The Position of Shippers under the Rotterdam Rules
D. Rhidian Thomas*
The Position of Shippers under the
Rotterdam Rules
I. Introduction
One of the many significant features of the Rotterdam
Rules1 is the prominence that they give to the position
of shippers. There should be nothing unusual about
this because the shipper is a principal party to the
international carriage of goods wholly or partly by sea
with which the new Rules are concerned. Nonetheless,
over the history of the international regulation of
carriage of goods by sea, commencing with the original
Hague Rules in 1924,2 the spotlight has been directed at
the carrier, with the shipper given very little attention.
This probably reflects an historical emphasis on the
need to regulate international carriers of goods by sea
rather than the bilateral contract of carriage.
In the Rotterdam Rules the position changes signifi-
cantly with ‘shipper’ defined3 and a new concept of
‘documentary shipper’ recognised.4 Thereafter an
entire chapter, Chapter 7, running from Articles 27
to 34 (8 articles) is devoted to the ‘Obligations of the
shipper to the carrier,’ and with the legal position of
shippers further entrenched by Article 79(2), which
renders void any attempt to vary the legal duties and
liabilities imposed by the Rules.
It is probable instructive to come to an examination
of the legal position of shippers under the Rotterdam
Rules by first briefly examining and comparing
the approach adopted to shippers in the preceding
conventions.
II. Hague and Hague-Visby Rules
Under both versions of the Hague Rules, the shipper is
not isolated and defined but there are various acknowl-
edgments that he is the person with whom the carrier
contracts.5 There is no attempt to impose express
obligations upon shippers, as is done with regard to
carriers,6 but a small number of obligations and rights
may be extracted, either as a matter of interpretation or
impliedly, from the body of the Rules.
The most significant provision is probable the strict
liability imposed upon the shippers of dangerous cargo
under Article IV(6), but apart from specifying the con-
sequences of shipping dangerous cargo, the sub-article
does not expressly create an obligation to disclose.7
Many of the exclusions specified in Article IV(2) also
imply duties owed by shippers, in particular a duty
to sufficiently pack goods,8 a duty to sufficiently and
adequately mark goods,9 and a duty not to do any act
or omission that will cause loss to the goods.10
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These implied duties are supplemented by Article IV(3)
which hints at the recognition of a general duty of care
owed to carrier and ship,11 though this sub-article has
always been of uncertain import. However, it is now
established that it does not override the strict liability
of shippers in relation to dangerous cargo established
under Article IV(6).12
The shipper also guarantees the accuracy of informa-
tion furnished by him in the bill of lading relating to
the marks, number, quantity and weight of the goods,
and is under an obligation to indemnify the carrier for
liability arising from any inaccuracy.13
The only right that is clearly recognised is the right of a
shipper to demand a bill of lading.14
With regard to the liabilities of shippers, the exclusions
in Article IV(2) and the right to limit liability in Article
* Professor of Maritime Law; Director, Institute of Inter-
national Shipping and Trade Law, Swansea University, Wales,
UK.
This article is based on the lecture held by the author at the
conference ‘the Rotterdam Rules appraised’ on 24 September
2009 at the Erasmus University Rotterdam.
1. UN Convention on Contracts for the International Carriage
of Goods Wholly or Partly by Sea 2009 (Rotterdam Rules).
2. International Convention for the Unification of certain Rules
of Law Relating to Bills of Lading 1924 (Hague Rules).
3. Art. 1(8).
4. Art. 1(9), considered infra.
5. For example, the definition of ‘Carrier’ includes the owner
or the charterer who enters into a contract of carriage with a
shipper – Art. 1(a).
6. Under Art. III(1) relating to seaworthiness and Art. III(2)
relating to the exercise of reasonable and proper care.
7. Mediterranean Freight Services Ltd v. BP Oil International
Ltd (The Fiona) [1993] 1 Lloyd’s Rep 257.
8. Art. IV (2)(n).
9. Art. IV(2)(o).
10. Art. IV(2)(i).
11. The sub-article provides – ‘The shipper shall not be
responsible for loss or damage sustained by the carrier or the
ship arising or resulting from any cause without any act, fault
or neglect of the shipper, his agents or servants’.
