Note to Chinese freight forwarders: Hapag-Lloyd has updated the terms of the bill of lading. If the
- Author:Maintenance network
- Release Date:2026-09-17
An adjustment to the terms of a bill of lading may allow some cargo owners and freight forwarders to conduct an additional compliance review when booking space.Recently, Germany's Hapag-Lloyd updated its standard bill of lading terms involving Russia, Belarus and Iran.The new terms are effective immediately and shipping documents covering the relevant markets will automatically be subject to the new compliance requirements.China, Hong Kong, Vietnam, India, South Korea, Singapore and other markets are within the scope of application.This change requires attention for cargo owners and forwarders who frequently operate transit trade, cross-border transshipment or goods involving sensitive destinations.
First, it is not only cargoes from Russia and Iran that need attention. According to a report published by the shipping media Container News on September 17, 2026, the main purpose of Hapag-Lloyd’s adjustment is to ensure that the transportation business complies with the sanctions imposed by relevant agencies such as the European Union, the United States, and the United Kingdom, and at the same time meets the company’s internal compliance requirements.The new clauses do not just address whether goods are shipped directly to Russia, Belarus or Iran.According to Hapag-Lloyd's updated regulations, relevant restrictions involve direct or indirect transportation of goods, as well as export, re-export and import.Simply put, the transportation route, transit arrangements and final destination of the goods may all become factors that need to be considered when the shipping company reviews it.Hapag-Lloyd will automatically add relevant clauses to the shipping documents based on the market where the loading port and unloading port are located.Currently, the scope of application includes 35 countries and regions, including China, Hong Kong, Vietnam, India, South Korea, Singapore, and multiple European, Middle Eastern and Asian markets.
2. What has really changed with this adjustment to the terms of the bill of lading?
First, it is not only cargoes from Russia and Iran that need attention. According to a report published by the shipping media Container News on September 17, 2026, the main purpose of Hapag-Lloyd’s adjustment is to ensure that the transportation business complies with the sanctions imposed by relevant agencies such as the European Union, the United States, and the United Kingdom, and at the same time meets the company’s internal compliance requirements.The new clauses do not just address whether goods are shipped directly to Russia, Belarus or Iran.According to Hapag-Lloyd's updated regulations, relevant restrictions involve direct or indirect transportation of goods, as well as export, re-export and import.Simply put, the transportation route, transit arrangements and final destination of the goods may all become factors that need to be considered when the shipping company reviews it.Hapag-Lloyd will automatically add relevant clauses to the shipping documents based on the market where the loading port and unloading port are located.Currently, the scope of application includes 35 countries and regions, including China, Hong Kong, Vietnam, India, South Korea, Singapore, and multiple European, Middle Eastern and Asian markets.
2. What has really changed with this adjustment to the terms of the bill of lading?
In the past, shipping companies' management of sanctioned countries was often reflected in stopping calls, suspending the receipt of cargo, or imposing booking restrictions on specific countries and regions.But the terms of the bill of lading are another matter.It is directly written into the transportation contract and related documents, clarifying the basis on which the shipping company can refuse transportation, restrict transportation, or require the customer to bear corresponding responsibilities under certain circumstances.This adjustment by Hapag-Lloyd at least sends a clear signal: sanctions compliance is no longer just an internal audit matter of the shipping company, but is further implemented in the transportation documents signed by customers.In particular, the clauses involve the direct and indirect transportation, export, re-export and import of goods, which means that the shipping company is not only concerned about "whether the cargo will eventually go to Russia."Where the goods come from, which countries they pass through, who trades them, and who they are ultimately delivered to may all affect the shipping judgment.Of course, this does not mean that Hapag-Lloyd will refuse to carry all goods involving relevant countries.Specific restrictions still need to be judged based on the original text of the terms, applicable laws and individual case circumstances.However, for cargo owners and freight forwarders, the past operational thinking of "as long as the destination port of the bill of lading is not in a sanctioned country, there should be no problem" is obviously no longer safe enough. 01
Why is the Chinese market also included in the scope of automatic application?
