House Bill of Lading vs. Marine Bill of Lading: How to Distinguish them?

 QUESTION

Dear Sir

I have received an LC with the below clause. It states that the Marine Bill of Lading to be presented.

+  AS PER MOROCCAN EXCHANGE RULES, THE TRANSPORT DOCUMENTS HOUSE AIR WAYBILL (HAWB) AND FORWARDER’S CERTIFICATE OF RECEIPT (FCR) ARE NOT ACCEPTED, HOUSE BILL OF LADING(HBL) AND FIATA BILL OF LADING (FBL) ARE ACCEPTED IF AND ONLY IF ACCOMPANIED WITH A COPY OF A MARINE BILL OF LADING.

Normally a Bill of Lading can also be issued by a Freight Forwarder identifying them as the Carrier in the BL.

My question here is how will the bank know if it’s a House Bill of Lading or Marine Bill of Lading?

Regards

Mike

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ANSWER

Hi Mike,

Thanks for your question — and it’s a good one.

Based on what the LC says, here’s the deal:

 What’s allowed under this LC:

• A Marine Bill of Lading that complies with both the LC terms and UCP 600 Article 20 is fine.
• A House Bill of Lading (HBL) or FIATA Bill of Lading (FBL) can also be accepted — but only if you attach a copy of a Marine BL.
• HAWB (House Air Waybill) and FCR (Forwarder’s Certificate of Receipt) are clearly not accepted — Moroccan exchange rules say no.

Now, your main question — how does a bank know whether it’s a House BL or Marine BL?

 Here’s the trick:

Technically, yes — a Freight Forwarder can issue a BL and even sign it as “Carrier.” That’s allowed. But what matters is how they sign and who they’re signing for.

According to UCP 600 Article 20, a Marine Bill of Lading should:

• Mention the name of the actual carrier, and
• Be signed by:
  • the carrier, or
  • an agent for the carrier, or
  • the master, or an agent for the master.

If a forwarder issues and signs the BL in their own name, without clearly acting on behalf of the carrier, that’s usually a House BL — and not what the LC (or Moroccan rules) want unless it’s accompanied by a Marine BL.

So, banks will look closely at:

• Who issued the BL,
• How they signed (as Carrier? As agent?),
• Whether the actual carrier is named,
• And whether the document matches UCP Article 20 rules.

 Just to add:

People often talk about House BL versus Master BL — with the Master BL being the one issued by the ocean carrier (i.e. the Marine BL). So if you’re hearing “Marine BL,” think “Master BL” issued by the actual ship line, not the forwarder.

Hope that clears it up!

Cheers,

Mr. Old Man