A switch bill of lading is a replacement set of BLs issued by a carrier to substitute the original, allowing changes to commercial parties (shipper, consignee, notify) while preserving cargo and vessel integrity. For LSPs, switch BLs are legitimate but high-risk. Major freight associations now discourage their use due to fraud exposure. This playbook covers what actually can change, the mandatory verification process, red flags to reject, and how real-time tracking protects your audit trail.
Why LSPs Need to Understand Switch BLs (And Why Industry Warns Against Them)
Switch BLs are common in triangular trade, intermediary transactions, and when cargo is resold mid-voyage. But they’re also instruments of fraud used for sanctions evasion, tariff misclassification, and payment fraud.
2019 Industry Warnings: Both the WCA (World Cargo Association) and BIFA (British International Freight Association) officially discourage their use. The WCA states: “There are high risks to agents that involve themselves in this, especially at destination. If we receive any complaints regarding shipments involving switch B/Ls, we will make note on the members’ records. If we receive any further complaints, we may have to consider the agent’s membership status.”
2025 U.S. Compliance Alert: New forwarder liability rules mean LSPs can be held liable for routing decisions via third countries that appear to circumvent export controls. Switch BLs at transshipment hubs are a primary audit trigger.
What Switch BLs Actually Are
A switch bill of lading is a second set of bills of lading issued in substitution for the original set, where selected details are changed while the core shipment information (cargo, loading port, loading date, vessel, voyage, quantity, weight) remains identical.
The Core Principle: The switch must preserve cargo and vessel integrity. If it doesn’t, it’s fraud.
Why they’re issued:
- Carrier receives request from BL owner
- Original BLs are surrendered and cancelled
- Carrier issues new BLs with changed commercial details
- New BLs replace originals in the supply chain
Legitimate Use Cases (with LSP Risk Assessment)
Use Case 1: Triangular Trade (Commercial Confidentiality)
When it happens: Intermediary (trader, consolidator, forwarder) wants to hide supplier identity from end buyer. Shipper issues master BL to intermediary; intermediary issues switch showing themselves as shipper to final buyer.
What changes: Shipper (shows intermediary instead of original supplier), sometimes consignee pathway (shows intermediary’s customer)
What CANNOT change: Cargo (must be exact same product), loading port (original origin), loading date (original sailing date), vessel and voyage
LSP Risk Level: MEDIUM (legitimate commercial practice in trading) BUT HIGH if requestor is unknown or one-time party.
Example: Chinese factory ships electronics to Indian distributor. Distributor wants to hide Chinese origin from Vietnamese end-buyer (supply chain margin protection). Distributor requests switch showing themselves as shipper instead of Chinese factory. Cargo, loading port, vessel, loading date all identical. Only “shipper” field changes.
Compliance Red Flags for LSP: Is routing through high-risk countries (sanctioned nations, known evasion routes)? Does shipper have history with your company or is this first-time request? Are trade finance controls in place (L/C, payment guarantees)? Check shipper/consignee against sanction lists, DPL (Denied Parties List).
LSP Control: KYC (Know Your Customer) on shipper AND new consignee. Verify both parties through DPL screening. Confirm commercial invoice/PO for transaction. Get bank-co-signed LOI. Document business rationale.
Use Case 2: Documentation Expediting (Original Delayed)
When it happens: Cargo arrives at the discharge port before the original BLs. The consignee needs timely release and cannot wait for courier delivery. (Preferred options: request a telex or express release, or use a sea waybill where commercially and legally acceptable. Avoid issuing a switch while originals are in transit to prevent dual-set risk.)
What changes: Issue date and place of switch BL (dated LATER than original, shows when/where new BL issued)
What CANNOT change: Everything else (cargo, ports, dates, vessel all tied to original)
LSP Risk Level: low for telex or sea waybill when documentation matches commercial terms. medium to high if attempting a switch without surrender of originals.
Example: Shanghai to Singapore, 4-day voyage. Cargo arrives day 6. Originals in international courier on day 8 (DHL/FedEx). Consignee needs pickup immediately (demurrage ticking). Switch BL issued day 6. Consignee uses switch to claim cargo; originals stored as backup documentation.
LSP Control: confirm whether the shipment is under L/C. If not under L/C, obtain carrier approval for telex or sea waybill and align commercial documents. If a switch is still requested, only proceed after full surrender and cancellation of the originals, or against a bank-co-signed LOI that covers full cargo value and costs.
