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Questions regarding FMC registered forwarder for shipments to USA

Here are a few questions regarding FMC registered forwarder and documentation, raised by Kashan Faiz Sajjad.. rq

I am a freight forwarder in Pakistan and not FMC registered, I have cargo destined for the US, and I ask my FMC registered agent in the US to issue their HBL. So is this workable? Is there any problem that I am going to face regarding this?

If your partner in USA is an FMC registered forwarder and you are issuing their bill of lading which is also registered by the FMC, it is perfectly alright.. In fact, for shipments to USA, only bills of lading approved by the FMC are allowed..

I am booking at origin on behalf of my contarct with the shipping line’s origin office, but issuing my foreign agents (destination agent) HBL with the cargo. What are the points that I should look at prior finalizing the agreement with my agent to avoid huge billing from thier side. Should I fix certain tariffs in the agreement itself?

On the USA trade with most shipping lines, it is very rare that they will allow you – a non FMC registered NVOCC – to be the holder of the service contract..

As far as i know usually the shipping lines will only enter into a service contract with an FMC registered forwarder/NVOCC.. You will have to work in conjunction with your agent on this one..

If I consign my cargo to my FMC agent in Florida where as cargo is for some other state, then is this ok?

As per my understanding, the FMC registration is national and does not relate to that state alone, so this would be in order..

What if I send the cargo on MBL only, whether it is prepaid or collect, on the name of direct shipper/consignee? Where is the FMC registered BL in this case?

If you are going to us the shipping lines MBL only, there is no involvement of your agent or any other forwarder or NVOCC in the USA..

Any shipping line that operates to the USA must be registered by the FMC as a Vessel-Operating Common Carriers (VOCCs) or ocean common carrier and only then they can issue a bill of lading..

Open for comments.. As these questions are specifically related to USA, if anyone involved in Logistics/Forwarding/Shipping in the USA would like to improve on these answers please feel free to do so..

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Hariesh Manaadiar
Hariesh Manaadiar
I am Hariesh Manaadiar, the Founder of Shipping and Freight Resource.. I have been in the dynamic shipping and freight industry for over three decades and have worked in several sectors.. I share my experiences and knowledge of the industry through this blog for those looking for help in the industry.. Stay subscribed for more free useful content about shipping, freight, maritime, logistics, supply chain and trade..


  1. Good day;
    I have agent in China FMC registered, can I use their FMC hbl for a shipment with my other agent from Pakistan to USA (who is not FMC licensed)?

  2. Dear Hariesh,
    thx a lot for this helpful messages.
    Hear our case. We are freight forwarder.
    We booked a shipment trough Hapag Spot. Direct BL, actual shipper, actual consignee, dest. agent only as Notify. Container allready at the port and now in a sudden the carrier asked for a Letter of authority with following wording,

    We (name of the Principal), with registered offices at XXX, hereby appoint (name of the Booking Party), with registered offices at XXX, as its true and lawful agent, with full powers to act as its Booking Agent and accept terms and/or sign a service contract on its behalf.
    For and on behalf of (Name of the Principal)

    Do you understand, if the want to have this signed by the shipper or which party because the european shipper from the BL ?

  3. Hi Hariesh,
    I have 1 trouble and need your advice for our solving.
    Details: our company is NVOCC and also contract holder. However, due to accidental human mistake, we submitted SI and only got direct MBL without issuing HBL and it’s too late to issue HBL, file AMS for HBL now. we’re thinking to ask stream shipping line/carrier/VOCC to revise direct MBL as below to meet both FMC regulation and AMS filling.
    we/NVOCC still not issue HBL to avoid late AMS filling.
    we don’t know if cnee can do import process at US with our below option.
    Could you take your time to help us? which option can be workable or let us know your instruction for this case.

    shipper = real shipper O/B our company/NVOCC
    cnee = real cnee

    shipper = our company/NVOCC
    cnee = real cnee or our US agent forwarder
    then we issue FCR to real shipper

    Thank you so much

  4. Dear Sir,

    We are a freight broker from Europe. Our client has a shipment dispatched from Europe on the way to Busan, Korea. Shipper is asking for the COD (consignee did not made the payment) to USA but the agent at origin to whom the booking was placed is refusing it stating there is no possibility due to Korea – USA customs regulation and/or US FMC regulation.
    The term booking agent is using tells “not being able to file the costs to FMC under EU – Korea tariff”.
    Kindly asking for your explanation.

  5. Dear Hariesh Manaadiar,

    Greeting !!!!!

    This is Hemant Juyal from a logistics Company ,Delhi, India & I take care of Operation & Export Documentation in our company, We have just received our FMC Licence from U.S. Customs/Distribution-Publications, Inc. (DPI OUR CONSULTANT) & Now I have to check for the contract filing with the carrier.

    As of now ,I have just received our FMC certificate & Title page from our Consultant. (DPI)..

    So is this FMC certificate & Title page is enough to Executive any Shipment for U.S.A ??

