Importing Bitumen into India: Documents, Conformity and Port Clearance

HS 2713.20 is the heading, not the code

Petroleum bitumen sits internationally in HS heading 2713.20. Those six digits are the part of the classification that is common to every country. India’s working tariff runs to eight digits under the ITC (HS) Classification of Export and Import Items maintained by the Directorate General of Foreign Trade, read together with the First Schedule to the Customs Tariff Act, 1975. The eight-digit line is what carries the import policy condition, the applicable rate columns and any notification-based condition attached to that product.

The practical rule for a seller is short. Keep every document you issue consistent at six digits, and put no eight-digit Indian code on a seller-issued document unless the buyer’s licensed customs broker has confirmed it in writing against the current schedule. A code that a supplier copied from a previous shipment, or from a search result, becomes the buyer’s problem at assessment and the seller’s problem at the bank.

The description that has to survive four readings

One description of the goods has to work in the sales contract, in the letter of credit, on the commercial invoice and on the Bill of Entry. Write it once and never improve it: the grade, the Indian Standard and its year, the packing type with net weight per unit, and the inspection arrangement. Something of the form Bitumen VG-30 to IS 73:2013, packed in new steel drums of 180 kg net can be reused verbatim in six documents. A description that is elegant in six different versions is the single most reliable way to generate a discrepancy.

There is a vocabulary trap specific to this market. In Indian usage bitumen is the binder and asphalt is generally the mix, which is the reverse of the common North American usage where asphalt means the binder. A document that says asphalt where the project specification says bitumen invites a reader to ask whether the right product arrived, and that reader may be an assessing officer rather than an engineer.

Origin: a certificate on its own no longer settles the question

Where a preferential rate is claimed under one of India’s trade agreements, the Customs (Administration of Rules of Origin under Trade Agreements) Rules, 2020 — universally called CAROTAR — changed what a certificate of origin is worth. The importer must make a declaration on the Bill of Entry, must possess origin-related information sufficient to show that the goods meet the origin criteria, and must be able to produce it on request. The proper officer can seek that information and can hold or deny the preferential claim pending verification, securing the duty difference meanwhile.

The consequence for a seller is that the Indian buyer will ask for production and origin information that a chamber-of-commerce certificate does not contain, and will ask for it because a rule obliges them to hold it. Settle at contract stage what will be supplied and by whom. A refusal to answer after the credit is opened reads as something other than administrative reluctance.

Sampling, and what customs is actually testing for

Customs may draw samples at import and refer them for testing, including to the Central Revenue Control Laboratory, to confirm that the goods are what the declaration says they are. For a bitumen cargo the question being asked is a classification question rather than a quality question: is this petroleum bitumen of the declared heading, or is it a residue, a blend or a cutback that belongs somewhere else in the tariff. A batch certificate of analysis reporting the properties of the standard the contract names is the seller’s contribution to answering it quickly.

Where the file is read, and by whom

Supporting documents are uploaded electronically through e-Sanchit, and each upload returns a reference number that is quoted on the Bill of Entry rather than the paper being carried anywhere. Since the move to faceless assessment, the officer assessing a Bill of Entry is allocated nationally and is generally not at the port of import. That officer cannot look at the cargo, cannot be visited at a counter and has only what was scanned and uploaded. A COA that is unsigned, a certificate scanned at an unreadable resolution or a packing list whose totals do not add up is therefore not a small untidiness; it is the whole of what the decision-maker can see.

The neighbours of 2713.20 matter more than the heading itself

Heading 2713 covers petroleum coke, petroleum bitumen and other residues of petroleum oils or of oils obtained from bituminous minerals. Within it, 2713.20 is petroleum bitumen specifically. What a seller has to know is what sits either side of it, because most classification arguments in this trade are not about whether the material is bitumen but about whether it is this kind of bituminous product.

• 2714 covers bitumen and asphalt that are natural, together with bituminous or oil shale, tar sands, asphaltites and asphaltic rocks. Natural asphalt is not refinery bitumen and does not belong in 2713.20 because it looks and behaves similarly.
• 2715 covers bituminous mixtures based on natural asphalt, on natural bitumen, on petroleum bitumen, on mineral tar or on mineral tar pitch — the heading under which bituminous mastics and cut-back products are generally considered. A cutback is petroleum bitumen with a solvent in it and a bitumen emulsion is bitumen dispersed in water with an emulsifier; neither is straight petroleum bitumen, and a supplier who prints 2713.20 on an invoice for either has misdescribed the goods before the file is even opened.

The decision rule follows from that. Settle which of the three headings the product sits in before the first document is issued, and settle it on what the material is rather than on what the trade calls it. Classification is governed by the General Rules for the Interpretation of the Import Tariff printed at the front of the First Schedule: the terms of the headings and the relevant section and chapter notes decide the question, and the same logic is applied one level down at the subheading. A trade name has no standing in that exercise, and neither does the code on the last invoice.

What is stored at the eight-digit address

The eight-digit line is not a label. It is the address at which several separate things are filed, and each of them is revised on its own schedule:

• The import policy condition in the ITC (HS) schedule — whether the item is free, restricted, prohibited or channelled through a state trading enterprise, together with any licensing or authorisation note attached to it.
• The basic customs duty rate column in the First Schedule to the Customs Tariff Act, 1975.
• The levies that ride on the tariff line: the surcharge computed on the duty, and the integrated tax charged on imports under section 3(7) of the Customs Tariff Act, whose rate is itself read off a tax rate notification that refers back to tariff headings.
• Any exemption notification that reduces the rate conditionally, and any condition the notification attaches to the reduction.
• Any preferential rate available under a trade agreement for a qualifying origin, which is where CAROTAR bites.
• Any trade remedy measure — anti-dumping, countervailing or safeguard — imposed on a specified description of goods from a specified country. These are attached to a tariff line and an origin together, which is why origin and classification cannot be settled separately.

Every one of those changes between budgets and notifications. That is why no rate, no tax figure and no eight-digit code appears on this page: a number of that kind is precise enough for a buyer to plan on and wrong often enough to cost them money. It is also why an Indian buyer treats classification as a finance question rather than a logistics one. A code that moves the goods from one line to another moves the duty, the tax and possibly a trade remedy with it.

The two dates that decide what is actually payable

Which exchange rate applies. The invoice currency is converted for assessment at the rate notified by the Central Board of Indirect Taxes and Customs in force on the date the Bill of Entry is presented. Not the contract date, not the invoice date, and not the rate the buyer’s bank gives it on the day it remits. A buyer who budgets landed cost from the contract-day rate is budgeting from a number that has no role in the assessment.