12. Effort Shipping Co Ltd v. Linden Management SA (The
Giannis NK) [1998] A.C. 605, [1998] 1 Lloyd’s Rep 337(HL);
Bung SA v. ADM DO Brasil Ltda and Others (The Darya
Radhe) [2009] EWHC 845(Comm), [2009] 2 Lloyd’s Rep
175.
13. Art. III(5).
14. Art. III(3).
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IV(5) are not applicable, nor is the one-year time limit
in Article III(6).
It is also recognised in many common law jurisdic-
tions that some of the performance obligations set
out in Article III(2) and which are capable of being
performed by shippers – namely loading, handling,
stowing and discharging – can be assumed by shippers
as contractual obligations.15
III. Hamburg Rules
Under the Hamburg Rules16 the shipper enjoys a little
greater prominence. In the first place a definition of
shipper appears in article 1(3) in the following terms:
‘“Shipper” means any person by whom or in whose
name or on whose behalf a contract of carriage of
goods by sea has been concluded with a carrier, or
any person by whom or in whose name or on whose
behalf the goods are actually delivered to the carrier in
relation to the contract of carriage by sea.’
This is an extended definition which anticipates a
similar but not identical approach in the Rotterdam
Rules. ‘Shipper’ is defined in terms of the contractual
shipper, meaning the shipper who enters into a contract
of carriage with the carrier, and a shipper who, not
being the contractual shipper, delivers the goods to the
carrier in relation to a contract for carriage of goods
by sea. A party who is associated with the shipment of
cargo in either manner is ‘shipper’ for the purpose of
the Hamburg Rules and therefore assumes the obliga-
tions and potential liabilities of a shipper.
Part III of the Rules, incorporating Articles 12 and 13,
is titled ‘Liability of the shipper’.
Article 12 lays down a general rule that a shipper or his
servants and agents is not liable for any loss sustained
by carriers and actual carriers, or by the ship, in the
absence of fault or neglect. This provision makes it
clear that shippers cannot be rendered strictly liable
and is equivalent to Article IV(3) of the Hague Rules.
Apart from setting out the basis of potential liability,
no specific duties are recognised. This is left to the
supporting role of the governing law of the contract.
An exception to the general rule set out in Article 12
is found in Article 13, which establishes the liability of
shippers in respect to the shipment of dangerous cargo
and also the corresponding rights of carriers. In respect
to liability, the provision is different from Article
IV(6) of the Hague Rules in so far as it established two
express duties. First, a duty to mark and label in a suit-
able manner dangerous goods; and, secondly, a duty to
disclose to the carrier or actual carrier the dangerous
nature of the cargo, and, if necessary, the precautions to
be taken, in circumstances where the carrier or actual
carrier does not have knowledge of the dangerous
nature of the goods. In the event of breach of either
duty, the liability of the shipper is strict.
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The Position of Shippers under the Rotterdam Rules
When, on the other hand, the duty of disclosure is
properly discharged, then the presumed fault regime of
the Hamburg Rules prevails and the rights of carriers
are restricted to circumstances when the goods shipped
become an actual danger.
A wider examination of the Rules reveals further
relevant provisions relating to the legal position of
shippers. Shippers have the right to demand a bill of
lading and also guarantee the accuracy of information
appearing in the bill of lading relating to the general
nature of the goods, their marks, number, weight and
quantity; and are also obliged to indemnify carriers
for any liability arising from the inaccuracy of this
information.17
More generally, under the Rules, the right to limit
liability is restricted to carriers and actual carriers,18
although the two-year time limit applies to claims
initiated by both carriers and shippers.19 The Hamburg
Rules being a presumed fault regime, there are no
exclusions of liability.
The jurisdiction and arbitration provisions apply
mutually to shippers and carriers.20
IV. Rotterdam Rules
As previously observed in the introduction to this
article, the treatment of shippers under the Rotterdam
Rules is advanced significantly.
