The United Nations General Assembly adopted the United Nations Convention on Negotiable Cargo Documents on 15 December 2025, a treaty developed by the United Nations Commission on International Trade Law (UNCITRAL). Its purpose is to introduce a treaty-based mechanism for the use of negotiable cargo documents across all modes of transport—something that already exists in practice for carriage of goods by sea in the form of bills of lading.

At first glance, the Convention appears to introduce a treaty-based concept of a negotiable transport document. The more relevant question, however, is not whether it operates independently from national law, but rather how it interacts with existing international regimes.

The explanatory notes are clear in that the Convention does not attempt to redefine the negotiability of documents as such. It leaves the question of negotiability to national laws. Instead, it focuses on narrower questions: when does a transport document qualify as an NCD under the Convention; how can such a document be transferred; who may claim delivery and who may claim damages, and from whom.

The mechanism is relatively straightforward. An NCD is issued “to order” or “to the order of a named person” and is transferred by endorsement. The explanatory notes explicitly state that this method was chosen in order to exclude straight bills of lading. The NCD should be noted as “negotiable”.

This approach to the transfer of order documents is not particularly controversial and is consistent with many national legal systems. Under Dutch law, for example, a straight bill of lading—although accepted as a document of title to which the Hague (Visby) Rules may apply—is not regarded as a negotiable document and cannot be transferred by endorsement, even though rights under it may still be assigned.

Although the explanatory notes state that the Convention does not create a liability regime and therefore does not interfere with existing conventions such as the CMR or the Hague (Visby) Rules, the introduction of a right for the holder to claim delivery and damages may, at first sight, appear to establish such a regime. One might therefore ask whether the Convention should, given its objective, have limited itself to defining the document and its transfer mechanics, leaving questions of liability entirely to national law or existing conventions.

In practice, however, the structure does not appear fundamentally different from many existing regimes, nor does it appear to conflict with them. At the very least, where other regimes provide a broader scope of entitlement to sue, the Convention does not appear to restrict that. Importantly, the Convention does not remove or replace claim rights that may exist under national law or other international conventions against carriers or performing carriers.

Nevertheless, the Convention may raise practical questions. One example concerns the position of freight forwarders. Under the Convention, only the transport operator may issue, or request the issuance of, an NCD. The transport operator is defined as the party that concluded the contract of carriage and assumed responsibility for performing it. The explanatory notes clarify that a freight forwarder acting purely as an agent, therefore, does not qualify as a transport operator.

However, practical difficulties may arise where a freight forwarder has not made it clear that it was acting solely as an agent and is therefore regarded as the contractual carrier, while at the same time not being the party that issued the NCD. Would a document requested by such a freight forwarder fall outside the scope of the NCD merely because it was not issued or requested by the transport operator?

Whether such situations will arise in practice remains to be seen. Given the involvement of banks and the typically strict requirements surrounding negotiable documents, the system may prove to be relatively robust. If a freight forwarder were to act outside its authority, any resulting liability would likely be addressed outside the scope of the Convention. Nevertheless, this is an area where future practice and case law may provide further clarification.

Challenges may also arise in the context of multimodal transport—an area that is not yet governed by a treaty with global reach and where liability regimes are often determined by the applicable national law. Under Dutch law, liability in multimodal transport is determined by the regime that would have applied to the leg of the transport where the damage occurred, as if that leg had been performed as a unimodal transport.

In situations where an NCD is issued, this could lead to interesting outcomes. For example, if damage occurred during the sea leg, the applicable regime might be more favourable to the transport operator who issued an NCD rather than under the Hague-Visby Rules if a bill of lading had been issued—unless the NCD for the sea leg would be treated as a bill of lading to which the Hague-Visby Rules would have applied in a unimodal context. And who is to say it will not?