Which rate of duty applies. For goods entered for home consumption, section 15 of the Customs Act, 1962 fixes the rate and any tariff valuation as those in force on the date the Bill of Entry is presented, or on the date of entry inwards of the vessel where the Bill of Entry was presented before the vessel arrived — in practice the later of the two. Filing early therefore does not freeze a rate. For goods that are warehoused and cleared later, the operative date is that of the ex-bond Bill of Entry, which is the point set out under the inland leg below and the reason bonded storage carries a rate risk in both directions.

Valuation: the Incoterms rule is part of the arithmetic

Value is transaction value under section 14 of the Customs Act, 1962, applied through the Customs Valuation (Determination of Value of Imported Goods) Rules, 2007. The price actually paid or payable is adjusted by the additions those rules specify, which for an ordinary bitumen import means the cost of transport to the place of importation, the loading, unloading and handling charges associated with delivery there, and insurance. Where freight or insurance is not ascertainable from the documents — the usual position on an ex-works or FOB purchase where the buyer arranges carriage — the rules provide for notional additions computed on a prescribed basis. That basis has been amended more than once and is a question for the broker rather than for a supplier page.

Two consequences follow, and both are commercial rather than technical. First, the Incoterms rule is not a drafting convenience; it changes the assessable value and therefore every duty and tax computed on it. A price agreed on CFR terms and invoiced as though it were FOB understates the value, which is a declaration problem rather than a pricing preference. State the rule, the named place and the edition on the invoice, and use the same rule in the contract, the credit and the declaration. The Incoterms page sets out which rules are coherent for a sea parcel and which are not. Second, discounts, commissions, royalties and any part of the resale proceeds accruing to the seller are declarable, as is any relationship between buyer and seller. A rebate agreed on the side and settled by credit note after clearance is a problem for the bank and for the declaration at the same time.

Who is allowed to make the declaration, and why the broker asks awkward questions

The Bill of Entry is filed by the importer itself through the customs electronic gateway, or by a customs broker licensed under the Customs Brokers Licensing Regulations, 2018. A licensed broker is not a forwarder with a rubber stamp. The regulations place obligations on the licence holder, including verifying the identity and functioning of the client and the correctness of the information imparted in relation to the clearance. The practical consequence for a seller is worth internalising: a broker who presses on description, origin, packing detail and value is discharging a regulatory obligation, not being difficult, and an offer whose paperwork cannot survive those questions will not survive assessment either. The corollary is that the broker is the right person to give the eight-digit line in writing, and the only person with any standing to do so.

The standard the Indian market procures against

Paving bitumen in India is specified against IS 73:2013, Paving Bitumen — Specification, published by the Bureau of Indian Standards. It names four viscosity grades: VG-10, VG-20, VG-30 and VG-40. Viscosity grading replaced the older penetration designations of IS 73:1992. The grade number is the nominal absolute viscosity at 60 °C in hundreds of poise, and the requirement is expressed as a band around that nominal figure rather than as a floor — roughly the nominal value less 20 per cent at the bottom and plus 20 per cent at the top. Reproduced here for orientation as this site tabulates IS 73:2013, and not as a substitute for the standard: VG-10 is 800–1200 poise, VG-20 is 1600–2400, VG-30 is 2400–3600 and VG-40 is 3200–4800. The limits that actually bind a batch are the ones printed in the edition of IS 73 the contract names. Two consequences follow and both cost people cargoes. First, a certificate reporting 2500 poise is a compliant VG-30, so reading the grade number itself as the floor is one of the more common ways a buyer and a seller end up arguing about a cargo that conforms. Second, because the VG-30 and VG-40 bands overlap between 3200 and 3600 poise, a viscosity result inside that window does not on its own identify the grade — the minimum penetration at 25 °C, the minimum softening point and the minimum kinematic viscosity at 135 °C are what settle it. Note what those three lines can and cannot do: they are minima rather than bands, so they exclude a grade more reliably than they confirm one, and a batch can clear both sets at once — in which case the grade is the one the contract and the certificate name, not one the arithmetic picks. A certificate carrying only the viscosity line leaves the question open altogether. The bands and the penetration floors are tabulated together on the grade equivalence page; standards are periodically revised and amended, so confirm the current edition of IS 73 with the Bureau of Indian Standards before writing limits into a contract.

VG-30 is the mainstream grade for dense bituminous hot-mix paving across most of the country, and VG-40 is specified on heavily trafficked national corridors, at junctions, on climbing lanes and at toll plazas where standing and slow-moving axle loads make rutting the dominant risk. The reason is structural rather than commercial: grading on absolute viscosity at 60 °C selects the binder for stiffness at the pavement service temperature an Indian summer actually produces, under axle loading that the same grading at 25 °C would say nothing useful about. That argument, the grade tables and the equivalence question are set out in full on the India market page and on the viscosity grade and VG-30 pages, and are not repeated here.

What matters procedurally is that project documents follow the standard. The Ministry of Road Transport and Highways Specifications for Road and Bridge Works, Section 500, and the relevant Indian Roads Congress codes name the IS grade. So the grade written into the sales contract has to be the grade written into the project specification, in the same words, or the engineer at site is comparing two documents that do not describe the same product. Where the cargo is not paving bitumen, the governing Indian Standard changes with it — bitumen emulsion is specified under IS 8887, polymer and rubber modified binders under IS 15462, industrial and blown grades under IS 702 — and the test methods sit in the IS 1201 to IS 1220 series.

Certification is a separate gate, and it belongs to the producer

The Bureau of Indian Standards operates under the BIS Act, 2016 and the BIS (Conformity Assessment) Regulations, 2018. Product certification is voluntary until the product is brought under a Quality Control Order issued by the administrative ministry. Once a Quality Control Order is in force for a given Indian Standard, conformity to that standard and use of the BIS Standard Mark — the ISI mark, carrying the licence number — become mandatory, and goods without it cannot lawfully be imported or sold.

Which ministry administers a given order, and which Indian Standards that order brings into scope, are both read off the order itself; for petroleum products generally the administering ministry has been the Ministry of Petroleum and Natural Gas. This page states no position on whether any particular bitumen product is inside the scope of an order in force today, and nothing here should be quoted as one. Two things about that question cannot be settled from any web page, this one included. First, coverage is defined by a schedule of specific Indian Standards, not by the word bitumen, so whether the exact product you are shipping is inside or outside the schedule has to be read off the current notification. Second, effective dates for Quality Control Orders are routinely amended, deferred and extended, and a date that was correct last quarter may not be correct now. Confirm the current notification, its schedule and its effective date with the buyer’s licensed customs broker in India and against the published BIS and ministry notifications before the vessel is fixed. The mechanism is stable and worth learning; the position on any given day is not, and only the broker at destination can state it.