    Request you to plz assist me on this & advise me if any information or Document is missing & I should ask DPI to share with us …

    Thanks in advance…

  6. Hi Hariesh,

    thank you for your prompt reply.

    Either for the consignee on the Master bill of lading? I mean we are just doing coordinating between shipper and real consignee, but we are not the owner of cargo or shipment. we have our US third party custom broker (they have FMC#), and we dont have our own FMC#. In this case, can shipper put our name as consignee on Master bill of lading, and custom broker as notify party and On the House bill of lading, put real shipper and real consignee who is the real importer registered?

  7. Dear Mr. Hariesh,

    We are a supply chain management company in U.S, we dont have a FMC number so far. and our Headquarter is a lisenced Freight Forwarder with NVOCC certification. We would like to ask if we have a shipment ship from Europe to Long beach, CA. On the Master bill of lading, our headquater’s name on shipper, and our name on consignee, it doesnt matter our U.S company has FMC or not, we still can release the cargo?

  8. I have a question for you all. If my agent is FMC reg. and I am not FMC reg. ( I am located in the USA) the ocean shipment is comign into US. My agent is using their own HB/L as they are registered, do I have to be FMC reg. or I dont need to be. Will that work using MB/L and HB/L…. Pls advise urgently.

  9. if shipment is under MBL and direct consign to US consignee, in this case who is responsible to file AMS and ISF?

    • When you say shipment is on MBL I presume there is also an HBL involved.. If so, then the fact that the MBL is consigned to the actual consignee in US is incorrect as the HBL would also be consigned to the same consignee..?? If HBL and MBL are issued then HBL should be consigned to actual consignee whereas MBL should be consigned to the agent of the NVOCC.. In that case the NVOCC is responsible to file the AMS and ISF..

  10. Hi Hariesh ,
    Here is another question for you. We work with our agent in Germany that is non registered. They procure rates directly from a steamship line. We are a US registered NVOCC/Forwarder. The agent would like us to issue our house bill of lading and we have an agency agreement. Can we do this?

  11. dear sirs
    how about if we issue FORWARDER’s CARGO RECIEPT (FCR) for export shipments from India to US, do we still need to be FMC registered.?
    We issue FCR to exporter and as back up we take MBL from carrier.
    kindly advise.
    thanks, gs

  12. Dear Sir,

    Does FMC contract no. is mandatory on released original HBL for USA shipments?

    Your valuable answer shall be appreciated…

    • Dear Sir,
      How about Air shipments exported to US? Can Non US based forwarder exporting shpiments to US just issue their own HAWB ask for other agents within US import cargoes? Or the Non based forwarder from origin have to do the same process as Ocean shipments (something like Registration like FMC for HB/L issue)? If yes, could you please advise us how to apply for this?
      Thank you!

  13. I have shipment and booking with cosolidatore to USA, and our company does not have FMC, should it be a problem or not if this is just a consolidation ? Can we use our HBL (no FMC)

  14. Dear Mr. Hariesh,

    What can happen if non-FMC-registered HBL is issued for a shipment destined to US (in this case, we place booking with a forwarder who has service contract with shipping lines & have them file AMS/ISF for this shpt)

    And how about shipments destined to Canada port? Must we use HBL registered with some organization?

    • In the event you move cargo on BL that is not FMC registered to the USA you are bound to be penalized heavily, the penalties are huge (Usd50,000.00 and more).

      You dont need to have a FMC registered BL for shipments consigned to Canada

  15. I wish to understand the process for a non US based forwarder to get his own BL registered with FMC,
    does the forwarder need separate registration with SCAC ?, how does the forwarder file ACD for the House BL he issues.

  16. Hi Hariesh,

    Just wanted to say that you did well with your explaination above and confirm that you are correct, it does not matter what state the cargo originates from, it can depart from any other state within the US.

    • Hi Anirban, these two are different but unique to USA and a requirement for shipments to USA..

      SCAC code is an abbreviation for The Standard Carrier Alpha Code and it is a unique two-to-four-letter code allocated to transportation companies and is used to identify them in computerised data exchanges..

      Any carrier operating transportation services to USA is required to have a SCAC code and this code should be advised to the US Customs via the AMS (Automated Manifest System).. This code is essential to the communication process with U.S. Customs as this code allows them to transmit load and no-load information to the relevant load ports, only based on which the load port will load the cargo on board the ship.. When NVOCC’s file their manifest, they are required to include this SCAC code as the “second notify” party on cargo declarations submitted to U.S. Customs for cargo booked with the contracted carrier..

      FMC is an abbreviation for The Federal Maritime Commission (FMC) which is an independent federal agency responsible for regulating the U.S. international ocean transportation system for the benefit of U.S. exporters, importers, and the U.S. consumers.. FMC registration is mandatory for any carrier operating services in USA..

      The relationship or common factor between these two is the shipment itself as without the SCAC Code or an FMC registration, cargo cannot be imported into the USA..


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