CMR consignment note for car transport: dealer guide
CMR consignment note for car transport: required contents, who signs, its role as VAT proof of intra-EU transport and how it limits carrier liability.
· 8 min read
A CMR consignment note is the standard transport document for paid road haulage between two countries, governed by the 1956 CMR Convention. For car dealers it does three jobs: it proves the contract of carriage and the condition of each car at pick-up, it records damage at delivery, and a signed copy is one of the documents that support the VAT exemption for an intra-EU sale.
What is a CMR consignment note?
A CMR consignment note is the document that records a contract for the international carriage of goods by road under the Convention on the Contract for the International Carriage of Goods by Road (CMR). The Convention applies to every contract for carriage by road in vehicles for reward when the place of taking over and the place of delivery are in two different countries, at least one of which is a contracting state. All EU countries, the UK, Norway, Switzerland and Ukraine are among the contracting states.
When a carrier moves your cars from Germany to Poland or from Belgium to Italy for a fee, the CMR rules apply automatically, even if nobody fills in the note. The note itself is evidence: under Article 9 it is prima facie evidence of the contract, its conditions and the carrier's receipt of the goods.
What must a CMR note contain?
Article 6 of the Convention lists the particulars every consignment note must contain. The ones that matter most for cars:
| Field | What to enter for cars |
|---|---|
| Date and place the note is made out | Pick-up date and location |
| Sender | The seller or the party handing over the cars |
| Carrier | The transport company actually performing the carriage |
| Place and date of taking over, place of delivery | Exact addresses, not just cities |
| Consignee | The buying dealer |
| Description of the goods | Make, model and, crucially, the VIN of each car |
| Number of packages / quantity | Number of cars |
| Gross weight | Approximate weight of each car or the load |
| Charges and instructions | Who pays, customs instructions where relevant |
The VIN is the single most important entry. Without it, the note cannot link a specific car to the transport, which weakens both a damage claim and your VAT proof. Add mileage and a short condition note or reference to an attached inspection sheet with photos.
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Request accessWho fills in and signs the CMR when cars are transported?
The sender and the carrier fill in and sign the note; the consignee signs on delivery. Under Article 5, the note is made out in three originals signed by the sender and the carrier:
- The first copy goes to the sender.
- The second copy travels with the goods and is handed to the consignee.
- The third copy stays with the carrier.
In practice the carrier often prepares the note and the seller's yard staff sign it at loading. Make sure the person signing for the seller actually checks the cars.
The carrier's check at pick-up
Article 8 requires the carrier, on taking over, to check the apparent condition of the goods. If the carrier has reservations, such as scratches, dents or a cracked windscreen, they must be entered on the note with reasons. If the note contains no reservations, Article 9(2) presumes the goods were in good condition when the carrier took them over.
That presumption is your friend. A clean CMR at pick-up, plus a damaged car at delivery, puts the burden on the carrier. A note with a vague "used vehicles, scratches" reservation does the opposite. Insist on specific remarks per car, and take your own photos.
Is a CMR enough proof of intra-EU transport for VAT?
On its own, no. A signed CMR is strong evidence, but EU rules ask for more than one document. Article 45a of Implementing Regulation (EU) No 282/2011 creates a presumption that goods were transported to another member state when the seller holds:
- If the seller arranges transport: at least two non-contradictory documents from list (a), issued by two different parties independent of seller and buyer, or one from list (a) plus one from list (b).
- If the buyer arranges transport: the same evidence, plus a written statement from the buyer confirming arrival, which the buyer must provide by the tenth day of the month following the supply. For vehicles, the statement must include the VIN.
| List | Accepted documents |
|---|---|
| (a) transport documents | Signed CMR document or note, bill of lading, airfreight invoice, invoice from the carrier |
| (b) other documents | Insurance policy for the transport or bank documents proving payment for it; official documents from a public authority, such as a notary, confirming arrival; a receipt from a warehouse keeper in the destination country |
So a signed CMR plus the carrier's invoice for the transport, from the same carrier, is weaker than it looks, because the rule asks for documents from two different independent parties. A signed CMR plus a bank statement showing payment for the transport, or a CMR plus an insurance certificate, fits the presumption better. National rules can accept other evidence too, such as the German Gelangensbestätigung. Tax authorities can rebut the presumption, so keep the file complete.
More on the VAT side in our guides to proof of intra-community delivery and the intra-community supply of cars.
How does the CMR limit the carrier liability?
The CMR makes the carrier liable for loss of or damage to the goods between taking over and delivery (Article 17), but caps compensation. Under Article 23(3), compensation may not exceed 8.33 units of account, the IMF's Special Drawing Rights (SDR), per kilogram of gross weight of the goods lost or damaged.
For a car weighing 1,500 kg, the cap is about 12,500 SDR, which at 2026 exchange rates is in the region of €14,000 to €15,000. For a total loss of a €40,000 car, the carrier's standard liability falls well short. For partial damage, Article 25 limits compensation to the reduction in the car's value, again within the cap.
There are three ways to protect more value:
- Declare a higher value on the note against a surcharge (Article 24).
- Declare a special interest in delivery against a surcharge (Article 26).
- Insure the cars yourself with cargo or goods-in-transit cover.
The cap does not apply if the damage was caused by the carrier's wilful misconduct or equivalent default (Article 29). Claims become time-barred after one year, or three years in the case of wilful misconduct (Article 32). For the claim procedure, see car transport damage claims.
Paper or electronic CMR
An Additional Protocol to the Convention, signed in 2008, allows electronic consignment notes (e-CMR) between states that have ratified it. Many carriers now use apps that capture signatures and photos at loading and delivery. That is convenient, but check two things: that the countries on the route accept e-CMR, and that you can download and archive a copy for your VAT file.
A practical CMR routine for dealers
- Prepare a car list with VIN, mileage and condition photos before the truck arrives.
- Check the CMR at loading: one line per car with VIN, correct addresses, no blanket reservations.
- Keep your copy and photograph the signed note.
- At delivery, inspect before signing and write any damage on the note.
- File the signed CMR with the invoice, payment proof and the buyer's arrival confirmation.
Transport is a cost line in every import, and the paperwork protects it. MyCarDealer includes transport in the margin calculation per car; dealers can request access.
Frequently asked questions
What is a CMR consignment note?
It is the transport document for international carriage of goods by road for reward under the 1956 CMR Convention. It is prima facie evidence of the contract of carriage, its conditions and the carrier's receipt of the goods.
Who fills in and signs the CMR when cars are transported?
The sender and the carrier sign the three originals at pick-up: one for the sender, one travels with the cars, one for the carrier. The consignee signs on delivery and should note any damage before signing.
Is a CMR enough proof of intra-EU transport for VAT?
Not on its own. Under Article 45a of Regulation 282/2011, the seller needs two non-contradictory documents from independent parties, for example a signed CMR plus a bank payment proof for the transport, and, if the buyer arranges transport, the buyer's written arrival statement with the VIN.
How does the CMR limit the carrier liability?
Compensation is capped at 8.33 SDR per kilogram of gross weight, about 12,500 SDR for a 1,500 kg car. You can raise protection by declaring a higher value or special interest against a surcharge, or by buying your own cargo insurance.
How long do I have to claim against a carrier under CMR?
The limitation period is one year, or three years for wilful misconduct. Visible damage must be noted at delivery and hidden damage reported in writing within seven days, excluding Sundays and public holidays.