Who has the obligation to issue the CMR waybill document?

Who issues the transport CMR waybill document

Regarding the obligation to issue the CMR waybll document (international transport document), we specify that the consignment note (CMR) is drawn up by the sender and the carrier and provides proof, unless proved otherwise, of the terms of the contract and the receipt of the cargo by the carrier.

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In the absence of registration of the carrier’s reasoned reservations in the consignment letter – CMR, there is a presumption that the cargo and its packaging were apparently good at the time of receipt by the carrier and that the number of packages and their markings and numbers were in line with the The letter of carriage.

According to art. 5 of the Convention of 19 May 1956 on the International Road Transport Contract (CMR), the consignment note is drawn up in three originals signed by the consignor and the carrier. These signatures being printed or replaced by the stamps of the consignor and the carrier if the law of the country in which the consignment note is drawn up so permits.

Who shall receive copies of the CMR consignment note document

The first copy shall be handed over to the consignor, the second shall accompany the consignment, and the third copy shall be retained by the consignor.

If the freight is to be loaded in different vehicles or if there are different types of cargo or separate lots, the consignor or the carrier has the right to ask for the drawing of letters of carriage for each used vehicle or for each type of cargo Or batch of goods.

Related resources: Create CMR documents online for free | What is a CMR consignment note.

Who issues the CMR document in UK cross-border transport?

Under Article 5 of the CMR Convention (Convention on the Contract for the International Carriage of Goods by Road, Geneva 1956), the consignment note is drawn up jointly by the consignor (sender) and the carrier. Both parties sign the document, and three originals must be produced at the time of loading.

The United Kingdom is a CMR signatory state — the UK ratified the Convention in 1967 and it continues to apply after Brexit. There is no UK-specific law that overrides the CMR Convention for international road transport. CMR governs any carriage for reward by road in a vehicle where the place of taking over and the place of delivery are in two different countries, at least one of which is a CMR contracting state.

In practice, the common approach used by UK hauliers is: the carrier (haulier) fills in the form, and the sender (shipper) checks and co-signs it before the vehicle departs. This division of labour reduces errors caused by unfamiliarity with transport terminology, while keeping legal responsibility aligned with the Convention.

Carrier obligations on CMR issuance in the UK

Before accepting goods for carriage, the carrier must verify the accuracy of the entries in the CMR that relate to the goods themselves. Article 7 of the CMR Convention makes the carrier liable for damage arising from incorrect, incomplete, or missing entries if those entries were supplied by the carrier.

Key fields the UK carrier must check or complete:

• Dangerous goods (field 13): ADR classification, UN number, packing group, and special instructions must be stated when applicable. Failure to record dangerous goods correctly exposes the carrier to criminal liability under UK ADR regulations.
• Special instructions (field 13 / 19): Temperature-controlled consignments require the agreed temperature range. Fragile goods require handling notes.
• Apparent condition of goods and packaging (field 18): The carrier must note any visible damage or discrepancy at the time of loading. Silence is taken as acceptance of goods in good condition.
• Weight and quantity (fields 11–12): Inaccurate weight declarations can lead to disputes with HMRC, port authorities, and the consignee.

If the CMR contains errors attributable to the carrier, Article 7 allows the sender or consignee to claim compensation for any resulting loss. Errors in dangerous goods fields may also trigger enforcement action by the Driver and Vehicle Standards Agency (DVSA) in Great Britain.

What happens if CMR is missing at UK customs?

Since January 2021, goods moving between Great Britain and the EU — or any non-UK country — require full customs documentation. While HMRC does not mandate the CMR document by name, the CMR consignment note is the primary proof of the transport contract and is routinely requested by:

• Border Force and HMRC officers at GB ports (Dover, Holyhead, etc.) as evidence of the consignment and its declared value.
• Customs brokers filing the import/export declaration — the CMR provides the goods description, weight, and consignee details needed for the customs entry.
• Insurance underwriters when processing cargo claims — a missing or unsigned CMR is the single most common reason for freight insurance claim rejection.

If the CMR document is absent at the border, practical consequences include: delays of 2–24 hours while supplementary documentation is obtained, potential HMRC query notices if the goods description cannot be verified, and carrier liability exposure because the consignment has no documented proof of condition at loading. Some ferry operators will refuse boarding for commercial vehicles that cannot produce a CMR or equivalent transport document for cross-border loads.

CMR issuance checklist for UK hauliers

Use this checklist before every international departure from or to the UK:

• Fields 1–2 (Sender / Consignee): Full legal name and address. For UK–EU routes, include the EORI number if known.
• Field 3 (Place and date of taking over the goods): Must match the actual loading address, not the registered office.
• Field 4 (Place designated for delivery): Full delivery address. Incomplete addresses delay customs clearance.
• Field 6 (Carrier): The primary carrier’s name and address. If subcontracting, successive carriers appear in field 36 on the reverse.
• Fields 10–15 (Goods description): Nature of goods, packing type, number of packages, gross weight, volume. Be specific — “general cargo” is insufficient for most customs entries.
• Field 13 (Special agreements / dangerous goods): Mandatory for ADR loads. Include temperature instructions for perishables.
• Field 18 (Reservations and observations by the carrier): Note any visible damage before signing. Silence = acceptance.
• Field 22 (Sender’s signature): Signed and stamped by the consignor at the loading point.
• Field 23 (Carrier’s signature): Signed by the driver or carrier representative at collection.
• Field 24 (Consignee’s signature): Completed upon delivery — confirms receipt.
• Copies: Minimum 3 originals — red copy for the sender, blue copy travels with the goods (carrier retains after delivery), green copy for the consignee. A fourth copy is recommended for customs retention at the border.

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