House bill of lading vs master bill: which one is yours

Two documents can describe the same container, and only one of them is yours.

A house bill of lading is the bill an NVOCC issues to the importer. An NVOCC is a non-vessel-operating common carrier, which includes most freight forwarders selling ocean carriage. A master bill of lading is the bill the vessel operator issues for the same box, and the party named as shipper on it is the NVOCC. The importer is not on it at all.

Most desks discover this when something needs chasing and the vessel operator declines to discuss the shipment at all.

Why the chain has two links

The Federal Maritime Commission’s definition is unusually plain about the double role. Under 46 CFR § 515.2, an NVOCC is

a common carrier that does not operate the vessels by which the ocean transportation is provided, and is a shipper in its relationship with an ocean common carrier.

A carrier to you, a shipper to the ship. The same section lists “issuing bills of lading or other shipping documents” among the services it describes, so the house bill is not a courtesy copy. It is the contract of carriage the NVOCC sells.

The tariff rules say the same thing from the money side. 46 CFR § 520.2 defines a shipper to include “an NVOCC that accepts responsibility for payment of all charges applicable under the tariff or service contract”. On the master bill, your carrier is somebody else’s customer.

How to check a house bill against the master bill

This is the part a desk can do unaided, and CBP’s manifest rules are what make it checkable. 19 CFR § 4.7a(c)(4) sets out what the carrier must transmit “from the carrier’s ocean bills of lading, either master or house, as applicable”, and it requires different parties at each level.

The shipper. At master bill level on a consolidated shipment, the NVOCC, forwarder or container station is sufficient. For each house bill in that consolidation, the shipper must be “the identity of the foreign vendor, supplier, manufacturer, or other similar party”, and the regulation then says the quiet part out loud:

by contrast, the identity of the carrier, NVOCC, freight forwarder or consolidator is not acceptable

So a house bill that names your forwarder as the shipper is not a formatting preference. It means the party CBP expects to see, the actual supplier at a foreign address, is missing from the data filed about your cargo.

The consignee. At master bill level the NVOCC may be listed. On a house bill the consignee is “the party to whom the cargo will be delivered in the United States”. Where the goods move to order of a named party, that named party is reported as consignee and any other commercial party on the bill goes in the Notify Party field, which is why the arrival notice can reach a desk that is not the consignee.

The count. Both levels must be manifested at the lowest external packaging unit. Containers and pallets are, in CBP’s words, not acceptable manifested quantities: a container of ten pallets holding two hundred cartons is two hundred cartons. A house bill showing one container against a master bill showing cartons is not two views of the same truth.

The co-loading annotation. If your NVOCC handed the cargo to a second NVOCC, you are entitled to know on the document itself. 46 CFR § 520.11(c)(3):

An NVOCC which tenders cargo to another NVOCC for co-loading, whether under a shipper-to-carrier or carrier-to-carrier relationship, shall annotate each applicable bill of lading with the identity of any other NVOCC to which the shipment has been tendered for co-loading. Such annotation shall be shown on the face of the bill of lading in a clear and legible manner.

Four comparisons, all of them doable from two documents you already hold. None of them needs the vessel operator’s cooperation, which is convenient, because it is rarely offered.

What follows the house bill rather than the master

Three things, and each one costs money when the desk assumes otherwise.

Free time. The allowance that matters is the one in the contract you are party to, and on a house bill that is the NVOCC’s. Its carrier tariff is filed under part 520 and its free time may differ from the vessel operator’s on the identical box. Reading the wrong one is the mistake behind working out how to calculate demurrage charges from a figure nobody can hold you to. Where that figure sits in a service contract instead, it is not published at all.

Recourse. A claim travels back along the arrow you signed. What stands behind it is set by 46 CFR § 515.21: $75,000 of financial responsibility for an NVOCC in the United States, $150,000 for a registered non-US one, which is “strictly responsible for the acts and omissions of its employees and agents, wherever they are located”. A group or association covers its members at the lesser of the per-member amount or $3,000,000 in aggregate. Those are the figures standing behind every house bill that carrier has issued, not behind yours alone.

The terms, in advance. Under 46 CFR § 520.4(a)(5) a published tariff must include sample copies of any bill of lading “showing legible terms and conditions”. Section 520.11(a) adds the surety’s name and the bond number. So the document that will govern your cargo, and the pot of money behind the party issuing it, are both readable before the booking, in a filing rather than in an email you are waiting for.

The four questions, and when to ask them

Which bill will I be issued, house or master. The answer decides every row in the table above.

If it is a house bill, which tariff is my free time in, and is the figure in it or in a service contract I cannot read.

What is the issuing NVOCC’s bond number and surety, from its own tariff.

Has the cargo been co-loaded, and does the annotation appear on the face of my bill.

All four are answerable before the vessel sails and all four are usually answered after the invoice arrives. Chasing them on every shipment, from the booking rather than from the arrival notice, is the work Docket does: demurrage and detention software that counts from the bill you hold.