Ocean Bill of Lading with Inland Final Destination — Article 19 or Article 20?

Intro

One of the most common — and persistent — areas of confusion in document examination arises when a credit requires an ocean bill of lading, but the routing information in the L/C or the transport document refers to an inland final destination.

Does this automatically turn the document into a multimodal transport document to be examined under UCP 600 Article 19?

Or should the examiner stay with Article 20, focusing on the port-to-port shipment actually required by the credit?

Let’s look at a real-world scenario discussed by the ICC Banking Commission.

Question

Dear Mr. Old Man,

I would like to seek your opinion on a document examination situation involving the application of Article 19 or Article 20 of UCP 600.

An L/C requires presentation of a clean on board ocean bill of lading and shows the following shipment details:

• Field 44A: South Korea
• Field 44E: Any port in Korea
• Field 44F: Peru Callao Port
• Field 44B: Lima

The beneficiary presents an ocean bill of lading with these particulars:

• Place of Receipt: Blank
• Port of Loading: Ulsan, Korea
• Port of Discharge: Peru Callao Port
• Final Destination: Lima

Question:

Which article of UCP 600 should be applied in examining this bill of lading — Article 19 or Article 20?

Thank you in advance for your expert opinion.

Best regards,

Hoai Phuong

______

Answer

Dear Hoai Phuong,

Thank you for your question.

My short answer:

Article 20 is the correct provision to apply.

Explanation

1. Start with the credit — not the document title

UCP 600 and ICC guidance consistently stress one fundamental principle:

Transport documents are examined under the article applicable to the conditions stated in the credit.

In this case, the credit:

• Explicitly requires an on board ocean bill of lading
• Specifies a port of loading and a port of discharge
• Does not call for a multimodal or combined transport document
• Does not require a place of receipt

This establishes a port-to-port ocean shipment, which falls squarely under UCP 600 Article 20.

2. The role of Field 44B (Final Destination)

Field 44B indicates Lima, an inland location. However:

• Field 44B is a routing field, not a transport document requirement
• Its presence alone does not obligate the carrier to perform inland carriage
• It does not convert an ocean bill of lading into a multimodal document

Unless the credit clearly requires the carrier’s responsibility beyond the port of discharge, Article 20 remains applicable.

3. Why ISBP 821 D1(c) does not change the result

ISBP 821 paragraph D1(c) states that Article 19 applies only when:

“it is clear from the routing of the goods stated in the credit that more than one mode of transport is to be utilized.”

The examples given (inland place of receipt, inland final destination, inland “port”) are illustrative, not automatic triggers.

In this case:

• The credit does not require inland carriage
• The transport document shows only the ocean leg
• There is no indication of carrier responsibility for multimodal transport

Accordingly, the condition required to trigger Article 19 is not satisfied.

4. ICC Banking Commission confirmation

This conclusion is fully supported by ICC Opinion R751 (TA 735rev), where the ICC Banking Commission confirmed that:

• The transport document must be examined under Article 20
• The absence of a “Place of Receipt” is not a discrepancy
• An inland final destination does not, by itself, mandate Article 19

Conclusion

Article 19 applies only when the credit clearly requires or implies multimodal transport.

An inland final destination stated in Field 44B, without more, does not meet that threshold.

Where a credit calls for an on board ocean bill of lading and specifies ports of loading and discharge, the document is to be examined under UCP 600 Article 20.

A classic case where careful reading of the credit — rather than over-reliance on labels or assumptions — makes all the difference.

I hope this clarifies your question.

Best regards,

Mr. Old Man