How to fill out a CMR consignment note box by box and cross-check it with the packing list

The declarant takes the number of packages in the customs declaration (CD) from the transport document; this is explicitly stated in the instructions for the CD. If the CMR states one number of packages, the packing list states another, and no one noticed this during loading, the discrepancy will surface at customs, where fines are already imposed for it. That is why we issue the consignment note last, once the cargo is packed and recounted, transferring the figures into it from the packing list rather than from the supplier's documents.

The consignment note is drawn up last, based on the packing list and invoice

The international CMR consignment note confirms the contract of international road carriage. Its content is governed by the 1956 Convention on the Contract for the International Carriage of Goods by Road (CMR Convention), and it applies if the places of loading and delivery are located in two different countries, at least one of which is a contracting party to the convention. Russia, Belarus, and Kazakhstan are contracting parties. The convention does not prescribe a standard form or number the boxes; it merely lists the particulars that must be included in the consignment note. Therefore, we provide the box numbers according to the Russian-German form used in Russia and Belarus.

The CMR is often referred to as a customs consignment note, although it is a transport document. It does not replace the declaration; it only provides the source data for it.

The sender is responsible to the carrier for the accuracy of the cargo details. Under Article 7 of the CMR Convention, the sender is liable for all expenses and damages sustained by the carrier due to inaccurate details regarding the consignee, place of delivery, description of the goods, packaging, number of packages, markings, gross weight, or customs instructions. Upon taking over the goods, the carrier is only obliged to check the number of packages, their marks and numbers, and the apparent condition of the goods, while the weight is verified only if requested by the sender.

Two parties are held liable before customs. Upon arrival, the carrier provides the details regarding packages and weight, and the carrier is held accountable for their accuracy at the border crossing. The declaration is submitted by the importer, and any discrepancy between the consignment note, the packing list, and the actual cargo during clearance is settled directly with the importer, regardless of who is listed as the sender in box 1 or under which trade term the delivery was made. Therefore, the importer should inspect the consignment note before the truck departs, even if it was filled out by the supplier.

This leads to the rule by which we complete the consignment note. Packages (box 7) are counted based on what is physically loaded into the vehicle body; gross weight (box 11) is taken from the packing list, including pallets and packaging; descriptions (box 9) are entered according to the invoice, as a separate line for each FEA CN code; the code (box 10) matches the one in the declaration, consisting of at least six digits; the consignment note itself is compiled after final packaging, rather than from the supplier's documents.

This was how we handled a shipment of auto parts for an e-commerce store—900 kg of filters, brake pads, and sensors from multiple suppliers—as LTL consolidated cargo via Kazakhstan. The suppliers delivered the goods to our warehouse in China and submitted their own package count and weight data. After repackaging onto pallets, labeling, and recounting, the actual figures turned out to be different, and those actual figures went into the consignment note instead of the suppliers' data. The shipment was dispatched to Moscow under a CMR consignment note and arrived within 12–14 days.

Suppliers count boxes, while after cargo consolidation at the warehouse, pallets are loaded into the truck, meaning the factory packing lists no longer reflect what is inside the cargo hold. If you enter numbers from supplier documents into the CMR, the consignment note will almost certainly conflict with the actual cargo in the very boxes checked during loading and customs clearance. The new packing list for the actual consolidated lot is prepared by whoever repackaged the cargo, and this new document—not the factory lists—is included in the customs package.

Where discrepancies in the consignment note surface and who pays for them

The consignment note is checked at every stage of the route, and each inspector focuses on specific boxes. The shipper in China verifies the number of packages prior to loading because they file an export declaration. The carrier checks the packages during loading. Upon import, customs receives the number of packages, markings, packaging type, gross weight, commodity codes (at least the first six digits), and the place and date of CMR issuance from the carrier in accordance with Article 89 of the EAEU Customs Code. The declarant enters the packages into the customs declaration.

Under Part 3 of Article 16.1 of the Administrative Offences Code, the fine for providing inaccurate information regarding package count, markings, description, and gross weight upon arrival, departure, or transit ranges from 50,000 to 100,000 rubles for legal entities, with or without confiscation of goods. The fine is issued to the party that reported the data to customs, typically the carrier. The Administrative Offences Code explicitly classifies documents containing false information as invalid.

Whether the fine is classified as damages that the carrier is entitled to claim from the sender is determined by the parties or by a court, but the underlying error in the records under Article 7 of the CMR Convention remains the sender's liability.

When we prepare a declaration, box 6 is filled out based on the consignment note; if the packages do not match the packing list, we catch this before the customs inspector does. We explained how packing list data translates into the remaining boxes of the CD and the costs associated with discrepancies between physical cartons and paperwork in our article on reconciling the packing list with the invoice.

