Under FCA Incoterms 2020, the seller delivers the goods, cleared for export, to the carrier the buyer nominates at a named place, and risk and cost pass to the buyer at that handover. Free Carrier works for any mode of transport, including a container booked door to door, which is why the ICC points container shippers to FCA rather than to the sea-only rules. For a US importer, FCA means the buyer controls the main freight booking, files the US entry as importer of record and pays the duty, while the foreign seller handles export formalities in its own country.
This guide covers the seller and buyer obligations under Free Carrier, the two delivery points the rule allows, the optional on-board bill of lading added in 2020, and what FCA means for a US entry: whose bond, who files the Importer Security Filing, and how the FCA price becomes a US customs value. For all 11 rules side by side, see the Incoterms chart.
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Seller and Buyer Obligations Under FCA
The FCA seller provides conforming goods and a commercial invoice, packs and marks them for transport, delivers them to the buyer’s carrier at the named place and clears them for export. The buyer pays the price, nominates the carrier, contracts and pays for carriage from the named place, and carries out every transit and import formality. Neither party owes the other an insurance contract under FCA; each insures its own risk if it wants cover.
Every Incoterms 2020 rule splits these duties into ten seller articles (A1 to A10) and ten mirror buyer articles (B1 to B10), from general obligations through delivery, risk, carriage, insurance, transport documents, clearance, packaging, costs and notices. The table below maps the FCA articles onto what each party actually does on a shipment into the United States.
| Obligation | Foreign seller | US buyer |
|---|---|---|
| Delivery | Hands goods to the buyer's nominated carrier at the named place | Takes delivery at the named place |
| Loading at origin | Loads if the named place is the seller's premises | Unloads from the seller's vehicle if delivery is at another place |
| Main carriage | None, unless agreed to contract it at the buyer's risk and cost | Contracts and pays for carriage from the named place |
| Insurance | No obligation; gives information on request | No obligation; insures its own risk if it chooses |
| Export clearance | Carries out and pays for export formalities | Assists at the seller's request and cost |
| US entry and duty | Assists with documents at the buyer's request and cost | Files entry as importer of record, posts the bond, pays duty and fees |
| Transport document | Gives usual proof of delivery; passes on any on-board bill of lading | Accepts proof of delivery; instructs carrier if the on-board option was agreed |
| Notices | Notifies delivery or the carrier's failure to collect | Notifies carrier name, time, mode and point of receipt |
Delivery at the Seller's Premises or at Another Named Place
FCA has two delivery points, and the named place decides which one applies. If the named place is the seller’s premises, delivery happens when the goods are loaded on the means of transport the buyer arranged, so the seller owns the loading operation and its risk. If the named place is anywhere else, such as a container freight station, an airport cargo terminal or a forwarder’s warehouse, delivery happens when the goods arrive there on the seller’s vehicle, ready for unloading and at the disposal of the buyer’s carrier. In that second case the buyer, through its carrier, bears the risk of unloading.
The ICC text tells both parties to name a precise point inside the named place, not just a city. If the contract says only “FCA Shenzhen” and several points are available, the seller may choose the point that best suits its purpose, and risk transfers there. A buyer who wants control writes “FCA Yantian CFS, Warehouse 3, Shenzhen” or the seller’s full factory address.
Incoterms 2020 also confirmed that the buyer may collect with its own vehicle instead of hiring a third-party carrier. The rule’s notice duties make the handover work: the buyer must tell the seller the carrier’s name, the collection time, the mode of transport and the receiving point in time for the seller to deliver. If the buyer’s carrier fails to show, risk passes to the buyer from the agreed date anyway, provided the goods are clearly identified as the contract goods.
The 2020 On-Board Bill of Lading Option
Incoterms 2020 added an optional mechanism to FCA: if the sale contract says so, the buyer must instruct its carrier to issue the seller, at the buyer’s cost and risk, a transport document stating the goods have been loaded, such as a bill of lading with an on-board notation. The seller then passes that document to the buyer, usually through the banks. The option exists because sellers paid under a letter of credit often need an on-board bill of lading to get paid, yet under FCA they deliver before the goods ever reach a vessel.
The ICC’s own example is an FCA Las Vegas sale: the buyer’s trucker collects in Las Vegas, and the on-board bill of lading can only be issued once the container is loaded in Los Angeles. Three limits apply. The carrier is not bound by the sale contract and may decline to issue the document. The seller has no obligation to the buyer about the terms of the carriage contract. And the inland delivery date and the on-board date will differ, which can create discrepancies under a letter of credit that names a single shipment date.
For a US importer paying by letter of credit, the practical step is to align three documents before booking: the sale contract clause invoking the option, the letter of credit’s document requirements, and the booking instruction to the ocean carrier or NVOCC. If the seller accepts a received-for-shipment bill of lading instead, the option is unnecessary.
