Switch Bills of Lading: Issue Date vs. On-Board Date under UCP 600

In documentary credit practice, questions often arise about the relationship between the bill of lading issue date and the on-board date—especially in cases involving switch bills of lading and high-seas sales. Can the two dates differ significantly, and if so, what do UCP 600 and ISBP 821 say about it?

QUESTION

Dear Mr. Old Man,

May I seek your opinion on the following scenario?

If goods are sold on high seas and a switch bill of lading is issued, the on-board date is shown as 01-Aug-25 while the BL issue date is 15-Aug-25. The LC tenor is 30 days after the BL issue date.

Would this be considered acceptable under trade practice and UCP/ISBP standards, provided the client explains that the switch BL was due to a high-seas sale? Also, if the on-board date and BL issue date are significantly far apart, is this in itself a concern?

I would appreciate your guidance on how such situations are generally viewed.

Kathryn

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ANSWER

Dear Kathryn,

Thank you for your interesting question.

First, banks do not concern themselves with whether a bill of lading is original or a switch bill, as long as it complies with the terms of the credit and UCP 600.

Under UCP 600, Article 20(a)(ii), a bill of lading must indicate that the goods have been shipped on board a named vessel at the port of loading. Importantly, the issue date of the bill of lading can be the same as, earlier, or later than the on-board date.

This is clarified in ISBP 821, paragraph E6(a):

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. In the latter case, the date of shipment is the on-board date, whether it is before or after the issue date.

In your case, the bill of lading shows:

• On-board date: 01-Aug-25
• Issue date: 15-Aug-25

This is acceptable under UCP and ISBP. In practice, it is common for goods to be loaded earlier and for the carrier to issue the bill of lading later.

However, a 15-day gap between the on-board date and the issue date is quite long. While not a discrepancy in itself, it may raise commercial questions. If the parties are aware of the high-seas sale and the switch bill explains the gap, banks will usually accept it. But if the gap is excessively long (say 30 days or more), the buyer should verify the reason, as it could affect risk perception.

So, to answer directly:

• Yes, it is acceptable under UCP/ISBP standards.
• No, the fact that it is a switch BL does not change compliance.
• But, a long delay between shipment and issuance may warrant extra caution from the applicant.

Best regards,

Mr. Old Man