Among the 35 countries and regions listed by Hapag-Lloyd this time, Asian trade nodes such as China, Hong Kong, Vietnam, India, Singapore, and South Korea are among them.This part deserves more attention from Chinese shipping practitioners than simply emphasizing "restrictions on goods from Russia, Belarus and Iran".Because there are different forms of trade and transshipment connections between China and Southeast Asia markets and the above-mentioned countries.For example, a shipment of goods may be shipped from China, transited through a third country, and then headed to other markets.For shipping companies, the loading port and unloading port alone are sometimes not enough to determine whether the goods involve restricted trading arrangements.But two things need to be distinguished here: First, the applicable terms do not amount to a ban on trade.China's inclusion in Hapag-Lloyd's automatic scope of application does not mean that all Chinese export goods are restricted, nor does it mean that all goods transiting through China will be refused carriage.Second, the shipping company’s internal compliance requirements may be higher than the customer’s understanding of the legal bottom line.Shipping companies not only need to consider whether a certain shipment clearly violates sanctions, but also need to evaluate whether they may bear compliance risks due to transportation arrangements, transaction entities, or the destination of the goods.This is why shipping companies may further set internal audit requirements beyond the scope of transportation permitted by law.For cargo owners and forwarders, the real increase in workload is often not to fill in an extra form, but to verify the trade background and final flow of the goods more clearly.
3. What may be the impact on Chinese cargo owners and forwarders?From a practical point of view, the most noteworthy aspect of this change is not "whether we can still handle Russian and Iranian related goods", but that some transportation arrangements that could have been promoted normally may need to be completed earlier for compliance confirmation.Especially the following types of business: goods involving transit in third countries.Although the goods do not go directly to the sanctioned country, if the final destination, actual consignee or transaction arrangement involves relevant countries, further verification may be required.Goods involved in complex trade chains.When the shipper, payer, consignee and end-user are not the same entity, the shipping company may need more information to determine the true transaction background of the goods.Businesses involving sensitive goods or high-risk transaction entities.Even if the cargo itself does not fall into a category that is explicitly prohibited from transportation, the transaction entity or transportation arrangement may trigger an internal audit by the shipping company.For freight forwarders, if this type of review occurs before customs cutoff or even before shipment, it may affect not only booking, but also trailering, customs declaration, transit and delivery arrangements.Therefore, for goods involving relevant markets, it is best not to wait until the shipping company is close to shipment before starting verification.Confirming in advance whether it can be transported, what information is required, and how to deal with problems if they arise often provides more room for maneuver than adjusting the plan after the goods have arrived at the port.
Why is the Chinese market also included in the scope of automatic application?
Among the 35 countries and regions listed by Hapag-Lloyd this time, Asian trade nodes such as China, Hong Kong, Vietnam, India, Singapore, and South Korea are among them.This part deserves more attention from Chinese shipping practitioners than simply emphasizing "restrictions on goods from Russia, Belarus and Iran".Because there are different forms of trade and transshipment connections between China and Southeast Asia markets and the above-mentioned countries.For example, a shipment of goods may be shipped from China, transited through a third country, and then headed to other markets.For shipping companies, the loading port and unloading port alone are sometimes not enough to determine whether the goods involve restricted trading arrangements.But two things need to be distinguished here: First, the applicable terms do not amount to a ban on trade.China's inclusion in Hapag-Lloyd's automatic scope of application does not mean that all Chinese export goods are restricted, nor does it mean that all goods transiting through China will be refused carriage.Second, the shipping company’s internal compliance requirements may be higher than the customer’s understanding of the legal bottom line.Shipping companies not only need to consider whether a certain shipment clearly violates sanctions, but also need to evaluate whether they may bear compliance risks due to transportation arrangements, transaction entities, or the destination of the goods.This is why shipping companies may further set internal audit requirements beyond the scope of transportation permitted by law.For cargo owners and forwarders, the real increase in workload is often not to fill in an extra form, but to verify the trade background and final flow of the goods more clearly.
3. What may be the impact on Chinese cargo owners and forwarders?From a practical point of view, the most noteworthy aspect of this change is not "whether we can still handle Russian and Iranian related goods", but that some transportation arrangements that could have been promoted normally may need to be completed earlier for compliance confirmation.Especially the following types of business: goods involving transit in third countries.Although the goods do not go directly to the sanctioned country, if the final destination, actual consignee or transaction arrangement involves relevant countries, further verification may be required.Goods involved in complex trade chains.When the shipper, payer, consignee and end-user are not the same entity, the shipping company may need more information to determine the true transaction background of the goods.Businesses involving sensitive goods or high-risk transaction entities.Even if the cargo itself does not fall into a category that is explicitly prohibited from transportation, the transaction entity or transportation arrangement may trigger an internal audit by the shipping company.For freight forwarders, if this type of review occurs before customs cutoff or even before shipment, it may affect not only booking, but also trailering, customs declaration, transit and delivery arrangements.Therefore, for goods involving relevant markets, it is best not to wait until the shipping company is close to shipment before starting verification.Confirming in advance whether it can be transported, what information is required, and how to deal with problems if they arise often provides more room for maneuver than adjusting the plan after the goods have arrived at the port.