Where Risk and Cost Pass Under Free Carrier
Under FCA, risk and cost pass at the same moment: delivery at the named place. From that point the buyer bears loss or damage in transit, pays all freight and destination costs, and pays every transit and import duty, tax and formality. The seller pays everything up to delivery, plus export clearance and the cost of proving delivery. That single transfer point is what separates FCA from the C rules, where the seller pays freight to destination but the buyer already holds the risk from origin.
Because risk moves at origin, the US buyer is the party that needs marine or cargo insurance from the named place onward. A buyer that assumes the seller’s export packing or the carrier’s limited liability will cover a loss is self-insuring without knowing it.
Buyers often ask whether FCA is the same as FOB. It is not. FOB is a sea-only rule that delivers when goods are on board the vessel; FCA delivers earlier, at the carrier’s handover, and works for any mode. When a container is handed to the line at an inland terminal days before loading, FOB leaves the seller carrying risk for cargo it no longer controls, which is why the ICC recommends FCA for containerized freight. The full FOB analysis sits in our guide to FAS and FOB.
FCA for US Imports: Entry, Bond, ISF and Customs Value
Under FCA the US buyer is the importer of record, because the seller has no import obligation. Under 19 U.S.C. 1484(a)(2)(B), entry is filed by the owner or purchaser of the goods or by a licensed customs broker it designates, and the importer of record carries the legal liability for classification, value and duty. Release of a formal entry requires a single-transaction or continuous bond on CBP Form 301 under 19 CFR 142.4, so the buyer needs its own customs bond before the goods arrive.
For ocean cargo, the Importer Security Filing falls naturally on the FCA buyer because it books the vessel. 19 CFR 149.1 defines the ISF importer as the party causing the goods to arrive, meaning the owner, purchaser, consignee or its agent, and 19 CFR 149.2 requires the core data elements no later than 24 hours before the cargo is laden at the foreign port. The FCA seller still has to supply the manufacturer, stuffing location and commodity data in time; our ISF filing guide lists every element.
The customs value starts from the FCA price. Under 19 U.S.C. 1401a(b)(4)(A), the price actually paid or payable excludes transportation, insurance and related services incident to the international shipment, and under FCA the buyer pays that freight outside the invoice. Two cases differ on foreign inland freight. FCA at the seller’s premises is an ex-factory price, and 19 CFR 152.103(a)(5)(i) says inland freight not included in the price is not added. FCA at a port or terminal includes the seller’s trucking to that point, and 19 CFR 152.103(a)(5)(ii) keeps that charge in transaction value unless it is identified separately and incurred after the goods were sold for export to the US and placed with a carrier for through shipment, proven by a through bill of lading or, where a through bill is clearly impossible, such as delivery on the seller’s own truck, by other documentation the Center director accepts. Without that evidence, the inland leg stays dutiable.
Statutory additions apply whatever the Incoterm: packing, selling commissions, assists, royalties and resale proceeds under 19 U.S.C. 1401a(b)(1). Our customs valuation guide covers the full hierarchy. A licensed customs brokerage that sees the sale contract before the first FCA shipment can set the named place, the bond and the invoice layout so the entry value is defensible from the start.
Frequently Asked Questions
Is FCA the same as FOB?
No. FCA delivers when the goods are handed to the buyer’s nominated carrier at a named place and works for any mode of transport, while FOB delivers only when the goods are on board a vessel and applies to sea and inland waterway transport. For containers handed to a carrier at a terminal before loading, the ICC recommends FCA.
Who pays for shipping under FCA?
The buyer pays the main carriage. The seller pays costs up to delivery at the named place, including export clearance and, when delivery is at the seller’s premises, loading onto the buyer’s vehicle. Freight from the named place, insurance if wanted, US duties, fees and destination charges are the buyer’s.
Is FCA the same as DAP or DDP?
No. FCA is an origin rule where risk passes when the seller hands the goods to the buyer’s carrier; DAP and DDP are destination rules where the seller carries cost and risk to the named place in the buyer’s country. Under DDP the seller also clears the goods for US import and pays the duty, as compared in our DAP vs DDP guide.
Who is the importer of record under FCA Incoterms?
The US buyer. FCA gives the seller no import obligation, so the buyer, or a licensed broker it designates, files the entry under 19 U.S.C. 1484, posts the customs bond and pays duty and fees.
What is the on-board bill of lading option in FCA?
It is an optional clause added in Incoterms 2020: if agreed in the contract, the buyer must instruct its carrier to issue the seller a bill of lading with an on-board notation at the buyer’s cost and risk. The seller then passes it to the buyer, usually to satisfy a letter of credit. The carrier is not obliged to issue it.
Does the buyer's freight count in the US customs value under FCA?
No. International freight and insurance paid by the buyer are excluded from the price actually paid or payable under 19 U.S.C. 1401a(b)(4)(A). Foreign inland freight already inside an FCA port price is dutiable unless identified separately and supported by a through bill of lading under 19 CFR 152.103(a)(5).
Who unloads the goods under FCA?
It depends on the named place. At the seller’s premises the seller loads onto the buyer’s vehicle and the buyer handles everything after. At any other place the seller delivers on its own vehicle ready for unloading, so unloading at that place is the buyer’s cost and risk.
