The green light for eBLs

Electronic bills of lading become law in the Netherlands

It has been an exciting few months for Dutch digital trade. On 31 March 2026, both Houses of Parliament approved an act giving electronic bills of lading (eBLs) the same legal status as paper. And then on 8 June, a Royal Decree set 1 July 2026 as the entry-into-force date for the new legislation.

These events mean that the Netherlands has crossed a significant threshold in trade digitalisation and places the country alongside the United Kingdom, France and Germany as European early adopters.

The first ICC Netherlands Digital Business Lunch – held three days before the decree was signed – anticipated this moment and set out what Dutch business should do next. More than 40 trade, banking and logistics professionals joined ING Bank Managing Director Ron van Staten and Philips Head of Global Trade Compliance Michel van den Hoven to discuss what comes next.

From orange to green

Van Staten has worked alongside the Ministry of Justice and industry stakeholders on the new legislation. At the time of the Digital Business Lunch, he framed the moment as “an orange light” – approved, but not yet operative. Now with the legal threshold crossed, the orange light has turned to green.

The new legislation is narrower than many had hoped. It covers bills of lading but not yet promissory notes, bills of exchange or warehouse receipts. However, Van Staten showed optimism, reaching for a pragmatic Dutch turn of phrase to describe the situation: “better to have one bird in the hand than ten in the bush”. He added that recognising the eBL on its own “removes the single largest legal obstacle in maritime trade documentation – broader expansion will follow”.

The pain of paper

For an exporter, the cost of paper trade is not abstract. Van den Hoven has spent 20 years at Philips, the last five of which heading the global trade compliance team. He estimated that Philips runs “around 8,000 distinct trade flows through multiple jurisdictions, each carrying its own combination of bills of lading, commercial invoices, packing lists, certificates of origin, customs declarations, export licences, insurance and letters of credit”. In his sector, integrated warehousing and distribution costs typically sit at three to six per cent of total sales. Bringing that down by a single percentage point through digitalisation, he said, is “direct money on the table”. The sustainability dividend – less paper, fewer courier journeys – is added on top of that.

Referring to the practical work due to start on 1 July, Van den Hoven’s central advice to the people attending the Digital Business Lunch was simple: to think in terms of data, not in documents. “A bill of lading is a data set. So is a letter of credit, a customs declaration, an export licence. Once a company starts modelling its supply chain as data, the rest becomes a question of integration. It’s a change of mindset,” he said. “One that needs to be embedded as much at executive level as on the warehouse floor.”

What Dutch businesses can start doing now

For a mid-sized Dutch exporter weighing up the options of where to begin, both speakers converged on the same advice: start small, and start with the counterparties you already trade with.

Van Staten’s practical sequence runs as follows. “Identify your buyers, sellers, carriers and bank, and ask each of them what digital frameworks they already operate in,” he said. “Establish which platforms they are signed up to. Map where the dots can already be connected, and where they cannot.” Test cases should be trialled on low-pressure projects (so not a shipment that has to leave tomorrow) and scaled up as experience grows. “The risk to avoid is letting a familiar process derail because the new one is not yet familiar.”

Van den Hoven reinforced the point with three lessons from Philips’ own operations. “First, think in data. Second, invest in change management at every level; top management included, because executives need to see the return on a digital programme before the floor will follow. And third, build in partnerships: digital trade only works when buyers, sellers, banks and carriers move together.” The remaining barrier is trust, he argued, and the answer to it is evidence: “that digital documents are more transparent, more traceable and easier to audit than paper. Companies should aim for adoption levels of 50, 60, 70 per cent rather than chase a binary target.”

It is also notable that there is also an immediate workaround for cross-border trade. Around 80 per cent of bills of lading worldwide are governed by English law, which has recognised electronic transferable documents since the UK Electronic Trade Documents Act came into force in 2023. Dutch businesses can already issue and receive eBLs under English law for shipments to a port whose national law accepts them. Cross-border recognition still needs to be checked port by port; the destination country must accept the electronic document at delivery. But for many trade routes, the route forward is already open.

The road ahead

ICC Netherlands has long advocated for the Dutch adoption of MLETR and welcomes the new act as a significant step in aligning Dutch trade with international digital standards. The work now is to broaden the scope to other negotiable trade documents, to support the interoperability conversation between platforms, and to help Dutch business in the first months of entry into force. We will continue to work closely with members, partners and policymakers to keep that momentum.

The Digital Business Lunch is a monthly online series discussing the issues that move international trade – covering a range of subjects from sanctions and export controls to customs reform, AI in trade compliance and sustainability.

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