What CAN Change vs. What CANNOT Change (Critical Distinction)
CAN CHANGE (Permissible with carrier approval + LOI)
| Field | Why It Can Change | LSP Note |
| Issue Date of Switch BL | Must be LATER than original (reflects when new BL issued) | CRITICAL: Cannot be same date as original that’s fraud |
| Shipper | Intermediary issuing BL to hide supplier (triangular trade) | Requires strict verification; KYC on shipper/consignee |
| Consignee | New buyer in resale scenario | Verify new consignee identity |
| Notify Party | Can change who gets notified on arrival | Low-risk change |
| Goods Description (Limited) | Can add clarifying detail or correct typos | Do not change the product substance, marks, weight, quantity, or IMO status. |
CANNOT CHANGE (Immutable per Carrier & Insurance)
| Field | Why It Cannot Change | Red Flag If Requested |
| Port of Loading | Physical loading port; core contract term | REJECT immediately signals fraud intent |
| Loading Date | Actual shipment date; affects insurance, credit terms | REJECT signals L/C fraud or sanctions evasion |
| Vessel Name | Ship that carried the cargo; verifiable fact | REJECT impossible, fraud signal |
| Voyage Number | Specific voyage; verifiable fact | REJECT impossible, fraud signal |
| Cargo Description (Substance) | The actual product/nature must match exactly | REJECT if materially different product switching fraud |
| Quantity / Weight | Volume and tonnage must match | REJECT if different indicates misrepresentation |
| Dangerous Goods Declaration (if applicable) | DGD details MUST stay identical for safety | REJECT any changes safety violation |
| Reefer/Temperature Settings (if applicable) | Cannot change; affects cargo safety/viability | REJECT could cause spoilage or liability |
| Out-of-Gauge (OOG) Dimensions (if applicable) | Cannot change; affects handling/stowage | REJECT vessel already allocated space for original dimensions |
| Original Payment Terms & Legal Clauses | Contract terms already agreed | REJECT if changed |
| Freight Terms Already Invoiced | Cannot change if already paid | REJECT reopens payment disputes |
Switch BL Controls in 5 Steps
- Verify authority: Confirm the requester controls the full set of originals. If not, obtain a bank-backed LOI that covers cargo value and costs.
- Freeze the non-negotiables: Place of loading and discharge, shipped-on-board date, vessel, voyage, marks, quantity, weight, DG, reefer, and OOG stay identical to the original.
- Show true issuance details: The switch shows the true place and date of issue. Do not ante-date or post-date to meet L/C terms.
- Choose the right tool for speed: Prefer telex or express release, or a sea waybill, when papers lag. Use a switch only after surrender or with a strong LOI.
- Document everything: Timestamp screening results, carrier approvals, fee quotes, surrender, issuance, and release in one timeline.
Want the rejection cheatsheet? See 10 Red Flags That Should Stop a Switch Bill Request.
Carrier-Specific Switch BL Fees (CURRENT TARIFFS)
CMA CGM
- Switch BL Fee (Export): €80 per BL (standard); €230 per BL (Germany, effective July 15, 2025)
- X-Trade Switch: $150 USD per BL
- Post-Printing Amendments: USD 100 (Amendment Fee) + AED 525 (BL Reissuance Fee)
- Note: Rates vary by region/port; check your local CMA CGM office for current fees
Maersk
- Allows switches: Yes, with conditions
- Requires LOI: Yes, bank co-signed
- Fee: Varies by region; contact local office for current rates
MSC
- Allows switches: Yes, with conditions
- Requires LOI: Yes, always bank co-signed
- Fee: $250 USD (India region); varies significantly by location; verify locally before quoting
Hapag-Lloyd
- Allows switches: Yes, but cautious approach
- Requires LOI: Yes, typically strong LOI
- Fee: €200 per BL (Germany – “Extra BL” for switch); other regions vary; verify specific region rates before quoting
KEY POINT FOR LSPs: Fees and policies vary significantly by carrier AND by trade lane/region. Official tariffs change regularly (CMA CGM fees increased July 15, 2025). Change of destination is handled as a COD process and not via a switch BL. Always check current carrier tariffs in the specific region BEFORE quoting or processing switch requests. Contact carrier’s local office for most current rates.
