Study Guide

Comparing the different Convention regimes

The Hague Rules 1924 imposed a general liability on carriers to provide a seaworthy vessel and to handle goods with care, subject to a list of exceptions — including fault of the master or pilot in navigation, act of God, act of war, riots, strikes, and saving life or property at sea. Liability was limited to £100 sterling per package or unit.

The Hague-Visby Rules retain the same exceptions but increase the liability limit to 666.67 Special Drawing Rights (SDRs)[1] per package or 2 SDRs per kilogram of gross weight, whichever is higher (unless the parties have agreed a higher value). One SDR is approximately USD 1.35 (May 2025).

The Hamburg Rules 1978 were developed in response to concerns from developing countries and cargo owners that the Hague and Hague-Visby Rules favored shipowners. Under the Hamburg Rules, the carrier is liable from the moment goods are placed in its care until the moment they are delivered, regardless of whether the goods are on board a vessel. Under the Hague and Hague-Visby Rules, liability runs only from the point at which goods pass the ship’s rail for loading to the point at which they pass the rail for discharge.

Feature	Hague Rules (1924)	Hague-Visby Rules (1968)	Hamburg Rules (1978)
Period of liability	Tackle to tackle (ship's rail)	Tackle to tackle (ship's rail)	Port to port – from receipt to delivery
Liability limit	£100 sterling per package	666.67 SDR/package or 2 SDR/kg (higher applies)	Higher: 835 SDR/package or 2.5 SDR/kg
Carrier exceptions	Nautical fault; act of God; war; fire; etc.	Same exceptions as Hague Rules	No nautical fault exception; narrower list
Issuing context	Outward: US, India, Indonesia, S. Korea, Philippines, Taiwan, Malaysia	Outward: Australia, UK, Canada, Japan, NZ, Singapore, HK, most EU countries	Fewer signatories; ratified mainly by developing nations

 

Note It is important to identify which conventions a country has ratified, as definitions and liabilities vary between regimes, including the meaning of key terms such as “carrier” and “consignee.” Where multiple conventions apply, the governing law must be clearly determined.