Following the lead given by the Hamburg Rules two
categories of shipper are recognised and are defined as
follows:
‘Shipper’ means a person that enters into a contract of
carriage with a carrier;21
‘Documentary shipper’ means a person, other than the
shipper, that accepts to be named as ‘shipper’ in the
transport document or electronic transport record.22
‘Shipper’ in its primary meaning alludes to the
contractual shipper, and the wider concept of ‘docu-
mentary shipper’ means any other person who agrees
to be named as shipper in a traditional or electronic
transport document. The documentary shipper is not
necessarily analogous with the Hamburg Rules concept
of a shipper who actually delivers the goods to the
carrier.
15. Renton v. Palmyra Trading Corp. [1957] A.C. 149; Jindal
Iron & Steel Co v. Islamic Solidarity Shipping Co. [2005] 1
Lloyd’s Rep 57 (HL).
16. UN Convention on the Carriage of Goods by Sea 1978.
17. Art. 14(1).
18. Arts 6, 8 and 10.
19. Art. 20.
20. Arts 21 and 22.
21. Art. 1(8).
22. Art. 1(9).
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 The Position of Shippers under the Rotterdam Rules
In Chapter 7 (Articles 27 to 34), entitled ‘Obligations
of the shipper to the carrier’, there are set out a range
of duties which in their generality oblige the shipper
to deliver the goods for safe carriage and to perform
those obligation relating to the carriage contractually
assumed by him; and to cooperate with and provide
the carrier with such information requested or which
may be for the carrier’s benefit. These duties also apply
to documentary shippers. The duties are drafted in
much detail and what follows is a succinct statement
of the essential substance of the duties. The shipper is
under a duty:
– to deliver the goods ready for carriage, such as to be
able to withstand the intended carriage;23
– to properly and carefully pack cargo in or on con-
tainer/vehicle safely (where shippers obligation),
such as not to cause harm to persons or property;24
– to disclose the dangerous nature of cargo (when not
known by the carrier) and to mark or label danger-
ous good in an appropriate manner;25
– to properly and carefully perform any obligations
assumed under Article 13(2), namely to load,
handle, stow and unload the goods;26
– to cooperate with the carrier in providing informa-
tion and instructions relating to the carriage of the
goods;27
– to provide the carrier with information, instruc-
tions and documents relating to the goods and the
proposed carriage;28
– to provide accurate information for the compilation
of contractual particulars and issuance of transport
documents/records;29
– to provide information, instructions or documents
relating to the goods when the controlling party has
failed or been unable to provide the information;30
and
– to guarantee the accuracy of information compiled
in the transport document and to indemnify the
carrier for loss resulting from any inaccuracy of this
information.31
The duties and liabilities of shippers and documentary
shippers under the Rules are incapable of being directly
or indirectly excluded, limited or increased by contract
save to the extent such a variation is permitted by the
Rules. Any attempt by contract to effect such a vari-
ation is void.32 This is a new development associated
with the Rotterdam Rules which brings the entrenched
status of the duties and liabilities of shippers into line
with the long-established position relating to the duties
and rights of carriers.33
The liability of the shipper is dependent on proof of
personal or vicarious fault of the shipper, with the
burden of proof on the carrier.34 Loss or damage must
also have been caused by the shipper’s breach of duty.
In the absence of fault or causal loss the shipper is not
liable, save in the case of dangerous cargo and with
regard to the guarantee of the accuracy of information
included in the transport document or receipt.35
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The two-year time limit applies to all claims under
the Rules, claims against carriers and shippers.36 The
right to limit liability applies to the liability of car-
riers only,37 as also do the defences in Article 17(3).
The defences applicable to shippers are restricted to
those set out in Chapter 7. The provisions relating to
jurisdiction clauses38 and arbitration agreements39 relate
to proceedings against carriers only.