P&I Insurance & Liability Implications (Why Industry Warns Against Switches)
When Shipowner P&I Insurance is VOID
Shipowner’s protection & indemnity (P&I) insurance is void (no coverage) if: Switch BL is issued with false/ante-dated information. LOI was not obtained or was inadequate. Requestor was not verified as owner. Original BLs were not cancelled before switch issued. Cargo description was misrepresented. Carrier/LSP knowingly participated in fraud.
Consequence: Carrier/LSP absorbs full liability for any cargo claims. No insurance backstop.
Liability Cascade (Who Sues Whom)
If switch is fraudulent: (1) Rightful owner of cargo sues carrier (misdelivery). (2) Carrier sues LSP under indemnity (claims LSP failed to verify/control process). (3) LSP’s liability insurance may also be void if switch was improper. (4) LSP absorbs uninsured liability (potentially cargo value + penalties + legal fees).
Example Cascade: Cargo worth $500K misdelivered due to fraudulent switch. Original holder sues carrier for $500K (misdelivery). Carrier’s P&I claims: insurance denies coverage (switch was improper). Carrier sues LSP/forwarder for $500K + $150K legal fees. LSP’s coverage is also contested (knowing participation in fraud). LSP potentially liable for $650K uninsured.
Why Industry Now Discourages Switches
2019 WCA (World Cargo Association): “Will not involve itself in Switch B/L business due to element of possible fraud…there are high risks to agents. If complaints received, member records marked. Further complaints may affect membership status.”
2019 BIFA (British International Freight Association): Actively discourage freight forwarders from handling switches due to fraud exposure.
Modern Shift: Industry is moving toward Electronic BLs (single-copy, cannot duplicate) and Sea Waybills (non-negotiable, no originals) instead of switches.
2025 Compliance Alert: New Forwarder Liability Rules
U.S. BIS (Bureau of Industry & Security) New Rules
As of 2025, LSPs/forwarders can now be held liable for routing decisions that appear to circumvent export controls via third countries.
What this means: Routing cargo through transshipment hubs to avoid direct shipment to restricted country = potential violation. Switch BLs at hubs known for sanctions evasion = audit trigger. Lack of documented commercial justification = presumed complicity.
LSP Compliance Requirement: Document business rationale for each switch request. Screen all parties against sanction lists. Maintain written verification trail. Flag suspicious patterns (repeated switches, known evasion routes).
Enforcement: LSPs can face fines, loss of export licenses, and individual liability.
Final Recommendations for LSPs
DO (Safe Switch BL Practice)
- Verify requestor is legitimate owner with all originals
- Run compliance screening (OFAC, DPL, sanction lists)
- Obtain bank-co-signed LOI before issuing
- Ensure originals are cancelled before switch issued
- Document business justification in writing
- Use TRADLINX to create audit trail
- Check carrier’s current tariff by region before quoting fees
- Reject requests that show any red flags
- Consult compliance counsel if uncertain
DON’T (Fraud Scenarios to Avoid)
- Issue switch without all originals located
- Issue without LOI (or weak LOI)
- Issue without compliance screening
- Ignore red flags (loading port change, cargo description change, suspicious routing)
- Allow LOI to be provided after issuance (“we’ll send it tomorrow”)
- Change issue date to match original (that’s fraud)
- Approve switches for one-time unknown requestors
- Assume switching is low-risk (major associations discourage it)
- Fail to document business justification
- Use outdated carrier fee information (tariffs change regularly)
Conclusion: Switch BLs Are Legitimate But Only With Strict Controls
Switch BLs are legitimate and widely used in triangular trade, resale scenarios, and transshipment consolidation. But they’re also high-risk instruments frequently used for fraud.
The LSP’s Approach: (1) Accept only legitimate requests (resale, transshipment, documentation expediting). (2) Reject any red flags (loading port change, cargo description change, unknown requestors). (3) Verify requestor authority (all originals in hand). (4) Screen for compliance risk (OFAC, DPL, sanction lists). (5) Require bank-co-signed LOI before issuance. (6) Cancel originals before issuing switch. (7) Use TRADLINX to document audit trail. (8) Keep permanent documentation trail.
Bottom Line: If you cannot justify the switch in writing, with all controls in place, and with no red flags don’t issue it. WCA and BIFA discourage switches for exactly this reason.
By following this playbook, you protect your company, your insurance coverage, and your compliance status.
