Bill of Lading vs Air Transport Document: Why Does UCP 600 Treat the Issuance Date Differently?

A small wording difference between article 20 and article 23 of UCP 600 often raises an interesting technical question among trade finance practitioners.

For bills of lading, UCP 600 does not expressly require the document to indicate a date of issuance. However, article 23 clearly states that an air transport document must indicate the date of issuance.

Why the difference?

The answer lies in the different legal nature and commercial practice of sea transport documents and air transport documents.

Question

Dear Mr. Old Man,

Sir one question if you can please help.

For a bill of lading, the issuance date is not mandatory. UCP 600 article 20 does not explicitly require for BL to show issuance date. However, for air transport document, article 23 says that it must indicate date of issuance.

Why so?

Thank you and best regards,

Ahtisham Ali

________

Answer

Dear Ahtisham,

Thank you for your thoughtful question.

Yes, it is correct that under UCP 600 a bill of lading does not necessarily have to indicate a separate “date of issuance” in the same express manner as an air transport document. However, a bill of lading must still indicate that the goods have been shipped on board, either by a pre-printed “Shipped on board” wording or by a separate dated on-board notation.

The distinction between article 20 (bill of lading) and article 23 (air transport document) reflects the different legal and commercial functions of these transport documents.

1. Bill of Lading — Article 20 UCP 600

Article 20(a)(ii) requires a bill of lading to:

indicate that the goods have been shipped on board a named vessel at the port of loading stated in the credit.

This requirement may be satisfied in two ways:

• by a pre-printed “shipped on board” bill of lading; or
• by a separate on-board notation.

ISBP 821 paragraph E6(a) further clarifies:

when a pre-printed “Shipped on board” bill of lading is presented, its issuance date will be deemed to be the date of shipment unless it bears a separate dated on-board notation.

Therefore:

• if the bill of lading is already a pre-printed shipped-on-board bill, the issuance date is deemed to be the shipment date unless another dated on-board notation appears;
• if there is a separate dated on-board notation, that date becomes the shipment date whether it is before or after the issuance date.

Accordingly, UCP 600 does not expressly require a bill of lading to indicate a separate issuance date as an independent requirement. The critical issue is whether the shipment/on-board status and shipment date can be determined.

However, a bill of lading cannot merely show a date without indicating shipment on board.

2. Air Transport Document — Article 23 UCP 600

Article 23(a)(iii) expressly requires that an air transport document:

indicate the date of issuance.

This requirement is explicit because an air transport document operates differently from a bill of lading.

An air waybill:

• is not a document of title;
• is normally issued immediately upon acceptance of the goods by the carrier;
• does not typically use “on-board notation” practice as in sea transport.

Under article 23, the issuance date generally functions as the shipment date unless a specific flight date is indicated.

Therefore, without an issuance date, it may be impossible to determine whether shipment complied with the latest shipment date in the credit.

In short:

• article 20 focuses primarily on proof of shipment on board;
• article 23 focuses on the issuance date because that date effectively evidences shipment in air carriage practice.

That is why UCP 600 expressly requires the issuance date for an air transport document, while article 20 does not impose the same express requirement for a bill of lading.

I hope this clarifies your concern.

Best regards,
Mr. Old Man