A package is what the carrier can recount

The CMR Convention does not define what constitutes a package. However, it obliges the carrier to check the number of packages upon takeover and, if verification is impossible, to enter a reasoned reservation in the consignment note. A driver is unlikely to recount individual cartons inside a stretch-wrapped pallet. Therefore, we define a package as whatever can be physically counted by the side of the truck: pallets if the cargo is palletized, and individual cartons if it travels loose.

The packing list must reflect the exact same breakdown. If the consignment note specifies 12 pallets, the packing list must also specify those 12 pallets along with the breakdown of cartons per pallet. Instructions for completing the CD for palletized goods also require data on pallets and their quantity in box 31, so pallets will appear in the customs declaration as well.

The package count changes whenever cargo is repackaged. In a case where we performed a factory audit before invoice payment, our inspector discovered inadequate packaging on a 350 kg shipment of circuit boards and microcontrollers. At the warehouse, the cargo was repackaged with shock-absorbing material inside rigid wooden crates, arriving via road transit through Kazakhstan in 18 days without damage. By the time of loading, the factory cartons were no longer individual packages; the crates had replaced them.

Box 11 is reserved for gross weight, including packaging; pallets, crating, and film add kilograms that are usually omitted from factory documentation. If you have doubts about the supplier's stated weight, you can demand reweighing upon loading from the carrier. Under Article 8 of the CMR Convention, this is the sender's right, so the party named in box 1 must request it, and the carrier enters the result into the consignment note.

If the weighing result contradicts the packing list, correct the packing list before departure. Otherwise, the cargo and consignment note will match, but the consignment note and packing list will diverge, leaving the discrepancy unresolved.

In our experience, volume calculations are often miscalculated even before reaching the warehouse. The client or factory sends dimensions based solely on the product itself, excluding the outer transport cartons into which individual packages are packed. At loading, the goods are already packed inside these cartons, resulting in a larger volume, and the consignment may not fit into the reserved space, whether it is part of a consolidated truck or an entire euro trailer cargo hold. Therefore, we request that the volume for box 12 and for booking be calculated strictly inclusive of transport cartons.

In consolidated shipments, surplus cubic meters also impact the shipping cost because lightweight cargo is calculated by volume rather than weight. We have covered how the w/m rule in consolidated cargo works in a dedicated article.

When this completion procedure will not work for you

The most important limitation concerns who issues the consignment note. Everything stated above assumes that you or your freight forwarder compile it based on your documents. If the CMR is prepared by the supplier in China or by the carrier, you can only influence the boxes via a draft prior to the truck's departure by cross-checking the packages, weight, descriptions, and code against the packing list and invoice.

If you are using the 2007 IRU form or the classic international form, the box numbers of the Russian-German form do not all correspond. We advise verifying boxes by title, as relying solely on numbers makes it easy to make a mistake. The 2007 IRU form also lacks a box for the statistical number, so the code should be appended to the goods description.

In multimodal freight transport, a CMR is required specifically on road legs that cross an international border. If cargo arrives by sea or rail, and a truck subsequently hauls it from the port or rail terminal within the destination country, a CMR is no longer used for that domestic leg. Such a leg is covered by a domestic transport waybill and, while the cargo remains under customs control, a customs transit declaration. The sea leg is covered by a bill of lading, and the rail leg by a rail consignment note. The exception is when the truck with the cargo is transported by ferry or rail without unloading: under Article 2 of the CMR Convention, the convention then applies to the entire journey.

If the truck carries consolidated cargo, as in our LTL case, a single consignment note for the entire vehicle may not suffice. Article 5 of the CMR Convention grants the sender and the carrier the right to require a separate consignment note for each vehicle, each type of goods, or each lot. This should be agreed upon before loading to ensure that packages belonging to one lot are not mixed with another party's cargo in a single consignment note.

Who fills in the boxes and where to get the data

In Russia, no official regulation prescribes the completion procedure for the CMR. The assignment of boxes is outlined in Belarusian Ministry of Transport Instruction No. 92, effective January 1, 2026. The sender completes boxes 1–15, 21, and 22; the carrier completes 16–19 and 23; the consignee completes 24; and box 20 is filled in by the contracting parties. The carrier reserves boxes 25–29 for vehicle registration details and freight calculations; these boxes do not appear on the classic international form. For shipments from Belarus this instruction is mandatory, and for shipments from Russia on the same form it serves as a reliable guideline.

A sample of CMR completion by box with the data source for each is provided in the table below.

To demonstrate how boxes 6–11 look in practice, here is an example based on a lot similar to our auto parts case. Figures and markings are illustrative.

If goods with different codes are packed on a single pallet, the package count is still determined by pallets, while the itemized breakdown across them is shown in the packing list.