The foreign manufacturer route, and why a trader cannot solve it

A producer outside India obtains a BIS licence under the scheme for foreign manufacturers set out in the BIS (Conformity Assessment) Regulations, 2018 — the route the trade calls the Foreign Manufacturers Certification Scheme. In outline it involves application to the BIS head office, an audit of the manufacturing works, testing of samples in a BIS-recognised laboratory, appointment of an Authorised Indian Representative resident in India, and grant of a licence number under which the Standard Mark is applied.

The point that decides commercial feasibility is this: the licence is granted to a manufacturing location, not to a trader, an exporter or a consignment. An intermediary cannot obtain the mark on a refinery’s behalf, and no amount of documentation substitutes for it. Where a Quality Control Order applies to the product and the producing refinery does not hold a licence for that Indian Standard, there is no route in for that cargo, and that is a question to answer before quoting rather than after the credit is opened. That is what makes the scheme a sourcing constraint rather than a paperwork one: it can disqualify a supply source outright, and no other document in the file compensates for it. Whether any other destination you also serve operates a comparable requirement is a separate question with a separate answer, to be checked destination by destination with a licensed broker there; nothing on this page answers it for anywhere but India, and it should not be read as saying that neighbouring markets are open because India is closed or the reverse.

What buyers ask for alongside, or in the absence of, a mark

Indian buyers, and contractors working to highway authority or state public works department specifications in particular, commonly require confirmatory testing at a laboratory accredited by the National Accreditation Board for Testing and Calibration Laboratories. A load-port certificate does not displace that testing and should not be offered as if it did. What it does is give both sides a traceable reference if the two sets of results ever have to be argued, which is why independent inspection and sealed retained samples at the load port are worth their cost on a first shipment. The certificate of analysis guide covers what a defensible certificate looks like.

One thing bitumen is not

The Petroleum Act, 1934 and the rules made under it apply to petroleum defined by a flash point below 93 °C, and the licensing classes sit under that threshold. Paving bitumen to IS 73:2013 carries a minimum Cleveland open cup flash point of 220 °C and therefore falls outside that definition, which is why a petroleum storage licence is not normally the gate for a bitumen receiving installation. That is not a statement that hot bitumen storage is unregulated: state factory, fire safety and pollution control requirements apply to the receiving installation and are the buyer’s responsibility, and they should be confirmed with the relevant authority rather than inferred from this paragraph. Separately, transport condition decides the dangerous goods position — solid bitumen in drums or bags at ambient temperature is generally not handled as a dangerous good, while bitumen carried at or above 100 °C is UN 3257, Class 9. State the carrying condition consistently on the safety data sheet, the booking and the transport document.

What a Quality Control Order does not do

Three misreadings recur, and each of them costs somebody a shipment. A Quality Control Order does not certify a consignment — it makes conformity to a named Indian Standard compulsory and licenses a manufacturing works to apply the Standard Mark, so there is no such thing as a certificate covering one cargo under it. It does not replace project acceptance testing: a marked product still gets sampled and tested by the contractor and by the employer’s engineer against the contract specification, and a failure at that gate is a commercial failure regardless of the mark. And it does not travel with a trader: an intermediary in the supply chain cannot hold the licence, cannot apply the mark and cannot cure its absence with documentation. Where the product is in scope and the works is not licensed, the correct answer to the enquiry is that the cargo cannot be supplied, given at the quotation stage.

Marking on the drum, which is a third body of law again

Alongside the standards regime sits the Legal Metrology Act, 2009 and the Legal Metrology (Packaged Commodities) Rules, 2011, which govern the declarations that must appear on a pre-packaged commodity. The regime is built around packages intended for retail sale, and packages supplied to an industrial or an institutional consumer are treated differently under those rules; an importer of pre-packaged commodities also registers with the Director of Legal Metrology. Whether drums consigned to a road contractor or to an asphalt plant fall inside or outside the retail regime turns on how the goods are supplied onward rather than on what they are, so it is a question for the buyer’s licensed customs broker and its own legal adviser, and this page states no position on it.

Independently of that question, there is a marking set a bitumen drum should carry because the rest of the file depends on it: product and grade exactly as the contract names them, the Indian Standard and its year, net weight per drum, batch or lot number, producing works identification, date of manufacture, and hazard information consistent with the safety data sheet. The reason is procedural rather than legal. Under faceless assessment the examining officer at the port is comparing a photograph or a report of the marks against the packing list and the invoice, and drum markings that do not match the packing list are the fastest way to convert a routine examination into a query. The new steel drums page covers what the drum itself should be.

Read the set as three families, not as a list

A bitumen import file contains documents from three different sources and they fail for three different reasons.

• Documents the seller writes — invoice, packing list, certificate of analysis, safety data sheet. These fail because somebody improved the wording, or because a figure was calculated rather than measured.
• Documents a third party writes on the seller’s instruction — bill of lading, certificate of origin, insurance certificate, inspection certificate. These are the ones that drift, because the carrier’s documentation desk, the chamber of commerce clerk and the underwriter’s assistant do not know that the wording is load-bearing and will write whatever seems natural to them.
• Documents the buyer holds or creates — the Bill of Entry, the Importer-Exporter Code, the GSTIN, the AD Code registration, the delivery order. These fail before the cargo moves, and the seller never sees the failure until the declaration will not file.

The middle family is where the money goes. A seller who circulates a one-page instruction — the exact goods description, the exact party names and addresses, the quantity basis, the six-digit classification, the Incoterms rule with its named place — to the carrier, the chamber and the insurer before anything is issued removes most of what follows.

Commercial invoice

Issued by the seller, on its own letterhead. Under a credit it must appear to have been issued by the beneficiary and made out in the name of the applicant.

What it is for. It is the price document, and it does two jobs that are read by two people who never speak to each other. For the bank it is the one stipulated document whose goods description must correspond with the description in the credit rather than merely not conflict with it. For customs it is the starting point of the assessable value, and the source of the freight and insurance additions that the valuation rules require.

What makes it acceptable. In the currency of the credit. Describing the goods in the credit’s own words. Quantity stated on the agreed basis, with the unit price and the total. The Incoterms 2020 rule named together with the place it applies to, so that what the price includes is readable rather than inferable. Country of origin, marks and numbers, invoice number and date, and the container numbers where the cargo is containerised. Under UCP 600 the invoice need not be signed, but Indian buyers routinely ask for a signed original because the broker uploads a scan of it and a nationally allocated assessing officer sees only the scan — and if the credit stipulates a signed invoice, the signature stops being a courtesy and becomes a condition of payment.