Documentary shippers are subject to the same obliga-
tions and liabilities as are imposed on shippers under
Chapter 7 and Article 55, and take the benefit of the
shipper’s rights and defences under Chapter 7 and
Chapter 13 (time for suit).40 Subject to conditions, a
documentary shipper may also come under a duty
to provide information, instructions or documents
relating to the goods.41
V. Some Observations on the Position of
Shippers under the Rotterdam Rules
1. Concept of ‘Documentary Shipper’
The Rotterdam Rules follow the Hamburg Rules in
favouring an extended definition of ‘shipper’, but
define the extension differently. Under the Hamburg
Rules, the person who delivers the goods to the carrier
for carriage under a contract of carriage is included
as ‘shipper’, whereas under the Rotterdam Rules
the extension is restricted to a party, other than the
contractual shipper, who agrees to be named as shipper
in the transport document or electronic transport
record. It is, of course, possible for a party associated
with the loading of a ship to fall within each definition,
but this will not always be the case. The definitions
take different approaches to the extended concept of
shipper and their application may result in different
conclusions. The ultimate consequence is that the
documentary shipper stands in the same legal position
as the contractual shipper.
23. Art. 27(1).
24. Art. 27(3).
25. Art. 32.
26. Art. 27(2).
27. Art. 28.
28. Art. 29.
29. Art. 31.
30. Art. 55(2).
31. Art. 31(2).
32. Art. 79(2).
33. See Art. 79(1); and Hague Rules Art. III(8), Hamburg Rules
Art. 23.
34. Arts 30 and 34.
35. Art. 30.
36. Arts 62-64.
37. Arts 59-61.
38. Chapter 14.
39. Chapter 15.
40. Art. 33.
41. Art. 55(2).
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A principal precondition to the characterisation is
that a documentary shipper is a person who has not
entered into a contract of carriage with the carrier. The
definition does not appear to preclude the servants,
agents or independent contractors acting for a contrac-
tual shipper from being recognised as documentary
shippers. More probable examples are freight forward-
ers, loading and discharging agents, international
sellers and buyers, and even a bank may be named in a
transport document in the way contemplated.
The predominant intention underlying the proposal,
it would seem, is to ensure that a FOB seller is char-
acterised as a documentary seller under the Rules and
thereby exposed to the same obligations and liabilities
as the contractual shipper, who on this presupposition
would be the buyer. This manner of thinking suggests
that what is in mind is what is sometimes described as
a strict FOB contract, with the ship fixed by the buyer,
usually under a charterparty contract, and with the
buyer, therefore, also the contractual shipper. In this
circumstance if the seller on loading the ship takes a
transport document or electronic record which names
him as shipper, the seller will be a documentary shipper
for the purposes of the Rotterdam Rules.
There are all manner of potential problems surround-
ing this particular proposal. I confine myself to two
comments.
The FOB sale contract is very fluid and therefore there
exist many varieties of contract. There may be variation
in the contractual position adopted by the seller, the
transport documents adopted and the manner in which
the documents are completed.
In most common law systems the FOB seller will
stand in some kind of contractual relationship with the
carrying vessel, though it may be restricted in point of
time and performance obligations, notwithstanding the
type of the transport document issued or the way in
which the seller is described therein.42 To this extent the
initiative taken in the Rotterdam Rules is unnecessary
in relation to such jurisdictions. But the emergence of
the Rotterdam Rules may raise the future question as
to whether such FOB sellers are to be characterised
as contractual or documentary shippers, should that
distinction ever be relevant, and, more fundamentally,
whether the Rules will exert an influence and possibly
effect change on the common law analysis.
A further question is whether the Rotterdam Rules will
have the effect of excluding the influence of national
law on the relationship between an FOB seller and the
carrying ship, with, for example, a contract only exist-
ing when the seller is named as shipper in the transport
document or electronic record. In other words, will
an FOB seller only be bound by the Rules when he
agrees to be named as seller in the transport document
or electronic record? And do the Rules preclude any
other relationships existing that might be recognised
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The Position of Shippers under the Rotterdam Rules
under national law? On the face of matters, the Rules
do not appear to exclude legal relations between FOB
sellers and carriers arising outside the ambit of the
Rules.
