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Applicant vs. Consignee on a Certificate of Origin — Does It Matter?

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A Practical Q&A with Mr. Old Man

In documentary credit work, applicants, consignees, and importers often end up being the same party, yet the terminology on document templates is rarely consistent. A common question is: If the LC asks for the “Applicant,” but the COO form only provides space for the “Consignee,” will banks treat that as a discrepancy?

Let’s take a look at Mike’s question below.

Question

Dear Sir,

How are you doing?

I have an L/C showing the clause:

“C/I, P/L and COO must indicate Applicant name and address as per Field 50.”

In the Certificate of Origin that was issued, it shows the Consignee Name and Address instead of the wording Applicant. The consignee’s name and address, however, match exactly what appears in Field 50.

Now, according to the L/C, the COO must indicate the applicant’s name and address — but the COO shows “Consignee” instead.

Will this be a discrepancy?

Also, could you quote the relevant ISBP or UCP clause that explains this?

Regards,

Mike

_______

Answer

Dear Mike,

Thank you for your question. Here’s my response.

The LC requires the certificate of origin to indicate the applicant’s name and address as per Field 50. The COO presented uses a box titled “Consignee Name and Address,” but the information entered there is exactly the same as the applicant’s details in Field 50.

In practice, most COO templates include a field for consignee/importer, not applicant. I have not seen a template with a box titled “Applicant’s name and address.” Therefore, exporters commonly insert the applicant’s information into the consignee/importer field when the LC calls for the applicant’s details to appear.

In my opinion, the document is compliant.

The required data — the applicant’s name and address — is present, and the use of the label “Consignee” does not create any conflict.

If a supporting UCP reference is needed, UCP 600 sub-article 14(d) is relevant:

Data in a document need not be identical to the wording of the credit, provided it does not conflict and can be understood in context with the credit, the document itself, and international standard banking practice.

In this case, the data matches, and there is no conflict. Therefore, no discrepancy.

I hope this clarifies your question.

Best regards,

Mr. Old Man

 

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