International supply chains rely on clear contracts, accurate documentation and well-defined responsibilities. A comprehensive update to China’s Maritime Code is reinforcing just how important those fundamentals have become.
The revised legislation, which came into force on 1 May, introduces a series of mandatory legal provisions covering international sea freight involving Chinese ports. While much of the attention has focused on carriers, the changes extend across the wider logistics industry, affecting NVOCCs, multimodal transport and the way international shipments are documented and managed.
For businesses trading with China, the reforms highlight the growing importance of supply chain visibility and compliance long before cargo reaches the vessel.
Documentation standards are becoming more demanding
One of the most notable operational changes concerns cargo carried on deck. The revised code requires bills of lading to identify when containers are stowed above deck rather than below. If that information is omitted, carriers could lose valuable legal protections should cargo damage occur.
Although the requirement appears relatively simple, complying with it may require significant operational changes. Documentation is often produced before final stowage plans are confirmed, meaning information must flow more effectively between vessel planners, terminals, documentation teams and NVOCCs.
Improving data accuracy throughout the shipping process is therefore becoming increasingly important.
The updated legislation also affects NVOCCs issuing their own multimodal bills of lading. Depending on the contractual arrangements in place, they may assume responsibilities normally associated with the shipper or with the multimodal transport operator, potentially increasing their exposure when cargo is delayed, damaged or remains unclaimed.
The changes have also prompted wider discussion about future trading practices. Some industry specialists believe the revised liability framework could encourage more exporters to favour Cost, Insurance and Freight (CIF) terms over Free on Board (FOB), allowing Chinese sellers to retain greater control over freight procurement, insurance and, where disputes arise, legal proceedings within China.
However, any move from FOB to CIF would be driven by commercial negotiation rather than the legislation itself. Incoterms remain internationally recognised standards, and the revised Maritime Code does not prevent UK importers from continuing to purchase on FOB terms where they wish to control the main carriage, select their own carrier and negotiate freight rates directly.
In practice, FOB remains a perfectly valid option for China–UK trade, provided the sales contract and the conduct of both parties clearly reflect that allocation of responsibilities.
The revised Maritime Code also changes the circumstances in which carriers can rely on the traditional fire defence.
The exemption is now limited to fires occurring on board the vessel, potentially increasing liability where incidents occur elsewhere in the transport chain, including terminals or inland facilities.
The amendment comes as international shipping continues to manage the safe movement of increasing volumes of electric vehicles, lithium batteries and other cargoes that require enhanced risk management.
Some changes benefit cargo owners
Not every amendment increases commercial exposure. The legislation extends the period before unclaimed cargo can be sold through the courts to 60 days after vessel arrival. This gives cargo owners additional time to resolve disputes, complete documentation or address commercial issues before goods are disposed of.
For exporters and importers, the revised framework provides greater flexibility while encouraging stronger compliance across the supply chain.
Preparing for a changing legal environment
China’s updated Maritime Code demonstrates how quickly the legal framework surrounding international trade can evolve.
Businesses moving freight through Chinese ports should review contracts, shipping documentation and operational processes to ensure they remain aligned with the new requirements. Strong collaboration between shippers, NVOCCs and carriers will become increasingly important as the industry adapts.
Ultimately, organisations with clear contractual arrangements, robust documentation and greater supply chain visibility will be best placed to manage risk while maintaining efficient international freight operations.
China’s revised Maritime Code reinforces the importance of working with logistics partners that understand both the legal and operational environment. As part of the Hecny Group, one of the region’s largest logistics operators, Global Forwarding provides comprehensive coverage throughout mainland China, combining local expertise with a global freight network. Our teams help customers manage changing regulatory requirements, optimise shipping strategies and maintain compliant, resilient supply chains across international markets.
