Cargo Insurance for a Specific Load: What to Ask the Insurer

Liability and insurance are two different questions

Under the Carmack Amendment, 49 U.S.C. 14706, a motor carrier that receives property must issue a receipt or bill of lading, and the receiving and delivering carriers are liable for the actual loss or injury to the property. A carrier may limit that liability to a value declared by the shipper in writing or agreed in writing, if the value is reasonable, and must give the shipper on request a copy of the rates, rules and practices the limit rests on. A carrier may not set less than nine months to file a claim or less than two years to sue, counted from its written disallowance.

Cargo insurance is how a carrier funds that liability, not the liability itself. A policy limit below the load value, a deductible or an excluded commodity leaves the carrier owing the difference from its own resources. Ask the coverage question and the contract question separately: what the carrier is liable for under the bill of lading and your agreement, and how much of that its insurer will pay.

Claims follow their own rules. Under 49 CFR 370.3, a claim must be in writing, identify the shipment, assert liability and ask for a specified or determinable amount; an exception noted on a delivery receipt is not a claim on its own.

Sources: 49 U.S.C. 14706: liability of carriers under receipts and bills of lading (Carmack Amendment); 49 CFR 370.3: filing of loss and damage claims

Federal filings answer a different question

The insurance filings on a carrier’s FMCSA record are mostly public-liability filings. The required minimum for a property carrier operating vehicles of 10,001 pounds or more with non-hazardous freight is $750,000, rising for listed hazardous materials. That security pays judgments for bodily injury, property damage and environmental restoration owed to the public.

The MCS-90 endorsement states that the public-liability insurance it certifies does not apply to property transported by the insured, designated as cargo. A healthy BIPD filing therefore says nothing about cargo. A BMC-34 cargo filing exists only for household-goods operations, so its absence from an ordinary carrier’s record is expected and is not evidence that the carrier lacks a cargo policy. The form codes are explained in the guide to BMC insurance filing forms.

Sources: 49 CFR 387.303T: minimum levels of financial responsibility, including household-goods cargo; 49 CFR 387.301T: public liability and household-goods cargo security filings; FMCSA: Form MCS-90 endorsement for public liability

Describe the load before asking about coverage

An insurer cannot confirm coverage for “general freight” in the abstract. A recommended starting packet for the agent or insurer, assembled from your own load record:

• The commodity as it will appear on the bill of lading, not a category.
• The invoice or declared value, and any liability limit agreed in writing with the shipper.
• Equipment and handling: trailer type, temperature setting and any monitoring requirement for refrigerated freight.
• Origin, destination, planned stops and whether the load will sit overnight or over a weekend.
• The legal name, USDOT number and docket of the carrier on your rate confirmation, and whether it will haul with its own power or a leased owner-operator.
• Pickup and delivery dates.

Questions for the insurer or authorized agent

These are questions to put to someone who can read the policy, reached through contact details you established yourself. The steps for finding and confirming that contact are in the guide to verifying a carrier’s insurance. They are not a description of what any particular policy contains.

• Is the named insured the same legal entity, USDOT number and docket as the carrier on the rate confirmation?
• Is this commodity covered, excluded or subject to a lower sublimit?
• What limit applies to one load or one vehicle, what is the deductible, and does the declared value fit inside it?
• Does coverage depend on the vehicle or driver being listed on the policy, and is the unit assigned to this load listed?
• For refrigerated freight, what conditions apply to a refrigeration breakdown?
• Do any conditions apply to theft from an unattended or parked vehicle?
• Is the policy in force on the pickup and delivery dates, and has a cancellation notice been issued?

A certificate is not the answer

ACORD, which publishes the standard certificate forms, says a certificate of insurance is not an insurance policy and does not provide, amend, extend or alter the terms of one; only an endorsement or amendment to the policy changes coverage. A certificate listing a cargo limit tells you a policy existed when it was issued. It does not tell you whether this commodity is excluded or whether the policy is still in force.

Get the answers to the questions above in writing from the insurer or agent, not relayed by the carrier. If a cancellation filing appears on the federal record after you approve, read it as a dated event against the filing it cancels before deciding anything about the next load.

Sources: ACORD: Certificates of insurance, frequently asked questions; 49 CFR 387.313: insurance filings and cancellation notice

Record the coverage decision for this load

An illustrative note: “Cargo: frozen poultry, declared value $180,000, reefer set to minus 10°F. Agent at [agency], reached through the insurer’s published directory, confirmed in writing on 2026-10-04: named insured matches USDOT and docket; commodity not excluded; $250,000 per-vehicle limit, $2,500 deductible; refrigeration breakdown covered with a temperature-recorder condition. Unresolved: none.”

A different commodity, a higher value or a new route can change every answer, even when the carrier’s public record has not changed. Store the confirmation with the shipment assumptions it was based on in the carrier review log, so the next booking can tell whether the earlier answer still applies.