LC Document Compliance: Consignee Details on Certificate of Origin vs Bill of Lading

Understanding ISBP 821 L5 — A Practical Q&A

In trade finance, it’s not uncommon for exporters and document checkers to wonder how far they can “stretch” consignee information on different documents without triggering a discrepancy — especially when a bill of lading is issued “to order” and the certificate of origin (C/O) needs to name a consignee.

 This question from a colleague in the field touches on exactly that situation. 

Let’s unpack it with reference to ISBP 821, focusing on paragraph L5 — an essential tool for anyone dealing with documentary credits under UCP 600.

Question:

Hello Mr. Old Man,

Hope you are doing well. I need your explanation regarding a potential discrepancy between the consignee information on a bill of lading and a certificate of origin (C/O). Given that the LC requires the bill of lading to be:

• Consigned to the applicant, or
• Issued “to order of issuing bank,”

and the consignor on the certificate of origin could be a third party not named in the LC…

What is the correct consignee to put on the certificate of origin in this case?

And would it lead to a discrepancy? Do we need to amend the LC to avoid this?

Thanks and best regards,

Muna Najja

______

Answer:

Dear Muna Najja,

Thank you for your thoughtful question.

To address your concern, we can rely on ISBP 821, paragraph L5, which provides clear guidance on how consignee information may appear on a certificate of origin when the bill of lading is issued “to order.”

According to ISBP 821 L5:

When a credit requires a transport document to be issued “to order,” “to the order of shipper,” “to order of issuing bank,” “to order of nominated bank (or negotiating bank)” or “consigned to issuing bank,” a certificate of origin may show the consignee as any entity named in the credit except the beneficiary.

In the case of a transferred credit, the first beneficiary may be stated to be the consignee.

Who counts as “entities named in the credit”?

Commonly, these include:

• Applicant (importer)
• Issuing bank
• Advising bank
• Nominated/Negotiating bank
• Confirming bank (if specifically named)
• Notify party or any other entity expressly mentioned in the LC

Practical Tip:

While naming a nominated or confirming bank as the consignee on a certificate of origin is not practical for customs purposes, it is acceptable under ISBP. In practice, the consignee on the C/O is usually the applicant or simply “to order.”

So, is there a discrepancy?

No. As long as the consignee on the C/O is an entity named in the LC (other than the beneficiary), there is no discrepancy, even if the consignee differs from the bill of lading.

Should the LC be amended to avoid this?

No amendment is necessary. ISBP 821 provides sufficient clarity, so long as document checkers and the issuing bank are aligned with its provisions.

Hope this helps!

Best regards,

Mr. Old Man