The defect that recurs. The description is rewritten. Not falsified — rewritten, usually by someone tidying it. The asymmetry is what catches people: every other stipulated document may describe the goods in general terms provided they do not conflict with the credit, while the invoice may not, so an accurate improvement is still a discrepancy. The second most common defect is an Incoterms rule quoted without the named place, which leaves nobody able to say whether the freight and insurance additions belong in the declared value or are already inside the price.

Packing list

Issued by the seller. It is not a document UCP 600 defines, which means its content is whatever the credit and the contract say it is — and that in turn means a badly drafted credit produces a packing list that satisfies nobody.

What it is for. It converts a tonnage into countable things. It is the source of the package count that goes onto the arrival manifest and the Bill of Entry, of the net and gross weights the declaration is built on, and of the container and seal numbers. At a container freight station it is the document the tally at unstuffing is compared against.

What makes it acceptable. A line per container, showing container number, seal number, package count, net weight and gross weight, with totals that actually add up. Drum type and net weight per drum stated explicitly. Drum tare excluded from the net weight, and container tare excluded from the gross. Marks and numbers as they appear on the drums. The site loading figures make the whole thing checkable in ten seconds: 80 drums of 150 kg is 12 MT in a 20 ft container; 80 drums of 180 kg is 14.4 MT; 80 drums of 185 kg is 14.8 MT; 20 jumbo or poly bags of 1 MT is 20 MT. A packing list whose per-container weights do not reconcile with those figures is describing a container that was loaded to a different plan from the one the contract describes.

The defect that recurs. Weights arrived at by multiplication rather than by weighing. A nominal net weight multiplied by a drum count is an estimate, and on drummed cargo routed to a container freight station the tally and the weights are taken again at unstuffing, so an estimate reappears as a shortage on a survey report with a Bill of Entry already filed against it. The fix is contractual rather than clerical: agree in writing which figure governs — load-port weighbridge, drum count multiplied by nominal net, or shore tank measurement at discharge — because those three numbers are never identical and the argument only starts once they diverge.

Bill of lading

Issued by the carrier, the master, or a named agent signing for one of them.

What it is for. Three jobs at once: a receipt for the goods as shipped, evidence of the contract of carriage, and — where the bill is negotiable — the document against which the carrier will give delivery. The third job is the one that matters on this routing, because it is what a short voyage puts under strain.

What makes it acceptable. Under UCP 600 article 20 a transport document covering a port-to-port shipment must indicate the name of the carrier and be signed by the carrier, the master, or a named agent that states the capacity in which it signs and for whom; must indicate that the goods have been shipped on board a named vessel at the port of loading stated in the credit, either by pre-printed wording or by a dated on-board notation; must show shipment from the port of loading to the port of discharge stated in the credit; must be the sole original or the full set as the document itself indicates; must contain the terms of carriage or refer to another source containing them; and must contain no indication that it is subject to a charter party. Charter party bills are governed separately by article 22 and are only acceptable where the credit expressly permits them, which is the ordinary position for a bulk parcel.

The defect that recurs. An agent signs without stating that it signs as agent for a named carrier. It is a refusal that has nothing whatever to do with the cargo, and it is generated by a documentation clerk who signs the same way on every bill they issue. Close behind it: a received-for-shipment form with no on-board notation, or an on-board notation without a date.

The Indian layer on top. The consignee and notify particulars have to reconcile with the entity that will declare the goods and hold the registrations, because the carrier’s manifest is built from them and the Bill of Entry is matched against that manifest line by line. Where the two disagree, the correction belongs to the carrier or its agent rather than to the buyer’s broker, which puts the fix outside the buyer’s control while the free period runs down. Three originals is the customary set; where the credit calls for a full set, all three are presented, and any arrangement to release one original at the load port or to courier one directly to the buyer has to be written into the credit before it is issued.

Certificate of origin

Issued by a chamber of commerce or another body authorised for the purpose in the country of export, for a non-preferential certificate; where a preferential rate is claimed, by the issuing authority designated under the relevant trade agreement, on the form that agreement prescribes. The two are different documents doing different jobs and they should never be ordered interchangeably.

What it is for. It states where the goods originate. Origin and tariff line together decide which rate column applies, and origin is also what a trade remedy measure attaches to, since anti-dumping and countervailing duties are imposed on a described product from a named country rather than on a product at large.

What makes it acceptable. Issued by a body the credit or the agreement recognises. Consignor and consignee named consistently with the invoice and the transport document. Goods described consistently. Any HS number quoted in the certificate’s own column agreeing at six digits with the line that will be declared. Signed and stamped by the issuing body. Where the certificate is issued after the goods have shipped, carrying whatever retrospective-issue endorsement the applicable rules require, because a certificate silently dated after the bill of lading invites the question of how it was verified.

The defect that recurs. The HS number in the certificate’s own column disagrees with the declared line at six digits. Nobody chose that number: a clerk at the issuing chamber copied it from an old invoice or a booking note. Once it is on the certificate the file contains two different classifications and the assessing officer is entitled to ask which one the importer stands behind.

The Indian layer on top. For a preferential claim, CAROTAR obliges the importer to make a declaration on the Bill of Entry and to hold origin-related information sufficient to show that the goods meet the origin criteria, producible on request, with the officer able to hold or deny the claim pending verification while securing the duty difference. That is a much heavier obligation than the certificate itself, and it falls on the buyer while the information sits with the seller. Decide at contract stage whether a preferential claim is being made at all, and if it is, settle in writing what production and origin information the seller will supply and how quickly. Most bitumen imports run on an ordinary non-preferential certificate, which is a far lighter document, and the moment to discover which case you are in is before the credit is opened.

Certificate of analysis

Issued by the producing works’ laboratory, or by an independent third party that drew the sample under supervision. The second is worth its cost on a first shipment for a reason that has nothing to do with distrust: it is the only version of the document that can be argued from when a laboratory at destination produces a different number.

What it is for. It is the only document in the set that says what the material actually is. Every other document says where it came from, who owns it, what it cost and how it travelled.

What makes it acceptable. A batch or lot identification traceable to the drums or the parcel that loaded, not to a production month. Each line carrying the property, the test method designation and the measured result, in that order. The standard and grade named exactly as the contract names them. The date of test and the sampling basis. A signature with a name and a position behind it. For India the lines that evidence the grade are the viscosity lines and the rolling thin film oven residue lines, and the certificate table below sets out each one with its Indian test method.