In box 15 of the Russian-German form, the Belarusian instruction requires payment terms under the contract, and in Russian practice, the Incoterms 2020 trade term is also entered. The delivery term in the consignment note must match the term in the invoice; otherwise, the documentation will describe two different transactions for the same cargo.

Who is listed as the sender in box 1 if goods from multiple suppliers are consolidated at a warehouse in China? Under the CMR Convention, the sender is a party to the contract of carriage; therefore, in consolidated shipments, it may be the supplier, the buyer, or the freight forwarder, depending on who orders the transport. Determine this prior to loading, as the answer dictates who signs box 22 and who bears liability under Article 7.

However, who physically fills out the form has little bearing on legal liability. If a freight forwarder—including TransGID—fills out the consignment note on behalf of the sender, the party identified as the sender in box 1 remains strictly liable to the carrier for the accuracy of the data. Article 7 of the CMR Convention confirms that entries made by the carrier upon the sender's request are deemed to have been made on the sender's behalf. That is why we require the packing list and invoice from the client and populate the boxes based on them, rather than relying on verbal descriptions.

Boxes 3, 10, 20, and 24 on different forms

The box number depends on the form used, and there are at least three forms in circulation: the Russian-German form, the classic international form in English, French, and German, and the 2007 IRU form. On the first two, boxes 1–13, 16–18, and 21–24 correspond, while 14 and 15, and 19 and 20 are transposed. On the 2007 IRU form, the numbering differs almost entirely.

Box 3 indicates the place of delivery, not the consignee's address

Box 3 designates where the cargo will be unloaded, specifying the city, country, and warehouse address. The unloading address does not have to match the consignee's address in box 2, as goods are frequently delivered to a warehouse rather than a corporate office. On the 2007 IRU form, the place of delivery was moved to box 4, while box 3 is used for the place and date of taking over the goods.

The statistical number in box 10 is the FEA CN code

There is no statistical number provision in the CMR Convention itself; the box exists solely on the form, and on the 2007 IRU form it was eliminated. In Belarus, starting from 2026, regulations require entering an EAEU FEA CN code of six or more digits in box 10, whereas previously four digits were sufficient. Russia has no single formal rule. However, the EAEU Customs Code requires the carrier to declare a code of at least six digits upon import, and the consignment note is the most straightforward source for this. We enter the complete code determined for the customs declaration—meaning all ten digits if the declaration is ready, and at least six digits in any event.

Where can you obtain the statistical number if the code is not yet determined? Consult your declarant, because the code is assigned during FEA CN classification, and in the CMR it must match the code in box 33 of the declaration. For the auto parts from our case, codes were determined separately for filters, pads, and sensors; grouping them under a single generic name is prohibited. In the consignment note, this corresponds to three separate lines in boxes 9 and 10.

Box 20 means different things on different forms

On the Russian-German form, box 19 is designated for carriage charges and ancillary transport costs, while box 20 covers special agreed terms. On the classic international form, the layout is reversed: box 19 is for special conditions, and box 20 is for freight calculations. On the 2007 IRU form, box 20 features a pre-printed clause stating that the carriage is subject to the CMR Convention.

Under the Belarusian instruction, the parties enter the agreed transit time, amounts payable by the consignee upon delivery, and insurance instructions into box 20. If cargo is discharged at a TSW in Belarus, the warehouse representative records the date of receipt, warehouse receipt number, signature, and stamp in box 20.

Box 24 is completed by the consignee

Box 24 is identical across all three forms. The consignee enters the date of cargo receipt, arrival and departure times for unloading, and provides an authorized signature and stamp. According to the Belarusian instruction, this endorsement is made on all copies—no fewer than three—and may be executed by an authorized representative of the consignee. If the consignee rejects the cargo, this must be explicitly noted in box 24 alongside the reason for refusal; cargo shortages must also be recorded there.

Consignment note number and number of copies

Where is the CMR number located? It is typically a pre-printed serial number applied by the printing company issuing the forms. On the Russian-German form, it is located in the header following the document title; on the 2007 IRU form, it appears in two places: top right and bottom left. ASMAP-Service sells numbered six-page sets. The convention itself does not require a serial number, but customs processing is impossible without one, because in box 44 of the CD, the consignment note is declared under code 02015, accompanied by its number and date. If the consignment note is reissued on a new blank, the number of that new form must be transferred into the declaration.

How many CMR copies are required? Article 5 of the CMR Convention requires three original copies signed by the sender and the carrier. The first copy is retained by the sender, the second travels with the cargo, and the third is retained by the carrier. The 2007 IRU form is printed in four color-coded sheets, with the fourth intended for administrative authorities. The Belarusian instruction requires a form consisting of six or more sheets, of which at least three are surrendered to customs authorities.