Whether an NCD can be considered a bill of lading for the sea leg will likely have to be determined through case law in the various national jurisdictions. This is not entirely unrealistic. The Hague (Visby) Rules do not provide a strict definition of what constitutes a bill of lading, nor does Dutch national law. In practice, courts may well look at the substance of the document. If an NCD functions as a document of title, is issued to order, exists in original form, and can be transferred by endorsement, one could argue that it may also qualify as a bill of lading in substance. Much will depend on the nature of the agreed transport—whether unimodal or multimodal—and on the role of the sea leg within that transport.

What the Convention does underline, however, is the importance of clarity in transport documentation. If an NCD is used, it may be sensible to explicitly incorporate the relevant liability regimes for the different legs of the transport—for example, the Hague-Visby Rules for sea carriage or the CMR for road transport—particularly in a multimodal setting.

Another point that may be of interest from a Dutch law perspective concerns the right to bring a claim. Dutch case law traditionally grants that right to the rightful and regular holder of the bill of lading—and only to that holder—even if that holder did not personally suffer the loss. Other jurisdictions take a broader approach and allow claims by other parties involved in the transaction. If an NCD were to be treated as a document comparable to a bill of lading under national law, Dutch courts might well apply the same reasoning. This question will likely have to be answered by future case law and could potentially lead to different outcomes across jurisdictions.

In short, the NCD Convention does not appear to rewrite the rules of transport law. Rather, it provides a structured framework for issuing and transferring negotiable cargo documents. The real legal questions will likely arise not from the document itself, but from its interaction with existing liability regimes and national legal systems. For practitioners, that is probably where the most interesting discussions will begin.

 

Caland Advocaten is pleased to announce that as per February 1, Willemijn Putz will join our firm, bringing with her a valuable record of legal expertise and international experience in the maritime industry.

“I am excited to join Caland Advocaten at this stage in my career,” said Willemijn Putz. “I look forward to contributing to the firm’s growth and working closely with clients to deliver pragmatic, high-impact legal solutions.”

Her appointment follows the addition of Marieke van den Dool and Ynke Ooijkaas last year, who brought with them extensive experience in inland shipping and ship building; in particular yacht construction, enabling Caland to provide an even more complete offering.

The expansion enables Caland to invest even more time and energy in building client relationships by organizing information sessions, publishing in professional journals, and providing industry-wide support.

The new team, which also include as partners Richard van ‘t ZelfdeJitteke Blussé Van Oud Alblas, Flip van Huizen and Cherry Almeida, embodies the spirit of modern professionals: engaged, legally astute, digitally skilled, diverse, and passionate about their work.

Caland invites media and partners to meet its strengthened team, ready to tackle the most complex challenges in the maritime and transport sectors.

Caland Welcomes Ynke Ooijkaas and Marieke van den Dool – Expanding Expertise

Rotterdam, 6 October 2025 – Caland is delighted to announce that Ynke Ooijkaas and Marieke van den Dool have joined the firm. Their arrival adds valuable expertise in inland shipping and shipbuilding, with a particular focus on yacht construction, further expanding Caland’s already broad practice in maritime law.

“Ynke and Marieke bring experience that allows us to offer an even more comprehensive service to our clients,” said Cherry Almeida. “Our mission remains to serve clients across the full spectrum of maritime, transport and trade law – from ocean shipping to inland navigation, from superyacht construction to road transport, and from charter parties to insurance disputes.”

Their appointment follows the addition of Flip van Huizen last year, who brought with him extensive experience in road transport law and insurance law, enabling Caland to provide an even more complete offering.

The expansion enables Caland to invest even more time and energy in building client relationships by organizing information sessions, publishing in professional journals, and providing industry-wide support.

The new team, which also include as partners Richard van ‘t Zelfde, Jitteke Blussé Van Oud Alblas and Cherry Almeida, embodies the spirit of modern professionals: engaged, legally astute, digitally skilled, diverse, and passionate about their work.

Caland invites media and partners to meet its strengthened team, ready to tackle the most complex challenges in the maritime and transport sectors.