The defect that recurs. Specification limits reproduced in the results column. A certificate on which every value sits exactly on the limit, shipment after shipment, is a specification sheet wearing a certificate’s clothes, and it is worth less than nothing because it invites the very testing it was supposed to make unnecessary. The fix is to write the test schedule into the contract — the properties, the methods, who draws the sample and who witnesses it — rather than accepting whatever the works habitually issues. The certificate of analysis guide and the sampling procedure page cover both halves of that.

Insurance certificate or policy

Issued by an insurance company, an underwriter, or their agents or proxies. A broker’s cover note is not one of those, and offering one under a credit that calls for a certificate is a refusal waiting to happen.

What it is for. On CIF or CIP terms the seller is obliged to procure cover, and the document evidences it. On those terms the insurance element also sits inside the value the Indian declaration is built on, which is why an insurance document corrected after the Bill of Entry is filed tends to pull the declaration into amendment with it.

What makes it acceptable. Under UCP 600 article 28: issued and signed by an insurance company, an underwriter, or their agents or proxies, and where an agent or proxy signs, indicating whether it signs for the company or for the underwriter. Dated no later than the date of shipment, unless it appears from the document itself that cover is effective from a date not later than shipment. In the same currency as the credit. For an amount of at least 110 per cent of the CIF or CIP value of the goods, or, where that value cannot be determined from the documents, computed on the basis the article prescribes. Covering at least between the place of taking in charge or shipment and the place of discharge or final destination stated in the credit. And covering the risks the credit stipulates, named by the clause set rather than by adjective.

The defect that recurs. Dated after the shipped-on-board date. It is the most mechanical refusal in this trade and it happens for a mundane reason: cover is arranged when the invoice is raised, and the invoice is raised after loading. Arrange the cover before the cargo loads and check the document on the day it is issued rather than on the day it is presented. The second most common: the credit stipulates a named clause set and the certificate offers something narrower, which is not visible unless somebody reads the clause references rather than the word cover.

One thing the document does not do. A marine policy written to the port of discharge stops at the port of discharge. On an Indian import that finishes several hundred or a thousand kilometres inland, the uninsured portion is most of the risk and all of the last leg, and the point is taken up under the inland leg below.

The documents nobody drafts and everybody needs

Three more travel with a bitumen cargo and each is capable of stopping it. The safety data sheet should be in the sixteen-section format the globally harmonised system uses and must state the carrying condition, because ambient solid bitumen and bitumen carried at or above 100 °C are different transport propositions and the terminal gate is a poor place to discover which one arrived. The weight or draught survey report exists to reconcile what left with what arrived, and its value depends entirely on both parties having agreed in advance which figure governs. The delivery order is not a shipping document at all but the release instrument the line or its agent issues against an original bill of lading or a telex release, and on this routing it is the document most likely to be the last thing missing.

Bitumen is a low value-density cargo and India is a large country

A tonne of paving binder is worth a small fraction of a tonne of most cargo that occupies the same container and weighs the same. Freight is therefore a material share of landed cost rather than a rounding error, and in India the variable a supplier cannot see from the enquiry is the distance from the gateway to the site. A quotation CFR Nhava Sheva prices the identical thing for a Pune plant and for a Nagpur plant, and those are not the same delivered cost.

The following road distances are commonly cited approximations given for orientation only. They vary with the alignment actually used, they are not a basis for a freight calculation, and the routing has to come from a forwarder in writing.

• Jawaharlal Nehru Port (Nhava Sheva) to Pune roughly 150 km, to Nashik roughly 190 km, to Nagpur roughly 850 km, to the Delhi National Capital Region roughly 1,400 km.
• Mundra and Deendayal (Kandla) to Ahmedabad roughly 350 km, to Jaipur roughly 900 km, to the Delhi National Capital Region roughly 1,100 to 1,200 km.
• Chennai and Kamarajar (Ennore) to Bengaluru roughly 350 km, to Hyderabad roughly 630 km, to Coimbatore roughly 500 km.
• V.O. Chidambaranar (Tuticorin) to Madurai roughly 140 km.
• Cochin to Coimbatore roughly 190 km through the Palakkad gap.
• New Mangalore to Bengaluru roughly 350 km, up the ghats.
• Visakhapatnam to Hyderabad roughly 620 km, to Raipur roughly 550 km.
• Haldia and Kolkata to Patna roughly 600 km, to Siliguri roughly 600 km.

The decision rule that falls out of that list is blunt. Beyond a few hundred kilometres the gateway is chosen by the inland distance, not by sailing frequency. A Delhi project fed through Nhava Sheva is paying for roughly a thousand four hundred kilometres of inland movement; the same project fed through a Gujarat gateway is paying for a materially shorter leg on the corridor that was built to serve it. The converse is equally true and less often noticed: a Pune plant fed through Mundra pays for a long haul to save nothing at all. Name the delivery town in the enquiry, not the country and not the port, because the port is an output of that answer rather than an input to it.

The container count is the inland cost, and the packing decides it

This is the only point in the transaction where a decision taken at a load port changes a road bill in central India, and it is arithmetic rather than judgement. Take a thousand tonnes to a single inland destination and apply the site loading figures:

• 150 kg steel drums at 12 MT per 20 ft container: 84 containers.
• 180 kg steel drums at 14.4 MT: 70 containers.
• 185 kg steel drums at 14.8 MT: 68 containers.
• 1 MT jumbo or poly bags at 20 MT: 50 containers.

Thirty-four fewer boxes for the same tonnage is the entire inland argument for jumbo bags, and on a leg of a thousand kilometres it is not a marginal saving. The counter-arguments are real and sit in the packing table above: the receiving plant needs a melting unit that takes the bag whole, and the stowage has to keep meltable packaging out of sustained heat in transit. But a buyer comparing packing options on the price of a drum alone is comparing the small number and ignoring the large one.

The same arithmetic drives a second decision that a first-time importer usually makes by default. Do the containers go inland, or is the cargo stripped at the gateway and moved onward on flatbeds? A box that travels to a northern inland depot and comes back is out of the line’s control for a round trip that, on the longer legs, is of the same order as the free period itself, and container detention runs on the difference. Stripping at a container freight station near the port costs a handling operation and a tally, and it stops that clock. Neither answer is right in general; the answer is wrong only when nobody decided.

