“Commencing on the Same Means of Conveyance” — What Exactly Does Article 31(b) Mean?

INTRO

Every now and then, a single word in UCP 600 sparks an entire chain of questions.

This time, it’s the word “commencing” in Article 31(b)—a term that often confuses practitioners when multiple bills of lading, pre-carriage, transshipment, and partial shipments are involved.

Below is my detailed response to a reader’s excellent set of questions on how Article 31(b) interacts with ISBP 821 and shipping practices.

QUESTION (from Alfred)

Article 31(b) induces striking thoughts on the word “commencing”:

1. Does it imply that presented bills of lading should not indicate any pre-carriage vessel, and should not indicate any transshipment vessel? (Meaning: single vessel, multiple port of loading, single port of discharge.)
2. Does Article 31(b) conflict with ISBP para B2(e)(i), which stipulates how to compute the maturity date when a BL indicates more than one on-board notation? The provision for multiple on-board notations is further supported by ISBP para E6(h).
3. If the applicant allows a range of ports or a geographical area as port of discharge, is this self-inflicted and does it permit multiple vessels? More precisely, partial shipment? If a vessel can load from multiple ports, can it not unload at multiple ports?
4. Is Article 31(b) more inclined toward the beneficiary?

ANSWER

Dear Alfred,

Thank you for your interesting questions.

I have reviewed UCP 600 sub-article 31(b) and offer the following comments on each point:

1. Does sub-article 31(b) imply that bills of lading should not show pre-carriage or transshipment vessels?

No.

Sub-article 31(b) addresses when multiple transport documents are still not considered partial shipments if they evidence shipment commencing on the same means of conveyance and for the same journey.

The term “commencing” simply refers to the main ocean vessel on which the actual shipment begins.

It does not prohibit:

• mentioning a pre-carriage vessel, or
• indicating transshipment, if permitted by the LC.

Therefore:

• A bill of lading showing pre-carriage is not a discrepancy.
• A bill of lading may show transshipment if allowed by the LC.

2. Does sub-article 31(b) conflict with ISBP 821 para B2(e)(i)?

There is no conflict.

• Sub-article 31(b) deals with whether multiple transport documents constitute partial shipment.
• ISBP 821 B2(e)(i) explains how to compute maturity date when a transport document shows multiple dated on-board notations.

They apply to different issues and operate independently.

3. Does allowing a geographical range as “Port of discharge” permit unloading at more than one port?

UCP 600 and ISBP 821 do not expressly define this situation.

However, the standard banking interpretation is:

A geographical range identifies alternative ports—not multiple ports of discharge.

The destination is still considered “one and the same destination.”

Therefore, this does not itself authorize unloading at more than one port unless the LC clearly allows it.

4. Is sub-article 31(b) more favourable to the beneficiary?

It does give the beneficiary additional flexibility, because:

• shipment can occur in more than one lift,
• multiple transport documents may be issued,
• yet the presentation is still not treated as partial shipment,
• provided all shipments commence on the same vessel, for the same journey, to the same destination.

Whether this is “beneficiary-friendly” or simply practical depends on perspective, but sub-article 31(b) certainly allows the beneficiary to work more flexibly within a single voyage.

Best regards,

Mr. Old Man