 

For more information on Caland Advocaten, please refer to www.caland.nl.

Press contact – Cherry Ameida – almeida@caland.nl, +316-24820047.

In two recent judgments Dutch courts have rejected the 2 year collision time bar defense.

Read here the latest article from Richard Van ‘t Zelfde on the topic.

2 year collision time limit

Click on the link below to read the full article:

Appointment of maritime court surveyors in the Netherlands

 

On 16 October 2019 the Rotterdam Court rendered an interesting judgment on the Dutch General Yardconditions “VNSI” (ECLI:NL:RBROT:2019:8389).

The Owners of a 70 meter long wooden replica of the Ark of Noah contracted with a Dutch shiprepair yard for some repairwork. To the repaircontract the Dutch General Yardconditions “VNSI” applied.

During the execution of the work fire broke out causing severe damage to the vessel, for which the ship owners held the repairyard liable.

Art. 13.2 of the Dutch General Yardconditions “VNSI”read as follows:

The yard shall not be liable for damages, except if and insofar as the yard shall inflict damages intentionally or through gross negligence. However, except in the case of intent on the part of the yard, liability of the yard for loss of profit, consequential or indirect damages is, at all times excluded. In this clause gross negligence or intent of the yard means gross negligence or intent of the yard’s officers and of managing officials identifiable with the yard.

This art 13.2 is clear: in principle the repairyard is not liable unless the damage has been caused intentionally or through gross negligence.

The Owners did not argue that the damage had been caused intentionally, but did argue that the damage had been caused through gross negligence. The court held that the Owners did not succeed in proving the gross negligence (which is indeed often difficult under Dutch law).

Therewith there remained for the Owners to argue that, shortly put, under the principles of reasonableness and fairness the repairyard should not be allowed to rely on the exoneration contained in art. 13.2 of the Dutch General Yardconditions “VNSI”.

There is Dutch case law in which it has been held, shortly put, that a party which is in principle entitled to invoke a (contractual) right, can nonetheless be denied such invocation where, in the given circumstances of the case, such would conflict with the Dutch principles of fairness and reasonableness.

In the subject judgment of NOAH’s ARK, the Rotterdam Court referred to its earlier judgment of 13 December 2006 (ECLI:NL:RBROT:2006:BD6181) in which it had held in a similar case, that invocation by the yard of art. 13.2 (in that case) did not conflict with the principles of fairness and reasonableness.

In that earlier judgment the Rotterdam Court held that invoking art. 13.2 Dutch General Yardconditions “VNSI” was not unreasonably onerous for the Shipowner:

  • since both the repairyard and the Owners were professional parties working in the shipping industry in which using general terms and conditions is common practice;
  • since the Dutch General Yardconditions “VNSI” are used by many Dutch ship repairyards;
  • since the repair contract clearly refers to the Dutch General Yardconditions “VNSI” which had been printed on the reverse side of the contract;
  • the Owners could have read the conditions and could have commenced negotiations with the repairyard in an effort to exclude art. 13.2 from applicability;
  • since an exclusion / limitation of liability is not unreasonable taking into account the possible liability and the price payable to the yard for the repair work;
  • the Owners were insured themselves against the suffered damage.

Since this remaining argument failed also, the Rotterdam Court rejected the Owners claims. This case confirms that in principle Dutch shipyards are able to rely on the Dutch General Yardconditions “VNSI” if applicable.

(Mr Richard van ‘t Zelfde, publication 06.11.2019)

The Dutch courts regularly deal with cases in which shipowners / charterers hold stevedores liable for damage to a vessel.

In some cases, the liability of the stevedore can be based (quite easily) on provisions of the Terminal Service Agreement in place with the stevedore.

In other cases, in particular when having to base the claim on tort (f.i. where the claiming party does not have the contract with the stevedore) the claim can prove more difficult to pursue, one reason being that it is a principal of Dutch law that “careless or otherwise unlawful acts cannot be deduced automatically from the mere fact of damage to property.”

