Container eBL usage reached 12.8% in November 2025, against a carrier pledge of 100% by 2030
Back to the Trade Finance Guide
Ossiano Guides · Digital trade
An electronic bill of lading can do the legal work of the paper original only where the law treats control of the record like holding the paper. Since 2021, both the law and carrier use have moved sharply.
Terms like this have a quick explainer. Tap or hover on them.
01 · What it is
An electronic bill has to do the same job as the paper bill: stand for the goods
An , or eBL, is a standardized bill of lading that is issued and passed on electronically. That is how the Digital Container Shipping Association () describes it. The DCSA is a body that writes digital standards for container shipping.
To see why the electronic version is hard, start with the paper one. A is the document a issues when it receives goods to ship. It is also a , like a . In business, the person who holds it is entitled to receive, hold and dispose of the goods, under the Uniform Commercial Code. In plain terms, the paper stands for the cargo. Our guide to the bill of lading explains the paper version in full.
The of a bill is the person who has it and has a property right in it, under 49 USC 80101. Trade finance relies on the . It sends the goods "to the order of" a , the person the goods are delivered to, so the claim can be passed on. A names one consignee and cannot be passed on. Both are defined in 49 USC 80103.
A paper bill works because only one person can hold it at a time. A computer file can be copied. So the law needed a new idea to replace holding the paper. , a model law from the UN trade law body UNCITRAL, supplies it. Under MLETR, of an electronic record replaces possession of a paper , per UNCITRAL. Control means one identified person has exclusive control of the record.
"Control is a fundamental notion of the Model Law"
UNCITRAL, Model Law on Electronic Transferable Records, 2017
The guiding principle is . An electronic record can do the legal job of a paper document when reliable methods identify it, keep it under control and keep it whole, per UNCITRAL.
02 · The law
The law, not the software, decides whether an eBL can pass on the claim to the goods
An eBL works only where the law says it does. MLETR was adopted on July 13, 2017. It aims to let electronic transferable records, such as bills of lading and promissory notes, be used legally at home and across borders, per UNCITRAL. A model law is a template. Each country must pass its own law to use it.
Thirteen jurisdictions have laws based on or influenced by MLETR, per the UNCITRAL status page. Some cover only part of the field. China's 2025 law covers bills of lading only. Mauritius covers bills of exchange only. Figure 1 lists all thirteen.
The UK received royal assent on July 20, 2023, per legislation.gov.uk. It came into force on September 20, 2023. Section 1(2) lists eight example trade documents, per section 1 of the Act. The bill of lading and the ship's delivery order are among them. Section 1(1) sets the test: a paper trade document is one whose possession is needed, by law or custom, to claim what it promises.
Singapore moved earlier. On February 1, 2021, Parliament passed a bill to amend its Electronic Transactions Act to adopt MLETR, per the Ministry of Digital Development and Information. The change lets eBLs be legally equivalent to paper bills.
China took its own route. The revised Maritime Code of the People's Republic of China (2025) deals with the in Articles 82 to 86. That is the Code's name for a transport document in electronic form. Negotiable records must use reliable methods. We read an English translation hosted by the Nanjing Maritime Court.
Figure 1 · Interactive
Where statute gives an electronic bill of lading legal footing
Filter by scope or search for a jurisdiction. Rows marked "bills of lading only" or "bills of exchange only" are partial enactments. Each law name links to its text.
Source: UNCITRAL, status of the Model Law on Electronic Transferable Records (2017), accessed September 30, 2026; instrument names from each jurisdiction's official text. Where UNCITRAL does not name the law and no official text was opened, the row says so.
03 · Adoption
Electronic bills were 1.2% of bills in 2021, and container eBL usage reached 12.8% in November 2025
Use started from a very low base. About 45 million bills of lading are issued each year, and only 1.2% of them were electronic in 2021, per the DCSA.
By November 2025, eBL usage in container shipping had reached 12.8%, per a DCSA and FIT Alliance webinar deck. The two figures come from different reports and may not measure the same thing. The 2021 figure covers all bills. The 2025 figure covers container shipping. Read the rise as a broad trend.
Surveys tell a similar story. The is a group of organizations working to make trade documents digital. In its 2024 survey, overall eBL adoption among respondents rose to 49.2%, from 33.0% in 2022, per the International Chamber of Commerce (ICC). Users of both paper and electronic bills rose to 41.7%, from 28.0%. Of the users still on paper only, 74.7% plan to switch, up from 58.0%. These are shares of survey respondents only.
Bulk shipping has its own pledge. Four dry bulk shippers pledged to move 25% of their iron ore shipments to eBLs by 2025. They reached 25.1% by mid-2024, the ICC reports.
Figure 2 · Interactive
eBL use among FIT Alliance survey respondents, 2022 and 2024
Tap a bar to see the share. Each pair compares the 2022 and 2024 surveys.
Source: FIT Alliance eBL survey 2024, as reported by the International Chamber of Commerce, December 12, 2024. The third pair is a share of paper-only users.
