A master bill of lading is issued by the ocean carrier to the NVOCC; a house bill of lading is issued by the NVOCC to the actual shipper. One container can travel under one master and several houses, and U.S. Customs expects different parties to appear at each level, so the two documents have to agree on everything they share.
An NVOCC sits between two contracts. FMC rules define it as a common carrier that does not operate the vessels by which ocean transportation is provided and that is a shipper in its relationship with an ocean common carrier (46 CFR 515.2). So when an NVOCC moves cargo, two bills of lading usually exist for the same box.
In a full-container shipment for a single customer there may be one house under one master. In an LCL consolidation, several houses share one master and one container. Either way, the ocean carrier only knows the master; the NVOCC is responsible for everything on the houses.
| Master bill of lading | House bill of lading | |
|---|---|---|
| Issued by | Ocean carrier that operates the vessel | NVOCC |
| Shipper shown | The NVOCC (for a consolidated shipment) | The actual shipper, such as the foreign vendor or supplier |
| Consignee shown | The NVOCC or its agent may be listed | The party to whom the cargo will be delivered in the U.S. |
| Covers | The whole container or consolidation | One customer’s cargo within it |
| Number prefix | Ocean carrier SCAC | NVOCC SCAC |
| Who relies on it | Ocean carrier, terminal, NVOCC | Shipper, consignee, bank, NVOCC |
CBP’s inward manifest rules spell out the difference directly (19 CFR 4.7a). For the shipper, the master bill level of a consolidated shipment may show the NVOCC, freight forwarder, container station or other carrier. For each house bill in a consolidated shipment, the shipper should be the foreign vendor, supplier, manufacturer or similar party, with a foreign address, and the identity of the carrier, NVOCC, freight forwarder or consolidator is not acceptable.
The consignee works the same way. At the master level of a consolidated shipment the NVOCC may be listed as consignee; for each house bill, the consignee is the party to whom the cargo will be delivered in the United States. If the cargo is shipped “to order of” a named party, that named party is reported as consignee, and other commercial parties go in the notify party field.
Two more rules catch NVOCCs often. Quantities must be reported at the lowest external packaging unit, so a container holding 10 pallets with 200 cartons is manifested as 200 cartons. And descriptions such as “FAK”, “general cargo” or “STC” are not acceptable.
Under 19 CFR 4.7(b)(3), when an NVOCC delivers cargo to the vessel carrier for loading at a foreign port, the NVOCC may transmit its cargo declaration data directly to CBP if it is licensed by or registered with the FMC and holds an International Carrier Bond. The data must be received 24 or more hours before the cargo is laden aboard the vessel at the foreign port. The alternative is to fully disclose the cargo information to the vessel carrier, which must then present it to CBP.
In practice, the ocean carrier files the master and the NVOCC, or the carrier on its behalf, files the houses. CBP links them, which is why a house that points to the wrong master or a master that does not account for its houses causes holds. Our guide on ACE AMS filing covers the filing itself.
Every bill of lading, master or house, needs a unique identifier of up to 16 characters: the issuer’s four-character SCAC followed by up to 12 letters or numbers, not reused for 3 years after issuance (19 CFR 4.7a(c)(2)(iii)). The master carries the ocean carrier’s SCAC; your house carries yours. Keep the master number on every house record so the link never depends on someone’s memory.
Software helps most in steps 4 and 5. In GDZ-ISIS, the stuffing module links loose cargo to dock receipts and bill of lading numbers and can create the master bill of lading, and the bill of lading module handles both master and NVOCC bills.
Each of these comes from the same root cause: two documents maintained separately. When the houses and the master are generated from one record, most of them disappear. For more on what a system should do here, see NVOCC software features that matter.
The master bill of lading is issued by the ocean carrier to the NVOCC. The house bill of lading is issued by the NVOCC to the actual shipper for that shipper’s cargo. One master can cover several houses in a consolidated container.
In a consolidated shipment, 19 CFR 4.7a allows the NVOCC, freight forwarder, container station or other carrier to appear as shipper at the master bill level. At the house level, the shipper should be the foreign vendor, supplier or manufacturer.
Yes, if it is licensed by or registered with the FMC and holds an International Carrier Bond, according to 19 CFR 4.7(b)(3). Otherwise it must give the full cargo information to the vessel carrier, which files it.
The consignee deals with the NVOCC under the house bill, while the NVOCC or its agent deals with the ocean carrier under the master bill. Release terms depend on the bills issued; confirm your case with your attorney or broker.
The master should account for every house, and CBP requires quantities at the lowest external packaging unit, such as cartons rather than pallets or containers. Building the master from the stuffed houses keeps totals equal.