Two ways to clear, and they are not the same transaction

Clear at the gateway. A Bill of Entry for home consumption is filed at the port of discharge, duty and integrated tax are paid there, out of charge is given and the goods leave the customs area as ordinary domestic cargo. From that moment the movement is a transport problem with an electronic waybill and a lorry receipt, and customs has no further interest in it. The advantages are that it is the shortest path into free circulation, that any query is raised where the cargo physically is, and that eligible importers may take containers on direct port delivery without a container freight station movement at all. The disadvantage is cash: the buyer needs the duty and the tax at the gateway on the port’s timetable, at a moment when the material is still several hundred or a thousand kilometres from the site that will use it.

Move under bond to an inland container depot. The containers move from the gateway to an inland container depot under a transhipment permission, covered by a bond executed by the carrier or its agent, and the Bill of Entry for home consumption is filed at the depot, which is a customs station in its own right. The box leaves the port quickly, which stops the port storage clock; the inland movement is priced as a haul to a depot near the buyer; and assessment and any examination happen where the buyer’s own people are. The disadvantages are symmetrical and are routinely underestimated. The goods are not available until they are cleared at the depot, so the clock has moved rather than stopped. The risk-management selection and any examination happen inland, where a query is slower to resolve and the cargo is further from the people who can answer it. The container stays under the line’s detention for longer. And the buyer’s registrations have to be in order for that customs station, not only for the gateway — which is the same trap as the AD Code registered at the wrong port, one step further inland.

Warehouse it. A third route exists and it is a treasury decision rather than a logistics one. An into-bond Bill of Entry places the goods in a licensed customs bonded warehouse without payment of duty, against a bond; duty is paid later, when an ex-bond Bill of Entry is filed for the quantity actually taken out. The point that decides whether it is worth doing is the one made in the classification section above: for warehoused goods the rate of duty is the rate in force on the date of the ex-bond Bill of Entry, not the date the cargo landed. Interest becomes payable once goods have remained warehoused beyond the prescribed period, and the warehousing period is itself prescribed and extendable on application. For a buyer building stock ahead of the January-to-March push described further down this page, warehousing converts a duty-payment problem into a rent-and-interest problem and takes a rate risk in both directions. It belongs to the buyer’s finance function, and a seller should know it exists because it changes when the buyer wants the cargo to arrive rather than whether it wants it.

Rail, and where it actually helps

Containerised import traffic moves inland from the western gateways to the northern inland container depots by rail as well as by road, and the dedicated freight corridor built between the Gujarat and Maharashtra gateways and the northern hinterland exists for exactly that traffic. A supplier does not need to know the operating position and should not state one. Two things are worth knowing. First, a rail movement to an inland depot is one of the two clearance routes above, so choosing it changes where duty is paid and which customs station handles any query. Second, rail lengthens the period the container is out of the line’s control, which is a detention question and not a freight question, and it is settled with the line rather than with the railway.

The electronic waybill and the last leg

Once the goods are in free circulation, movement above a prescribed value requires an electronic waybill generated on the goods and services tax portal, carrying the consignment particulars and the vehicle number. For imported goods it is generated from the port or the inland depot to the buyer’s premises, using the Bill of Entry particulars. It is entirely the buyer’s responsibility, and it is mentioned here for one reason: an error in the Bill of Entry propagates into it. A wrong GSTIN or a party name that does not match does not merely misdirect the input tax credit; it follows the cargo onto the road document for the final leg.

Insurance does not follow the cargo inland by itself

A marine cargo policy written to the port of discharge covers the sea leg and stops. An import that finishes eleven hundred kilometres inland needs cover that runs to the named final place, and the transit provisions of whichever clause set is used have to be read against where the cargo is actually going rather than against where the bill of lading ends. Carrier liability under a domestic road consignment note is limited by the terms of that document and is not cargo insurance; it will not make a buyer whole on a full load of drums. Where the sale is on CIF terms, the cover the seller procures ends where the term ends, so the inland exposure is the buyer’s from the port gate onward and has to be arranged deliberately. This is the most commonly missed line on a first Indian import and it is missed because the marine policy looks comprehensive right up to the moment it is read.

What all of this means for the enquiry

Four answers turn a bitumen enquiry into something that can be priced properly: the delivery town, the packing, the gateway, and whether clearance is at that gateway or at an inland depot. The first sets the inland distance. The second sets the container count. The third follows from the first. The fourth sets the timetable and decides which clocks can run against the cargo. A supplier who receives all four can put a number against the whole journey; a supplier who receives only a port name is pricing the easy half and leaving the expensive half open, and so is the buyer who compares two such offers.

What is India-specific about a documentary credit here

How a credit is examined, what an issuing bank does and why a discrepancy matters are covered on the letters of credit page. Four things about an Indian import are not general and should be understood before a payment term is offered.

Paying is not the end of the buyer’s obligation. Import remittance is regulated, and the buyer’s authorised dealer bank has to be able to match the money that left the country to evidence that goods actually arrived. Bill of Entry data flows from the customs system into the Reserve Bank of India’s Import Data Processing and Monitoring System, and the bank closes the outward remittance against that record. An entry left open in that system is a live compliance item that belongs to the buyer and can hold up its later import remittances. This is the machinery behind a behaviour sellers often misread: an Indian buyer pressing hard on party names, on the spelling of an address or on a GSTIN is not being fussy, it is making sure the entry will match.

Timing is regulated at both ends. Remittance against an import is expected within the period the Reserve Bank prescribes from the date of shipment, ordinarily six months. Where the buyer pays in advance, evidence of import has to be produced within the prescribed period after the remittance, and advance remittance above a threshold requires an unconditional, irrevocable standby credit or a guarantee from an international bank of repute. That last requirement is most of the reason an Indian buyer prefers a documentary credit to an advance payment, and reading it as reluctance to pay misreads the position entirely. No thresholds or periods beyond the six-month convention are stated here; they are set by regulation, they are revised, and the buyer’s bank is the authority on them.

A long usance is not simply a payment term. Where a seller or a bank finances the buyer beyond a permitted period, the arrangement falls into the Reserve Bank’s trade credit framework — supplier’s credit and buyer’s credit — which caps maturity and all-in cost and imposes reporting on the buyer’s bank. Those caps are revised and are not stated here. The practical effect on an offer is direct: a tenor that looks like a commercial concession on the selling side may be a regulated instrument on the buying side, so ask what tenor the buyer’s bank can actually accommodate before offering one.

The credit is usually written against a project, not against a cargo. Indian buyers are frequently contractors with a specification obligation to a highway authority or a state public works department, so the credit tends to stipulate documents that evidence the grade and not merely the goods. That is why a certificate reporting penetration and softening point only is a bank refusal in India and no more than an irritation in a penetration-graded market: the document fails because the credit was drafted by somebody who has to satisfy an engineer.

