS2

Where the draft comes from: booking, SI cut-off and VGM

A B/L draft is the carrier's proposed text of the bill. It combines your shipping instruction with what the carrier already knows from the booking and the terminal: vessel, voyage, container and seal numbers and, once the goods are loaded, the on-board date. If you ship through a freight forwarder, you receive the forwarder's house B/L draft, and the forwarder sends its own instruction to the shipping line for the master B/L.

Each carrier sets a documentation (SI) cut-off for each sailing. A late SI risks missing the manifest and can be charged: Hapag-Lloyd's German export tariff (version of 15 June 2026), for example, has a late shipping instruction fee of EUR 70 per document when the SI is delivered after the published documentation closing. Send a complete SI early, with the 6-digit HS code where the destination or carrier asks for it, so the draft reaches you while there is still time to fix it.

The verified gross mass (VGM) is a separate declaration. Under SOLAS regulation VI/2, as amended by resolution MSC.380(94) and in force since 1 July 2016, the shipper must provide the verified gross mass of each packed container, found by one of two methods: weighing the packed container, or weighing all packages and cargo items, including pallets, dunnage and other securing material, and adding the container's tare mass. The shipper states it in a shipping document sent to the master or his representative and to the terminal in time for the stowage plan; the IMO describes it as a condition for loading. Because the VGM includes the container and packing materials, it is not the cargo gross weight that goes on the B/L.

Parties, vessel and routing

Start with the boxes that decide who can claim the goods and where they go. Compare each one, letter by letter, with the SI, the booking confirmation, the invoice and packing list, the sales contract and any credit.

• Shipper: your full legal name and address, as on the commercial invoice. A forwarder appearing as shipper is normal on the master B/L the shipping line issues to it, not on the house B/L issued to you.
• Consignee: "to order", "to order of shipper" or "to order of" a named bank makes the bill negotiable; a named consignee makes it a straight bill. Use exactly the wording the contract or credit requires; the telex release note explains which choice suits which payment terms.
• Notify party: usually the buyer or its customs broker, with full address and contact details. With a "to order" consignee it is the only named party at destination, and some destinations' manifest rules ask for its details.
• Vessel and voyage: as on the booking confirmation. A draft that says "intended vessel" needs an on-board notation naming the actual vessel once the goods are loaded.
• Port of loading and port of discharge: the ports, not just the countries, matching the booking, invoice and credit. A transhipment port is not the port of discharge.
• Place of receipt and place of delivery: filled in only when the carrier also moves the goods inland before or after the sea leg. Under a credit, a place of receipt before the port of loading changes what the on-board notation must show.

Goods, marks, containers and weights

The description must cover the same goods as the invoice and packing list, in plain words that say what they are. In the US, the carrier's cargo declaration takes from every bill, master or house, a precise description, or the 6-digit HTS number if the shipper supplies it, and the weight; generic descriptions such as "FAK" (freight of all kinds), "general cargo" and "STC" (said to contain) are not acceptable (19 CFR 4.7a). For EU-bound cargo, Hapag-Lloyd asks for a six-digit HS code plus an accurate and complete cargo description for ICS2. The B/L does not need every SKU from the invoice; a shorter description such as "skin care creams and lotions" is fine as long as it does not conflict with the invoice.

Marks, numbers and quantities are your declaration. Under the Hague-Visby Rules, where they apply, the carrier issues a B/L showing the leading marks and the number of packages or the quantity or weight "as furnished in writing by the shipper", plus the apparent order and condition of the goods, but need not show figures it has reason to suspect or no reasonable means of checking. The shipper is deemed to have guaranteed their accuracy and must indemnify the carrier for losses caused by inaccuracies, and once the bill has been transferred to a third party acting in good faith, the carrier cannot prove the contrary against that holder (Article III, rules 3 to 5).

• Marks and numbers: exactly as printed on the cartons or pallets and on the packing list; "N/M" (no marks) if there are none.
• Number and kind of packages: the outer packages counted on the packing list, for example 20 pallets containing 1,200 cartons, with figures and words that agree.
• Container and seal numbers: from your packing record or the terminal gate-in; the US cargo declaration needs both.
• Gross weight and measurement: the cargo gross weight and volume (CBM) from the packing list, not the VGM.
• HS code: add it where the destination or carrier requires it, using the same code as on the invoice.
• Clauses: on a container you pack and seal, carriers often add "shipper's load, stow and count" or "said to contain". These record that the carrier did not check the contents and are normal; a remark on the condition of the goods or packaging is a different matter.

Freight terms, originals and dates

Freight terms must match your Incoterms rule and the booking. Under CFR and CIF the seller books and pays the freight and must hand the buyer a valid bill of lading, so the B/L shows "freight prepaid"; when the buyer pays the ocean freight, it shows "freight collect". If a credit names one of them, the B/L must not show the other.

Check the number of originals (often three, shown as "3/3") and of non-negotiable copies against the contract or credit, and the type you asked for: original bills, a sea waybill, or originals to be surrendered for a telex release.

A "shipped on board" bill confirms loading in its printed text; a "received for shipment" bill needs a dated on-board notation after loading, and under the Hague-Visby Rules the shipper can then demand a shipped bill (Article III, rule 7). ICC guidance treats the issue date as the shipment date unless the B/L carries a dated on-board notation, in which case the notation date counts. Check that this date is the actual loading date and falls within the latest shipment date in the contract or credit. Never ask a carrier to back-date a B/L.