Make every switch defensible
Frontline readers of this guide care about two things: fast intake decisions and a clean record when someone asks “why did you approve this.” TRADLINX Ocean Visibility gives you one place to see carrier events, add accountable notes, attach proofs, and export the timeline.
- Freeze the facts: add a note that lists the original particulars (POL, POD, shipped-on-board date, vessel, voyage, marks, packages, quantity, weight, DG/reefer/OOG) before any change request.
- Decide with evidence: attach KYC results, carrier replies, LOIs, and approvals to the same BL record with reviewer and timestamp.
- Use the right tool: when papers lag, record the choice to use telex or sea waybill and track release on the same timeline.
- Prove the sequence: export the timeline and store linked files with the job record to support audits and customer inquiries.
- Keep systems in sync: send events to your ERP or TMS by API so downstream teams act on the same truth.
Next step: Use TRADLINX Ocean Visibility on your next switch request to baseline the shipment, attach screening, and capture the true issue place and date before you approve.
Sources and References
Official Carrier Tariff Documents (As of June-July 2025)
- CMA CGM – Export Local Customer Service Charges (March 2025) – 80 per B/L switch fee (Export), $150 USD switch fee (X-Trade), amendment fees USD 100 + AED 525
- CMA CGM – Germany Local Charges (June 2025) – 230 per B/L switch fee effective July 15, 2025
- Hapag-Lloyd – Germany Local Charges (July 2025) – 200 per B/L for Extra/Switch BL
- Hapag-Lloyd – Great Britain Local Charges (July 2025) – Regional fee variations
- MSC – India Export Local Charges (2025) – $250 USD per BL switch fee (India region)
- CMA CGM – Guideline for Switch BL Release Process – Procedures and post-printing amendment fee structure
- MSC – Fee Updates Announcement (January 2025) – MSC fee adjustments effective February 2025
Authoritative Industry Guidance on Switch BL Risks & Controls
- Skuld Club – Switch Bills of Lading Guidance (2019) – Most authoritative source on switch BL risks, P&I implications, mandatory controls, and format requirements
- Westpandi – Bills of Lading Guide (P&I Claims) – Hague-Visby Article III Rule 3 explanation and carrier obligations
- Gard – When Irresistible Force Meets Immovable Object (2018) – Legal guidance on appropriate LOI wording for switch bills and correct issue date practices
- Miriam Goldby – Managing the Risks of Switch Bills of Lading (NUS Law Journal, 2019) – Academic analysis with case law and real litigation outcomes showing liability cascades
Industry Association Warnings & Positions
- Lloyd’s List Daily Briefing – BIFA Warning (February 2019) – British International Freight Association official warning on switch bill fraud risks
- WCA Fraud Risk Warning (October 2018) – World Cargo Association official statement discouraging switch BL use
Practical Guides & Industry Standards
- Cogoport – Switch BL: Meaning, Use & Procedure (October 2025) – Modern practical guide with India-based forwarder scenarios
- Investopedia – Can I Have More Than Three Original Bills of Lading? (February 2025) – Clarifies that 3 originals is industry standard, not legal requirement; more than 3 possible
- Wallenius Wilhelmsen – Can I Have More Than 3 Original BLs? – Confirms 3 is industry standard but not mandatory
- WMU Dissertation – Reasonable Number of Issuing Original Bills of Lading (2010) – Legal analysis confirming no mandatory requirement for BL sets under Hague Rules or UCP 600
- Legal Guide Ireland – Hague-Visby Rules Article III Rule 3 – Full text and explanation of carrier obligations regarding shipper figures
- Mekong Control – Cargo Shortage Claims: Who’s Responsible? (2022) – Hague-Visby Article III Rule 3 explanation regarding quantity statements
Compliance & Forwarder Liability
- TRADLINX Blog – Compliance Gets Personal: Forwarder Liability Under New U.S. Rules (April 2025) – 2025 BIS forwarder liability rules affecting routing decisions
Real-Time Tracking & Audit Trail Best Practice
- TRADLINX Real-Time BL Tracking – Industry standard for documenting switch BL verification steps, audit trail preservation, and timeline documentation admissible in disputes and compliance audits
Last verified: November 6, 2025 (Tariff documents verified through July 2025) | Volatility: High (carrier policies and fees change regularly; always verify current rates before each transaction)
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