The short-voyage problem, in full

The sea leg from a Middle East load port to a west-coast Indian port is short. No transit time is stated on this page, because the problem is structural rather than arithmetic and it does not depend on how many days the voyage takes. The documentary chain runs like this: the bill of lading is issued at the load port; the seller assembles the set; the set is presented to the nominated bank; that bank has a period to examine it, which under UCP 600 is a maximum of five banking days following the day of presentation; the documents are forwarded to the issuing bank, which has its own examination period on the same basis; the issuing bank releases the documents to the applicant against payment or acceptance; and the applicant presents an original bill of lading to the carrier’s agent to obtain a delivery order.

On a long ocean haul that chain runs in parallel with the voyage and finishes first. On this routing it does not. Two examination periods of up to five banking days each, plus courier time between two countries, plus a weekend at either end, is a period that does not shrink because the sea leg is short. The vessel is not competing with a courier; it is competing with a process, and the process has a floor.

What happens when the vessel wins

The consignee has no original bill of lading, so the carrier will not issue a delivery order, so the containers stay where the terminal put them. Every clock in the next section starts, and they start together. The Bill of Entry can be filed, assessed and given out of charge, and none of that produces a delivery order — customs releasing the goods and the carrier releasing the goods are two separate permissions from two unrelated parties, and buyers new to the trade routinely assume the first implies the second.

On a bulk parcel the position is worse rather than merely more expensive. The vessel discharges into shore tank against the master’s obligation to deliver to the holder of the bill, and the shipowner will not deliver without either the bill or an indemnity it finds acceptable. So the cargo is ashore, the buyer cannot lift it, and the vessel’s own clock is running under the charter party.

One statutory backstop is worth knowing because it explains why nobody at the port treats a stuck consignment as indefinitely somebody else’s problem: section 48 of the Customs Act, 1962 permits the custodian to sell goods that are not cleared within thirty days of unloading, after notice to the importer and with the proper officer’s permission. It is a remote outcome on a live commercial cargo, but it sets the outer edge of the argument.

The options, and what each one actually costs

1. Telex release or express release. The shipper surrenders the full set at the load port and instructs the carrier to release without originals at destination. Cheapest and fastest, and it removes the security that the documentary credit exists to provide. Unusable under a credit calling for a full set of originals unless the credit was drafted for it. Suits a repeat relationship or a structure where the bank is not relying on the bill for control.
2. Sea waybill. Non-negotiable, consignee named, delivery against proof of identity. It removes the problem completely and removes the document of title with it. Workable where the buyer’s bank does not need the bill as security, or where the bank itself is named as consignee.
3. Bill consigned to the issuing bank, or to its order. The bank retains control and endorses on payment or acceptance. This is the arrangement most compatible with both a credit and a short voyage, because the endorsement is a counter transaction in the buyer’s own city rather than an international courier movement.
4. One original couriered directly to the consignee. Common, and it must be authorised expressly in the credit — a stipulation of the form that one original bill of lading has been sent directly to the applicant. Without that authority it is a discrepancy. It also means the buyer can take delivery whether or not it honours the presentation, which is precisely the security the seller thought it had.
5. Letter of indemnity to the carrier, countersigned by a bank. The buyer asks the carrier to deliver without production of the bill against an indemnity on the carrier’s own standard form, which for a bulk parcel usually requires a first-class bank’s countersignature. The indemnity is typically unlimited in amount and open-ended in time, the bank will hold security against it, and it is not free. It is nevertheless the standard answer on a bulk parcel.
6. Shipping guarantee issued by the buyer’s bank to the carrier. This is the Indian bank product designed for exactly this situation: the bank guarantees the carrier against the consequences of releasing the cargo without the bill, and the buyer takes delivery. The trap is the one nobody mentions at the counter. A buyer that has taken delivery under its own bank’s shipping guarantee will be required to accept the documents when they arrive, discrepant or not, because the bank cannot be left guaranteeing a delivery its customer then refuses to pay for. A buyer who intends to preserve the right to reject discrepant documents cannot also take the cargo this way, and a seller should understand the mechanism because it is what quietly removes the discrepancy argument from the table.
7. Electronic bill of lading under an approved rulebook. Real and growing, and only useful where the carrier, both banks and the practice at the destination all accept it. Confirm it on the specific trade lane rather than assuming it.

What to write into the contract, before the credit is opened

• Name the release mechanism for this shipment and say who pays for it. A sentence providing that the seller will procure a telex release at its own cost if the original documents have not reached the issuing bank by the vessel’s arrival is a clause. An argument at the berth is not.
• Cut the presentation period. UCP 600 gives a default of twenty-one calendar days after the date of shipment, and on this routing that default is the problem rather than the protection. A shorter stipulated period, with the credit’s expiry set to match, keeps the documents ahead of the vessel instead of behind it.
• Require the scanned set within a stated number of hours of the on-board date, with the courier airway bill number advised the same day. Scans release nothing, but they let the broker upload through e-Sanchit and file the Bill of Entry before arrival, and that is the part of the timetable that is genuinely recoverable.
• Allocate the cost of delay caused by documents to the party that controls the document, and define what attributable means before anyone needs the definition. Free time is a budget, not a remedy.
• Where the cargo is bulk, permit a charter party bill of lading in the credit expressly, and attach the laytime and demurrage terms to the sale contract rather than incorporating them by reference to a document the buyer has never seen.
• Fix the discharge port before the credit is issued. A credit naming a port the cargo does not use requires an amendment, and an amendment on a short voyage is measured against a vessel already at sea.

Laytime, free time and demurrage, for a buyer who has never had to argue one

There are four separate clocks, with four different payees and four different rulebooks, and the most expensive mistake a first-time importer makes is to treat them as one thing called demurrage.