Three originals are sufficient for the contracting parties, but administrative bodies also retain copies. Confirm with your carrier before loading how many copies will be collected along your route; we recommend using a six-sheet set.

When exporting to Kazakhstan and Belarus, there is no customs clearance, but the consignment note is still required

Carriage from Russia to Kazakhstan or Belarus remains international under the CMR Convention because loading and delivery occur in two separate countries, and all three states are contracting parties. The absence of customs borders within the EAEU does not alter this status. Who completes the CMR when exporting to Kazakhstan? The exporter, acting as the sender, fills in the sender's boxes and signs the consignment note together with the carrier, while the buyer signs box 24 upon receipt. When exporting to Belarus, the procedure is identical, and trips originating in Belarus are subject to the Belarusian instruction.

Export road transport within the EAEU is not among our published case studies, so we focus solely on statutory requirements. For exports, the consignment note must be preserved primarily for VAT purposes. To confirm the 0% VAT rate, the Protocol on Indirect Taxes to the EAEU Treaty mandates transport documentation proving the movement of goods between member states. Under clause 1.3 of Article 165 of the Tax Code of the Russian Federation, the consignment note does not have to be submitted alongside the tax return if you have submitted the register of import applications electronically. However, the tax authority may request it during an audit (with a 30-day response window), and without it, the 0% rate is deemed unverified.

The buyer in Kazakhstan or Belarus also requires the consignment note for their import statement. The original copy bearing the consignee's signature in box 24 must be returned to you. Cross-checking against the packing list is just as essential for exports as it is for imports: there is no border customs checkpoint, meaning any package shortage will first be discovered by the buyer during unloading.

Electronic consignment notes (e-CMR) are not yet viable on routes to Kazakhstan. While Russia and Belarus have acceded to the e-CMR protocol, Kazakhstan has not, according to the UN Treaty Collection. Furthermore, the Russian domestic electronic transport waybill cannot replace the CMR because, under the Charter of Motor Transport, international carriage is governed by international treaties.

What to do if a discrepancy is discovered during loading

First, recount the packages and check the markings against the packing list while the truck is still at the warehouse dock. If the carrier cannot verify the package count, they must enter a reasoned reservation in box 18. Such a reservation does not bind the sender unless the sender explicitly accepts it in writing on the document. However, it will be visible to everyone handling the consignment note further along the chain, including border customs officers.

Second, align the paperwork with the cargo. If an error lies in the packing list, it must be revised, and the updated figures must be entered into the consignment note. If there is a physical shortage of cargo—for instance, one pallet was not dispatched from the warehouse—record what was actually loaded in the consignment note; the party that issued the packing list must update it before departure, and the seller must update the commercial invoice. Because handwritten corrections are rarely entered consistently across all sheets, we prefer to rewrite the consignment note on a clean form.

The best practice is to detect discrepancies before loading begins. In a shipment of apparel from Guangzhou, the actual quantities did not match the factory invoices, and several items lacked labels. We suspended dispatch, counted every single position, and generated an accurate packing list, allowing the consignment to reach its destination in 26 days without inquiries or inspections.

We apply the same standard to consolidated shipments from multiple manufacturing plants. During cargo consolidation from three suppliers in Shenzhen, we verified package counts, packaging, and markings, while a pre-shipment document audit identified incomplete product descriptions and invoice errors. Had those inaccuracies traveled with the vehicle, they would have made their way into box 9 of the consignment note. Following such an audit, all that remains is to transfer verified figures into the CMR.

Checking the consignment note before the truck departs

Box numbers below correspond to the Russian-German form; on other layouts, locate the box by its title.

1. The consignment note was drawn up after final packaging, not based on preliminary supplier documents.
2. The package count (box 7), markings (box 6), and method of packing (box 8) match what was physically loaded and correspond to the packing list.
3. The gross weight (box 11) is taken from the packing list, including pallets and packaging, and if the goods were reweighed, the packing list was updated accordingly.
4. The volume (box 12) is calculated inclusive of outer transport cartons.
5. The code (box 10) matches the customs declaration and contains at least six digits.
6. Descriptions (box 9) match the commercial invoice, with a dedicated line for each code.
7. The Incoterms rule in the payment conditions (box 15) matches the invoice.
8. Sufficient copies are provided for the parties and transit customs authorities, and the serial number of this exact form will be referenced in the declaration.
9. When exporting to the EAEU, you have confirmed arrangements with the buyer for returning the copy endorsed in box 24.

When all nine points align, the consignment note will convey the exact same data to customs as the packing list and declaration. If you are shipping consolidated cargo by truck from China, TransGID will prepare the consignment note based on the post-consolidation packing list and calculate an optimal rate for road freight from China tailored to your lot.