2. Shipper’s and Documentary Shipper’s Obligation
not to Deliver/Ship Dangerous Cargo
The subject of dangerous cargo is addressed in the
Hague and Hague Visby Rules, Article IV(6) (the
provision is precisely the same in each version of the
Hague Rules) and in the Hamburg Rules, Article 13,
where the drafting is different. Whereas this aspect has
received little published attention, a body of interest-
ing judicial law has developed about the concept of
dangerous cargo in the Hague Rules.
Under the Rotterdam Rules, the treatment of danger-
ous cargo is more fragmented. Article 3243 addresses
the duties of shippers to disclose the dangerous nature
and character of cargo, and in turn this provision must
be read in association with: Article 30(2),44 which
indicates that the liability is strict; Article 15,45 which
enumerates the rights possessed by carriers when
goods become a danger; and Article 33(1),46 which
indicates that the duties of documentary shippers
are the same as contractual shippers. This is not the
place to undertake a close analysis of these provisions
42. Pyrene Co v. Scindia Navigation Co. [1954] 2 QB 402.
43. Art. 32 provides –
‘When goods by their nature or character are, or reasonably
appear likely to become, a danger to persons, property or the
environment:
(a) The shipper shall inform the carrier of the dangerous
nature or character of the goods in a timely manner before
they are delivered to the carrier or a performing party. If the
shipper fails to do so and the carrier or performing party
does not otherwise have knowledge of their dangerous nature
or character, the shipper is liable to the carrier for loss or
damage resulting from such failure to inform; and
(b) The shipper shall mark or label dangerous goods in
accordance with any law, regulation or other requirements of
public authorities that apply during any stage of the intended
carriage of goods. If the shipper fails to do so, it is liable to
the carrier for loss or damage resulting from such failure.’
44. Article 30(2) provides – ‘Except in respect of loss or damage
caused by breach by the shipper of its obligations pursuant to
articles 31, paragraph 2, and 32, the shipper is relieved of all
or part of its liability if the cause or one of the causes of the
loss or damage is not attributable to its fault or to the fault of
any person referred to in article 34.’
45. Article 15 provides – ‘Notwithstanding articles 11 and 13,
the carrier or a performing party may decline to receive or
to load, and may take such other measure as are reasonable
including unloading, destroying, or rendering goods harm-
less, if the goods are, or reasonably appear likely to become
during the carrier’s period of responsibility, an actual danger
to persons, property or the environment.’
46. Article 33(1) provides – ‘A documentary shipper is subject
to the obligations and liabilities imposed on the shipper
pursuant to this chapter and article 55, and is entitled to the
shipper’s rights and defences provided by this chapter and by
chapter 13.’
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 The Position of Shippers under the Rotterdam Rules
but it must be recognised that the distribution of
risk and liability for dangerous cargo is changed,
possibly significantly, by the Rotterdam Rules. In the
present context I will confine myself to three concise
observations.
First, the test of danger is extended to include danger
to the environment. This is a fashionable and probably
uncontroversial extension. It is likely to be of greatest
relevance when a pollutant cargo is spilled into the
sea, causing pollution for which the owner is strictly
liable. Under the relevant international conventions,
the owner retains a right of recourse, which in the
circumstances here envisaged could be asserted against
the shipper of dangerous cargo.47
Secondly, it would appear that the distribution of lia-
bilities for the shipment of dangerous cargo is changed
significantly under the Rules. Under the Hague Rules,
the shipper is strictly liable for the shipment of cargo
that was dangerous at the time of shipment or became
dangerous in the course of voyage.48 Consequently, the
liability of shippers is very harsh because it extends
to include the shipment of benign cargo which for
some wholly unexpected or even previously unknown
reason became dangerous in the course of transit.
This extended wing of liability may not arise under
the Rotterdam Rules because the obligation to disclose
is a pre-delivery obligation, and because of the way
dangerous goods are defined. The characterisation
applies to goods which by their nature and character
are ‘or reasonably appear likely to become’ a danger
to persons, property and the environment. The result
would appear to be that if prior to delivery the shipper
has no reason to believe that the goods are likely to
become a danger, the goods are not dangerous and
there is no duty of disclosure, and consequently there
is no liability for the shipment of dangerous goods.
