e-CMR and eFTI: what the digital consignment note changes in your paperwork

The e-CMR is an electronic consignment note, and in the Netherlands it is allowed but not mandatory. The eFTI Regulation puts the duty on authorities: from 9 July 2027 they accept electronic freight information from a certified platform. In many warehouses the CMR is still a set of carbon copies at the dispatch desk. Days after the trip a signed copy comes back, and someone scans it and looks for the order. What changes once that paper becomes data is set out below rule by rule, with the source next to it.

What is an e-CMR?

An e-CMR is the electronic consignment note for international road transport under the CMR Convention, made out and signed by electronic communication instead of on paper. Its basis is the Additional Protocol to the CMR concerning the electronic consignment note, adopted in Geneva on 20 February 2008. The CMR Convention itself dates from 1956 and assumed paper.

Under article 2 of the protocol, an electronic consignment note that meets its requirements is equivalent to the paper CMR, with the same evidentiary value and the same effects. It carries the same particulars (article 4). The protocol does not prescribe a system or an app. The e-CMR is a legal form, and which platform you use is something you agree with your carriers and customers.

Is the e-CMR allowed in the Netherlands?

Yes, the e-CMR has been allowed in the Netherlands since 5 June 2011, the day the protocol entered into force. The Netherlands signed the protocol on 28 May 2008 and ratified it on 7 January 2009. The Dutch treaty database lists the protocol as in force from 5 June 2011.

The protocol does set requirements. The parties authenticate the e-CMR with a reliable electronic signature that is linked to the signatory and makes later changes traceable (article 3). An addition or amendment must be visible, and the original data stays preserved (article 4). The parties to the contract of carriage agree between them how the e-CMR is made out and delivered, and how delivery to the consignee is confirmed (article 5).

If a shipment goes abroad, check the United Nations treaty list to see whether the country at the other end has adopted the protocol too.

Domestic transport falls under the Dutch Road Haulage Regulation (Regeling wegvervoer goederen). It knows the electronic consignment note as well. If the consignment note data is exchanged in a structured, standardised way through an electronic system, the rules about a paper note in the vehicle and signing for it on delivery no longer apply (article 15, third paragraph).

Is the e-CMR mandatory?

No, there is no Dutch or European rule that obliges you to use the e-CMR. The protocol says the consignment note may be made out electronically. The eFTI Regulation expressly keeps paper possible, see below.

What is mandatory is something else: that there is a consignment note. Article 2.13 of the Dutch Road Haulage Act prohibits haulage for hire when no consignment note has been made out, or when the driver cannot show a complete and correct one at an inspection. The Human Environment and Transport Inspectorate (ILT) checks this at the roadside and at company inspections. A packing slip or delivery note is not a consignment note, according to the ILT. A few kinds of transport are exempt, for example lorries with a payload of up to 500 kilos, household removals and postal items.

If your warehouse or 3PL does not drive itself, you are often the sender. You fill in the consignee, the nature of the goods and the gross weight. For cross-border transport that includes, among other things, the number of packages and the customs instructions. If those details are incomplete or wrong, the prohibition is aimed at the sender (article 15, fifth paragraph, of the Road Haulage Regulation).

What does the eFTI Regulation require?

The eFTI Regulation, Regulation (EU) 2020/1056, obliges authorities in the EU to accept freight transport information electronically when a business makes it available through a certified eFTI platform. eFTI stands for electronic freight transport information. The regulation covers road, rail, inland waterways and air.

From when must authorities accept digital transport documents?

Authorities must accept electronic freight information through a certified eFTI platform from 9 July 2027. Article 5 starts that duty 30 months after the first implementing and delegated acts entered into force. Those acts entered into force in January 2025. The European Commission names 9 July 2027 as the date the regulation applies in full.

Since January 2026 authorities may already accept data from certified platforms at an inspection. The Commission plans to adopt the remaining technical requirements for platforms and the rules for their certification by December 2026.

What do businesses have to do under eFTI?

As long as you use paper, eFTI puts no new duty on you. The regulation expressly keeps the option of presenting information on paper (recital 7).

If you go digital, the requirements of article 4 apply. The information comes from a certified eFTI platform. It is machine readable over a secure connection, and an inspector can read it on the spot on the screen of your device. Whether businesses will later be obliged to go digital is something the Commission looks at in an evaluation due by 21 February 2029 (article 16).

Which information falls under eFTI?

eFTI covers the transport information an authority may request under EU rules. Article 2 lists, among others, the details for cabotage and combined transport, the documents for dangerous goods under ADR, RID and ADN, and shipments of waste. The regulation leaves customs controls untouched. If a national law asks for the same data, it only falls under eFTI when that rule is on the list in Annex I, Part B (article 2 and recital 6).

What changes in the paperwork of a warehouse or 3PL?

With an electronic consignment note the consignee’s signature arrives as data instead of as paper that comes back days later. The protocol asks the parties to agree how delivery to the consignee is confirmed. In a digital system that confirmation sits with the shipment, with a time and a name, plus the consignee’s remark if they make one.

On the dispatch floor

Your dispatch team stops printing sets of CMRs and stops hunting for carbon copies. The data the sender fills in is already in your WMS or TMS: consignee, goods, packages and weight. When digitising the CMR, the first question is whether that data flows from your own system into the e-CMR, or whether someone types it again into a carrier’s portal. How to build that link is in connecting WMS, TMS and ERP.

In the office

A remark from the consignee, such as a damaged pallet or one package short, arrives with the shipment attached. You link it to the order, and a claim or a follow-up delivery can start as soon as it is in. At the same time you deal with more parties. One carrier uses an e-CMR app, another still sends paper, a third emails a PDF. For the next few years your office works with a mix of channels.

Consignment note data as fields, and what you can automate with it

An e-CMR delivers the consignment note data as fields instead of as an image: sender, consignee, packages, weight, the moment of delivery and the consignee’s remark. A system then has nothing to read or guess. It can put the fields straight next to your own data, without anyone first opening a scan, looking for a signature and retyping the number of packages.

Per shipment you can then check whether the number of packages delivered matches what the WMS released, and whether every delivered shipment is on an invoice to your customer. A signed consignment note is also the evidence next to your carrier’s invoice. That is the core of checking freight invoices.

Paper and scanned CMRs are not going away for now, because nobody is obliged to switch. That is where AI does the work. A language model with document extraction reads the scan or the PDF and fills in the same fields as if it were an e-CMR. With a stamp across the text or a handwritten remark that does not always go right. When the system is unsure about a value, that value goes to a queue where a person looks at it. How that works for orders, invoices and consignment notes together is in document processing in logistics.

According to the European Commission, you can share data on an eFTI platform selectively with business partners you give access, and the platforms can be connected to the systems companies already have. How that works out in practice depends on the platforms your carriers choose.

What to do now and what can wait

If one of your carriers already runs on an e-CMR, ask whether the data you fill in as sender can come from your WMS or TMS. Otherwise someone types it again into its portal.

If you only work on paper, eFTI asks nothing of you. Do measure how long it now takes before a signed CMR is with the order and how many never come back, starting with the proofs of delivery from one carrier or one customer. That baseline is the reference point in our way of working, and with those two numbers an introductory call has something concrete to start from.

Whether businesses will later have to go digital stays open until the Commission’s evaluation, due by 21 February 2029.