04 · The targets
Nine carriers committed to 100% eBL by 2030, and the pace has to rise to get there
On February 15, 2023, nine DCSA member carriers made a joint pledge, per the DCSA press release. They are MSC, Maersk, CMA CGM, Hapag-Lloyd, ONE, Evergreen, Yang Ming, HMM and ZIM. They committed to 100% use of an eBL based on DCSA standards by 2030. They also aim to issue 50% of their bills digitally within five years, per the DCSA commitment page.
Support goes beyond the carriers. Over 350 signatories have endorsed the FIT Alliance eBL declaration, per the November 2025 webinar deck. The DCSA estimates that the switch could save US$6.5 billion in direct costs for the parties involved. That is the DCSA's own estimate.
How fast must use grow? From an assumed start in December 2021 to November 2025, the share rose by about 2.96 percentage points a year. A percentage point is one step on the percent scale, such as from 12% to 13%. To reach 100% by December 2030, it must rise by 17.15 points a year. Try other starting points in Figure 3.
Figure 3 · Try it
How fast must eBL use grow to hit the carrier targets?
Move the slider to set today's usage and pick a target. The result shows percentage points a year needed.
Carrier target
Gap to the target
-
Time left from November 2025
-
Growth needed each year
-
Formula: growth needed each year = (target percent minus current percent) divided by years remaining. Years remaining = months from November 2025 to the target month, divided by 12. The default of 12.8% is container eBL usage in November 2025 (DCSA and FIT Alliance).
Our Research Desk used simple arithmetic: (target share minus current share) divided by years remaining. The target months are our reading of 'within 5 years' of February 2023 and 'by 2030'. The results are not Ossiano pricing or forecasts.
This calculator explains the concept only. Actual adoption depends on carrier, shipper, bank and legal readiness and will not follow a straight line.
05 · Systems and cover
Shipping's P&I clubs approve the eBL systems their members can use
Shipowners insure their liabilities to others through a , short for protection and indemnity club. The International Group of P&I Clubs decides which electronic bill of lading systems its members' cover will accept.
The Group approved twelve electronic systems from February 20, 2010, per its notice of February 4, 2025. From February 20, 2025, it changed the process. Paperless trading systems that meet two stated criteria are now deemed approved. They no longer need a separate review.
The Group's list of approved systems showed 21 providers when we checked it on September 30, 2026. The list changes over time. Our guide to trade finance platforms covers these systems, without endorsing any of them.
06 · Banks and delivery
Bank rules accept electronic records, and courts test what counts as delivery
Banks that pay against documents have rules for electronic records too. Most letters of credit follow , the ICC rules for documentary credits. A is a bank's promise to pay the seller against the right documents. The is a supplement and digital companion to UCP 600, per the ICC. The current text is Version 2.1, per the eUCP rules. The ICC says Version 2.1 aligns the eUCP with MLETR, per the ICC Digital Library.
Documentary collections have a matching supplement. In a , banks pass the shipping documents to the buyer against payment or a promise to pay. The , Version 1.1, supplements , the ICC rules for collections. See the eURC rules text and the ICC page on eURC.
Courts have also tested electronic release systems, which work differently from eBLs. In MSC v Glencore (2017), a carrier used an electronic release system that gave out pin codes in place of taking back the paper bills. Two of the three containers were taken by someone with no right to them. The Court of Appeal held that giving out the pin codes was not delivery under the bill of lading (paragraph 42). The paper bill still governed who could claim the goods.
07 · Ossiano view
The eBL has its legal footing; volume is the remaining step
OBSERVATION 01
Adoption is now measurable
DCSA put electronic issuance at 1.2% in 2021, and container usage reached 12.8% by November 2025. A published baseline and a dated target give the market a scoreboard it did not have before 2023.
OBSERVATION 02
Bank rules and statute point the same way
The ICC aligned eUCP Version 2.1 with MLETR, and the UK Act has been in force since September 20, 2023. An eBL presented under a credit can now rest on matching rules and law in the jurisdictions that have enacted.
OBSERVATION 03
Insurers have simplified approval
From February 20, 2025, the International Group of P&I Clubs deems qualifying systems approved. That shifts the question for shippers from which system is approved to which system meets the stated criteria.
Summary
An eBL can carry the claim to the goods where the law recognizes control, and use is rising toward a 2030 carrier target
An electronic bill of lading is a bill of lading issued and passed on electronically. To work like paper, it must stand for the goods. MLETR, adopted on July 13, 2017, makes control of the electronic record do the job of holding the paper. Thirteen jurisdictions have laws based on or influenced by it, including Singapore (2021), the UK (2023) and China (2025, bills of lading only).
Use is rising from a low base. The DCSA put electronic bills at 1.2% in 2021. Container eBL usage reached 12.8% in November 2025. Nine carriers have pledged 100% by 2030, which needs about 17.15 percentage points of growth a year from here. Bank rules (eUCP 2.1 and eURC 1.1) accept electronic records, and the International Group of P&I Clubs has simplified how it approves eBL systems.