If this is a correct analysis, it results in a significant
modification of the liability regime relating to the
shipment of dangerous goods to the disadvantage of
carriers.
Thirdly, the rights of carriers, compared with the
Hague Rules approach, are also more restricted in rela-
tion to their powers of action when dangerous cargo is
shipped and as regard rights of indemnity in relation to
resulting expenses and liabilities. Their rights of action
are restricted to instances when the goods are, or
reasonable appear likely to become, an actual danger
during the carrier’s period of responsibility.49 And
their right of indemnity arising from any such action
is restricted to resulting ‘loss or damage’ but subject to
the condition that the shipper is in breach of its duty
of disclosure.50
3. Assumption of Performance Obligations by
Shippers
The performance obligations of carriers are set out in
Article 13(1):
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‘The carrier shall during the period of its responsibil-
ity as defined in article 12, and subject to article 26,
properly and carefully receive, load, handle, stow,
carry, keep, care for, unload and deliver the goods.’
It is made expressly clear in Article 13(2) that the par-
ties may agree that certain of these functions – loading,
handling, stowing or unloading – may be performed
by the shipper, documentary shipper or consignee. The
sub-article provides:
‘Notwithstanding paragraph 1 of this article and with-
out prejudice to the other provisions in chapter 4 and
to chapters 5 to 7, the carrier and shipper may agree
that the loading, handling, stowing or unloading of the
goods is to be performed by the shipper, the documen-
tary shipper or the consignee. Such an agreement shall
be referred to in the contract particulars.’
This provision appears to settle a long-running dispute
as to the proper interpretation of Article III(2) of
the Hague Rules. In specifying the duties of carriers
in those Rules the word ‘shall’ was used, which in
some jurisdictions was viewed as indicating that the
obligations were mandatory and not capable of being
delegated to shippers. In other jurisdictions, including
the English common law, a contrary approach was
adopted, with the drafting viewed as not prohibiting
the distribution of performance obligations that could
be performed by shippers.51
The Rotterdam Rules favour the approach adopted in
at least some common law jurisdictions. What is left in
some doubt is the legal implication of this redistribu-
tion of contractual functions under the Rules. In
particular, although the physical performance may be
contractually assumed by the shipper or documentary
shipper, there is at least the argument that the carrier
remains legally responsible unless it can establish a
defence under the Rules. It is to be noted that Article
13(2) is without prejudice to Chapters 5 to 7, and in
Chapter 5, the basis of the carrier’s liability is laid
down. On this basis, it is at least arguable that the car-
rier remains liable unless the shipper can be established
as a performing party and that the loss has been caused
by the fault of the shipper.52
47. E.g. International Convention on Civil Liability for Oil
Pollution Damage 1992, Article III(5).
48. The Athanasia Comninos [1990] 1 Lloyd’s Rep 277; Effort
Shipping Co. Ltd v. Linden Management SA (The Giannis
K) [1998] 1 Lloyd’s Rep 337; [1998] AC 605; Bunge SA v.
ADM DO Brasil Ltda and Others (The Darya Radhe) [2009]
EWHC 845(Comm); [2009] 2 Lloyd’s Rep 175.
49. Art. 15.
50. Art. 32(a).
51. Renton v. Palmyra Trading Corp. [1957] A.C. 149; Jindal
Iron & Steel Co. v. Islamic Solidarity Shipping Co. [2005] 1
Lloyd’s Rep 57.
52. Arts 17(2) and 18.
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 The Position of Shippers under the Rotterdam Rules

VI. A Final Comment

The Rotterdam Rules are a complex and troublesome
code. Every time they are studied, the reader is at risk
of coming away with a different understanding or with
a new uncertainty or difficulty revealed. Thoughts
readily drift in the direction of a seafarer furiously en-
deavouring to plug the leaks in a decayed wooden hull.
As each inlet is plugged another suddenly bursts into
life. What one discovers by scrutiny is often surprising
and one increasingly suspects that the surprises are not
always intended. The best that can be said about the
published record of the deliberations which led to the
emergence of the Rules is that they are rarely helpful.

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