Put more simply: where it is established that the stevedore caused damage to a vessel, the damage itself does not automatically prove that the stevedore has (also) commited a tortious act and therefore does not automatically lead to his liability for the damage.

A claimant will need to state and prove that the stevedore committed a tortious act for the tort claim to be able to succeed.

This was (first) held by the Dutch Supreme Court in its longstanding judgment HR 06.03.1953, NJ 1953/791 NICOLAS PATERAS and has been upheld in much lower case law ever since, also earlier this week by the Rotterdam (Maritime) Court in its judgment of 30.10.2019 (ECLI:NL:RBROT:2019:8469): “Now that Peak Shipping has not disputed that discharge was performed in the usual machinal manner, the crane operator will only be deemed to have acted unlawfully if he has not proceeded with the care that can be reasonably expected of him during machinal unloading.”

Being able to prove that a toritous act has been committed, is a factual question and it might be necessery, for instance, to (preliminary) hear witnesses such as the cranedriver and crewmembers to obtain evidence. Also the instruction of surveyors is often necessary.

In the above recent case, the Rotterdam Court rejected the claims by the vessels’ charterers, shortly put, on the grounds that the charterers had not sufficiently proven their standpoint that the stevedore committed a tortious act.

Mr Richard van ‘t Zelfde (posted on 03.11.2019)

Anyone who gets on board a ship is left at the mercy of the gods. Or so can it feel. But seafarers not only have to deal with the weather circumstances and the long time at sea. No. Also legally there is much more to it than one might at first think.

The Maritime Labour Convention was signed in 2006. After ratification by thirty countries it entered into force in 2013. A welcome development, as in a sense it provides the seafarer better protection and the sea employer more clarity. The member countries are obliged to implement in their national law the main guidelines or so-called Regulations as detailed in part A of the Convention. The treaty creates frameworks for the relationship between the sea employer and the seafarer. What are the obligations of shipping companies, ship owners and other employers in shipping? What happens in case of illness, accident or death? Note that under the treaty an employee is already a seafarer if there is an agreement to provide services on board a vessel. Whether sailing will actually take place, is irrelevant.

In the Netherlands, the mandatory guidelines of the treaty have been neatly implemented into the Dutch Civil Code in the so-called law on sea-employment. Quite clear one might think … But nothing could be further from the truth. … Under Dutch law the relevant code applies only to ships sailing under the Dutch flag. But exactly that flag is so interesting! If you employ a Dutch seafarer, Dutch law can apply because the seafarer has the Dutch nationality, but the law on sea-employment might not if the ship sails under a foreign flag. And so suddenly as an employer you (also) have to deal with the laws of Panama, Barbados, Jamaica or name some other (tax) paradise.

On the other hand you may have had good grounds to stay away from Dutch legislation. However the choice for the Dutch flag can pull you right back into the Dutch legislation. To make it even more complicated, the employer and the seafarer can mutually still choose a different law in the contractual negotiations. And so you suddenly find yourself dealing with three different laws! All of which cannot simply be ignored. It is therefore not surprising that everyone, shipping companies, ship owners and other employers in the maritime industry as well as the seafarer are sailing clueless. It is necessary for all parties that they know where they stand, especially when it comes to insurance.

Insurers can insure a ship owners’ liability for death or injury to a certain amount, but whether that is sufficient will depend on the applicable law and which one is that …? Advice is the motto. Not afterwards, but already at the time that the choice for a flag has to be made.

For each flag / party to the Maritime Labour Convention, the interpretations of the Convention can vary significantly. Already because the treaty provides mostly recommendations and not all mandatory rules. Top this to the possibility of different laws being applicable to the contract and you see that we are discussing a complex subject. All the more reason for you as an employer to ask yourself three times how your business is organized. Three times a charm remains!

Are you a ship owner, sea employer or seafarer and interested to learn more on sea-employment and the legal implications of a chosen flag? Please contact Caland advocaten.