1. Laytime and demurrage under a charter party. This applies to a bulk parcel only and it is the one with the largest numbers behind it. Laytime is the period the charterer is allowed for loading and discharging without further payment; demurrage is liquidated damages at an agreed daily rate for exceeding it. The vocabulary that decides who pays:

• Notice of readiness. The master tenders it when the vessel has arrived and is ready in all respects to discharge. Laytime begins after a stated notice or turn time, and the length of that period is a contract term.
• The abbreviations that decide whether the clock runs while the vessel waits. WIBON, whether in berth or not. WIPON, whether in port or not. WIFPON, whether in free pratique or not. WICCON, whether customs cleared or not. Each of them moves the risk of waiting from the shipowner to the charterer, and on a congested berth that risk is the whole argument.
• The exceptions. SHEX means Sundays and holidays excepted, SHINC means included, and clauses on weather working days and on time lost waiting for a berth do the rest. These are not boilerplate: they decide how many hours a calendar day contributes.
• Once on demurrage, always on demurrage. The exceptions that stop laytime do not stop demurrage unless the clause expressly says so. The first day of delay is expensive and the tenth is worse, and the curve is not linear in effort.
• The evidence and the time bar. The claim is built on the statement of facts and the time sheet signed by the master and the agent at the discharge port, and charter parties commonly bar a demurrage claim that is not presented with supporting documents inside a fixed period after completion of discharge. That period is short. A buyer who intends to dispute a claim needs the port papers on the day, not the month after.

Where the sale is CFR or CIF the seller is usually the charterer, and the sale contract typically passes discharge-port demurrage to the buyer as per charter party. A buyer who signs that has accepted a liability defined by a document it has never read. Ask for the laytime allowed, the demurrage rate, the notice time and the exceptions to be written into the sale contract itself, or for the relevant charter party extract to be attached to it. Two lines generate most bitumen disputes: the guaranteed discharge rate and the cargo temperature clause. If the shore tank cannot receive at the rate the vessel warrants, or the discharge line is not traced and hot, the delay sits on the receiving side and laytime runs against the buyer. That is why the ports table asks for four things in writing before a parcel is fixed — tank allocation, working temperature on arrival, discharge rate and free time — and it is the same four questions in a different order.

2. Terminal storage, or ground rent. Charged by the custodian of the customs area — the port terminal or the container freight station — for occupying space beyond a free period, and payable to that custodian. One India-specific protection is worth knowing: the Handling of Cargo in Customs Areas Regulations, 2009 oblige a custodian not to charge rent or demurrage on goods seized, detained or confiscated by customs, and a detention certificate is the instrument through which that is claimed. It is a real protection and it is narrow. It addresses delay caused by customs action, not delay caused by the buyer’s paperwork, the seller’s courier or a bank’s examination period.

3. Container demurrage. Charged by the shipping line for the container remaining inside the terminal beyond the line’s free days, and payable to the line. Note that the word means something different here from what it means in the charter party paragraph above, which is exactly why the four clocks get confused.

4. Container detention. Charged by the line for the container being outside the terminal — at the buyer’s yard, a plant or an inland depot — beyond the free days, and again payable to the line. On a long inland leg the round trip can exceed the free period on its own, which is the arithmetic behind the decision to strip at the gateway discussed in the inland leg section. A customs detention certificate does not bind the line: detention is a contractual charge under the carrier’s tariff, and any waiver is a commercial decision rather than an entitlement.

No free periods, rates or charges of any kind are stated anywhere on this page. They are commercial terms between the buyer, the line, the terminal and the charterer, they differ by port and by contract, and a figure quoted from another shipment is worth nothing.

The decision rule

Before the vessel is fixed, get four answers in writing. Which of these four clocks can run on this shipment. Who pays each one. What starts and stops each one. And which document releases the cargo if the originals are not there on the day. Three of the four are avoidable by a clause drafted before anybody is under pressure, and all four are unanswerable once the vessel is on the berth.

Two wet seasons, not one

The southwest monsoon reaches the Kerala coast around the beginning of June, advances north and covers most of the country by mid-July, then withdraws from the northwest through September and from most of the peninsula through October. For the west coast, the north and the interior that is the paving shutdown, and it is the low season for binder demand.

Tamil Nadu is the exception that matters commercially: it takes its largest single share of annual rainfall not from that system but from the northeast monsoon between October and December, while coastal Andhra Pradesh and the Rayalaseema interior take a substantial share from the same system on top of what the southwest monsoon gives them. The practical consequence is that the wet season at Chennai is roughly the opposite of the wet season at Mumbai. A supplier who builds one Indian shipping calendar is building it for the wrong half of the country, and a cargo timed to land just after the southwest monsoon lifts arrives on the Tamil Nadu coast exactly as its own wet season begins.

The specification, not the preference, is what stops the work

This is not a matter of contractors preferring dry weather. The Ministry of Road Transport and Highways Specifications for Road and Bridge Works require that bituminous work is not carried out during rain, on a wet or damp surface, or when the air temperature is below the stated minimum. The engineer cannot authorise laying in those conditions, so demand for binder does not taper through the monsoon — it stops, and then returns hard when the weather lifts. Storage in the interval is the buyer’s problem: drums standing uncovered in an open yard through a monsoon corrode and take in water, which is why water content belongs on the certificate and why drums should be stored under cover and off the ground.

The financial year is the other season

The Indian financial year runs from 1 April to 31 March. Government road budgets are allocated and released against that year, and a substantial share of state public works and highway spending is pushed into the January-to-March quarter so that allocations are not surrendered unspent. Set that against a working paving season that runs roughly October to June in most of the country, and the tightest period for binder is the pre-monsoon window from about January to May, while the monsoon months are the loosest.

For a supplier the scheduling consequence is direct. A cargo intended for the March push has to be fixed against a load-port and voyage schedule that puts it in the buyer’s yard well before March, not against a Bill of Entry filed in March. Buyers who enquire in February for material they need in March are asking for a shipment that has already sailed.

Cyclones, and which coast pays for them

The Bay of Bengal cyclone season is bimodal, with a pre-monsoon peak around April and May and a stronger post-monsoon peak from October into December. It is the east-coast ports — Chennai, Kamarajar, Krishnapatnam, Visakhapatnam, Paradip and Haldia — that suspend operations for it, sometimes for several days at a time. The Arabian Sea season affects the west coast less frequently. Where a bulk parcel is being fixed to an east-coast port in that window, the possibility of a port closure belongs in the laytime and free-time discussion rather than in a demurrage argument afterwards.

The inland leg is seasonal too

Movement inland from the gateways slows in the same months. Road haulage through the Western Ghats from Mangaluru or Cochin, and the eastern corridors out of Haldia and Paradip, are the first to suffer in heavy rain. The Siliguri corridor that connects the rest of India to the North Eastern states is a single narrow land route, so a monsoon disruption there has no alternative around it; the same applies to transit traffic moving to Nepal through Raxaul and Birgunj or to Bhutan through Jaigaon. Where a cargo is destined beyond the immediate port hinterland, add the inland leg to the shipment window rather than treating clearance as the finish line.

• Bitumen supply to Nepal — what changes when the cargo clearing an Indian port is not staying in India: a transit regime rather than an import, and a delivery term that must name an inland place