Extra checks when you are paid by letter of credit (UCP 600)

Banks compare the B/L with the credit and the other documents presented. Under UCP 600 Article 14(d), data "need not be identical to, but must not conflict with" data in the same document, any other stipulated document or the credit. Under Article 14(e), documents other than the commercial invoice may describe the goods in general terms that do not conflict with the credit. Under Article 14(j), when the applicant's address and contact details appear as part of the consignee or notify party details on a transport document, they must be as stated in the credit.

Check the draft against the credit, not only against the invoice. A discrepancy spotted on the draft costs an e-mail; one spotted by the bank after the originals are issued can delay or stop payment.

• Consignee and notify party: copy the credit's wording, for example to order of the issuing bank, notify the applicant at the address the credit gives.
• Ports: the B/L must show shipment from the port of loading to the port of discharge stated in the credit (Article 20(a)(iii)). If it shows another port of loading, or calls the port of loading "intended", it needs an on-board notation with the credit's port of loading, the shipment date and the vessel name.
• On board: pre-printed wording or an on-board notation must show that the goods were shipped on a named vessel at the port of loading (Article 20(a)(ii)). With "intended vessel", the notation must give the actual vessel and the date; with a place of receipt before the port of loading, it must show the port and the vessel unless the B/L already makes this clear.
• Clean: under Article 27, a clean transport document bears no clause or notation expressly declaring a defective condition of the goods or their packaging, and the word "clean" need not appear even if the credit asks for a "clean on board" bill. In ICC Banking Commission Opinion 470/TA.941rev (July 2024), a refusal of a B/L noting "Cargo Conditions As Per Survey Report" was not valid where the report was neither required nor presented.
• Freight, originals and dates: freight prepaid or collect, the number of originals and the shipment date must match what the credit asks for.

Destination filings that use B/L data: US, EU and China

United States: the carrier's cargo declaration takes its data from the bills of lading, master or house: the shipper's and the consignee's complete name and address or identification number, a precise description or 6-digit HTS number, the weight, and the container and seal numbers (19 CFR 4.7a). Separately, the ISF importer or its authorised agent must file the Importer Security Filing (ISF, often called "10+2") no later than 24 hours before the cargo is loaded on the vessel at the foreign port. The container stuffing location and consolidator may follow, but no later than 24 hours before arrival in a US port, and the filing must be updated if information changes or more accurate information becomes available before the goods arrive (19 CFR 149.2). The ISF relies partly on data you supply, such as where the container was stuffed, so keep it consistent with the B/L.

European Union: under the Import Control System 2 (ICS2), all operators bringing goods into or through the EU must declare safety and security data in an entry summary declaration (ENS), in a single filing or in multiple filings, for example by the carrier for the master bill and by a forwarder for its house bills. Risk analysis can lead to requests for more information or screening, or to an instruction not to load the cargo, and customs may impose administrative sanctions for non-compliance with data requirements. Hapag-Lloyd's ICS2 guidance asks shippers for a six-digit HS code with an accurate and complete description and for the Economic Operators Registration and Identification (EORI) number of the consignee established in the EU, and gives a deadline of 24 hours before loading for containerised deep-sea cargo. The European Commission also publishes a list of "stop words" for goods descriptions; an updated list comes into force on 3 August 2026.

China: Maersk's FAQ of 4 May 2018 on China Customs' advance manifest rules (Order No. 56 [2017], for cargo loaded from 1 June 2018 to or via the Chinese mainland) says the manifest must be filed 24 hours before vessel loading and the SI must give the consignor's company code and phone number and the consignee's name, code, phone and contact person, or, for a "to order" consignee, the notify party's code and phone; an SI missing mandatory data is declined. This is a carrier's 2018 summary, so confirm current requirements, including any HS code requirement, with your carrier.

Corrections after issue, house vs master, waybills and eBLs

Corrections before the documentation cut-off are the cheapest. After it, carriers charge fees that vary by carrier, country and stage. Hapag-Lloyd's German export tariff (15 June 2026), for example, lists EUR 125 per amendment after shipping instruction closing (from 1 January 2026), EUR 200 per B/L for a switch B/L or an amendment with a new set printed and issued, and, for FCL, EUR 85 per booking amendment after the booking confirmation, with the first amendment free. Check your own carrier's local tariff. If originals have already been issued, ask the carrier what it needs back before it issues a corrected set, tell your buyer and any bank, and remember that a US ISF must be updated when its data change.

With a forwarder acting as a non-vessel-operating common carrier (NVOCC), you approve the house B/L, but the master B/L and the customs filings must tell the same story: US manifests use the numbers and quantities from master or house bills, and in ICS2 house-level data may be filed separately from the carrier's. Ask the forwarder to confirm that the master B/L shows the same container and seal numbers, package count, weights and description.

A sea waybill, or a bill to be surrendered for a telex release, goes through the same draft check. With a waybill there is no original to present, so the named consignee must be exactly right. An electronic B/L (eBL) carries the same data on a platform, and its legal effect depends on national law: UNCITRAL lists laws based on or influenced by its Model Law on Electronic Transferable Records (2017) in, among others, Singapore (2021), the United Kingdom (2023), France (2024) and China (2025, for bills of lading only). Before agreeing to an eBL, check that your buyer and any bank under a credit can receive it.