Related guides: the bill of lading, the trade documents checklist, title and ownership in commodity trade, letters of credit, MLETR and digital trade law and trade finance platforms. Instrument cards: letter of credit (sight), documentary collection, documents against payment (D/P) and structured commodity finance. Every term is defined in the Trade Finance Glossary.
For questions on how these shifts affect existing or planned trade finance exposures, contact the Ossiano Research Desk.
Sources
- Digital Container Shipping Association, 100% eBL by 2030 (DCSA commitment page), February 2023. Supports: definition of an electronic bill of lading; carrier targets of 50% within five years and 100% by 2030; Figure 3.
- Uniform Law Commission and American Law Institute (UCC text hosted by Cornell LII), UCC 1-201, General definitions, undated; accessed September 29, 2026. Supports: definition of document of title (UCC 1-201(b)).
- Office of the Law Revision Counsel, US House of Representatives, 49 USC 80101, Definitions, undated; accessed September 29, 2026. Supports: definition of the holder of a bill of lading.
- Office of the Law Revision Counsel, US House of Representatives, 49 USC 80103, Negotiable and nonnegotiable bills, undated; accessed September 29, 2026. Supports: definitions of negotiable bill of lading (80103(a)) and straight bill of lading (80103(b)).
- UNCITRAL, UNCITRAL Model Law on Electronic Transferable Records (2017), 2017. Supports: adoption on July 13, 2017; purpose; control as the equivalent of possession; functional equivalence; quote.
- UNCITRAL, Status: UNCITRAL Model Law on Electronic Transferable Records, undated; accessed September 30, 2026. Supports: 13 jurisdictions with legislation based on or influenced by the Model Law; footnotes on influenced laws, China (bills of lading only) and Mauritius (bills of exchange only); Figure 1.
- legislation.gov.uk, Electronic Trade Documents Act 2023, enacted text, July 20, 2023. Supports: royal assent on July 20, 2023; Figure 1.
- legislation.gov.uk, Electronic Trade Documents Act 2023, 2023. Supports: in force on September 20, 2023 (section 8(2) and commencement note).
- UK legislation (legislation.gov.uk), Electronic Trade Documents Act 2023, section 1, 2023. Supports: the paper trade document test in section 1(1); eight example trade documents in section 1(2), including the bill of lading.
- Ministry of Digital Development and Information, Singapore, ETA amended to facilitate transactions, provide convenience and boost trade, February 1, 2021. Supports: amendment of the Electronic Transactions Act to adopt MLETR; eBLs legally equivalent to paper; Figure 1.
- Institute of Maritime Law, Shanghai Maritime University (English translation, hosted by Nanjing Maritime Court), The Maritime Code of the People's Republic of China (Revised 2025), 2025. Supports: Articles 82 to 86 on electronic transport records; Figure 1.
- Digital Container Shipping Association, DCSA's member carriers commit to a fully standardised electronic bill of lading by 2030, February 15, 2023. Supports: about 45 million bills a year; 1.2% electronic in 2021; the nine carriers' commitment; US$6.5 billion DCSA savings estimate; Figure 3.
- DCSA and FIT Alliance (deck hosted by BIMCO), DCSA FIT Alliance webinar deck, November 27, 2025. Supports: container eBL usage of 12.8% in November 2025; over 350 declaration signatories; Figure 3.
- International Chamber of Commerce, Survey shows steady rise of global adoption of electronic bills of lading, December 12, 2024. Supports: FIT Alliance 2024 survey results (overall adoption, dual-format users, paper-only users planning to switch); dry bulk iron ore pledge and progress; Figure 2.
- International Group of P&I Clubs, Electronic bills of lading: notification of new process, February 4, 2025. Supports: twelve systems approved from February 20, 2010; deemed approval from February 20, 2025.
- International Group of P&I Clubs, IG approved electronic bill of lading systems, undated; accessed September 30, 2026. Supports: 21 approved providers listed at the access date.
- International Chamber of Commerce, eUCP version 2.1: ICC Uniform Customs and Practice for Documentary Credits, June 29, 2023. Supports: eUCP as a supplement and digital companion to UCP 600.
- International Chamber of Commerce, eUCP (ICC Publication No. 823E), 2023. Supports: current version is Version 2.1 (article e1).
- ICC Digital Library, News item on eUCP Version 2.1, July 5, 2023. Supports: eUCP Version 2.1 aligns the eUCP with MLETR.
- ICC Digital Library, eURC Version 1.1 rules text, undated; accessed September 29, 2026. Supports: eURC Version 1.1 supplements URC 522 (article e2).
- International Chamber of Commerce, URC 522: Supplement for Electronic Presentation (eURC), June 29, 2023. Supports: eURC as the digital addition to URC 522.
- Court of Appeal of England and Wales, MSC Mediterranean Shipping Co SA v Glencore International AG [2017] EWCA Civ 365, May 24, 2017. Supports: pin codes under an electronic release system were not delivery under the bill; two of three containers misappropriated (para 42).
The real economy moves through Ossiano.
