Paper CMR waybills get lost, get soggy in the rain, and sit around for weeks waiting to be returned to headquarters—and without them, you can’t issue an invoice. We explain how to legally sign an electronic CMR consignment note (e-CMR), what the EU’s eFTI regulation actually changes, and what role qualified signatures and qualified seals play in the digital flow of TSL documents.
CMR This is an international bill of lading issued on the basis of Convention on the Contract for the International Carriage of Goods by Road (CMR) dated 1956 — a document confirming the conclusion of a contract of carriage, the acceptance of the goods, and their delivery to the consignee. e-CMR is its electronic counterpart, introduced the Additional Protocol to the CMR Convention, drawn up in Geneva February 20, 2008. The protocol ensures that an electronic waybill that meets its requirements has the same evidentiary value and the same legal effect a paper CMR.
In Poland, the protocol has been in effect since September 11, 2019. (Journal of Laws 2019, Item 1487). It is already a party to nearly 40 countries — including the most important transport partners of Polish carriers: Germany (starting in 2022), France, the Netherlands, Spain, the Czech Republic, and Lithuania. In trade between these countries, the electronic bill of lading may be used today, legally and voluntarily.
What are the benefits for a transportation company or freight forwarder?
📌 Don't confuse e-CMR with the system SENT (a record of shipments of so-called sensitive goods, such as fuels) nor with e-TOLL (toll collection). These are separate systems with different purposes—e-CMR pertains specifically to shipping document and contracts of carriage.
Article 3 of the Additional Protocol provides that the e-CMR authenticates the parties to the contract of carriage by means of a valid electronic signature — that is, one that is unambiguously linked to the signer and created using means under the signer’s exclusive control. Another electronic method is also acceptable if permitted by the law of the country issuing the document.
In practice, the process works as follows:
Why should you choose QES, given that the protocol only refers to a „reliable” signature? Because, according to the regulation, eIDAS (EU 910/2014) A qualified electronic signature is legal effect equivalent to a handwritten signature (Article 25(2)), and a QES issued in one EU country is recognized in all other countries (Article 25(3)). When the sender is in Poland, the carrier is in Lithuania, and the recipient is in Germany—it is precisely cross-border recognition that determines the probative value of the document in the event of a dispute. More: eIDAS: Digital Trust in the European Union.
💡 A signature created with a stylus on the app’s screen may be sufficient for operational purposes, but its evidentiary value depends on the security measures of the specific platform. A QES and a qualified seal reverse the burden of proof: the party challenging the document must demonstrate that it is invalid. We explain how to verify the validity of an e-signature in our guide: How do you verify an electronic signature?
eFTI (Electronic Freight Transport Information) this regulation EU 2020/1056 regarding electronic freight transport information. Its meaning is sometimes misunderstood, so let's clarify: eFTI does not require companies to paper waste. It imposes an obligation on administrative bodies — regulatory agencies in all EU countries will have to accept shipping information provided electronically through certified eFTI platforms. For carriers, digitization remains a right, not an obligation—but a right that will be respected during every roadside inspection in the EU.
The schedule (following delays from the original plans) currently looks like this:
| Date | What's going on? |
|---|---|
| 20.02.2008 | Signing of the e-CMR Protocol to the CMR Convention (Geneva) |
| 11.09.2019 | The e-CMR Protocol enters into force for Poland |
| 21.08.2024 | Implementation of Key Provisions of the eFTI Regulation |
| 9.01.2025 | Entry into force of the EC’s package of implementing acts (technical requirements for platforms) |
| 2026 | Preparation phase: eFTI platform certification, testing, system integration; authorities may already accept electronic data |
| 9.07.2027 | According to the current schedule: supervisory authorities in all EU countries must accept electronic information from certified eFTI platforms |
The year 2026 is therefore the time when platform providers undergo certification, and TSL companies integrate systems and streamline processes—including electronic signature and seal tools, without which a digital document lacks a reliable „anchor” to a specific person or company.
In Poland, legislative work is currently underway on amendments to the Road Transport Act and the Carriage of Goods Act, which are intended to explicitly establish the use of electronic waybills in roadside inspections (responsibility for implementation lies with, among others,. GITD — General Inspectorate of Road Transport). Until these regulations are enacted, it is advisable to exercise caution when traveling domestically—as discussed below.
An electronic signature in the transportation industry isn’t limited to the waybill alone. Every day, TSL employees sign documents for which the electronic format using QES is the fastest and most secure option:
For mobile workers—and that’s the nature of the industry—the best solution is cloud signature SimplySign: Can be set up from a phone or laptop, without a card or card reader, from anywhere. Comparison of options: The SimplySign mobile signature or the Certum Mini signature with a reader?
The electronic signature belongs to people. What about the documents it generates? system — hundreds of delivery confirmations, copies of waybills, and invoices every day? That's where qualified seal (QSeal) — the electronic equivalent of a company seal, issued in the name of companies (name, NIP), not people.
Pursuant to Article 35 of Regulation eIDAS, a qualified seal is subject to presumptions of data integrity and authenticity of origin. A sealed document thus provides verifiable proof that „this file originated from this company and no one altered it along the way”—the foundation of trust between the sender, the carrier, the recipient, and, ultimately, the regulatory authority.
| Tool | Who/What is this about? | Typical Applications in the Transportation, Logistics, and Services Sector |
|---|---|---|
| Qualified Signature (QES) | Individual (first and last name) | Contracts, work orders, e-CMR, posting documents, quotes |
| Qualified Electronic Seal (QSeal) | Entity (company, NIP) | Automatic archiving of ePODs, e-CMR copies, invoices, and reports generated by TMS/ERP systems |
| Qualified timestamp | Document (point in time) | Proof of the time of release of goods, delivery, or filing of objections |
The stamp works without human intervention — It integrates with a TMS or ERP via an API, so that every ePOD or copy of a shipping document is automatically stamped upon generation. podpisano.pl’s offering includes a cloud-based SimplySign qualified seal (for API integration, starting at 1,289 PLN) and Certum Mini qualified seal with a card reader (starting at 1,399 PLN, 5,000 time stamps per month).
The three trust services—signature, seal, and timestamp—work best together: an individual makes a declaration of intent, a company guarantees the document’s origin, and the timestamp records the moment the event occurred. We describe how they work together in the following articles: Signature, Seal, and Timestamp—How Do Digital Trust Services Work? and Electronic timestamp — what is it and how does it work? Differences between an electronic seal and a traditional „rubber” seal: Traditional Seal vs. Electronic Seal.
Domestic transportation is governed by the Act Transport Law. Pursuant to Article 47(3) thereof, proof of the conclusion of a contract of carriage is a consignment note confirmed by the carrier, which may also be electronic transmission, a computer printout, or another document containing the information listed in Article 38. Formally, therefore, the electronic format of the national waybill has been permissible for a long time.
In practice, the situation is more challenging: for years, regulations governing roadside inspections have required the presentation of paper documents, and the amendment—which is intended to explicitly put the national „e-transport” system on an equal footing with paper documents for inspection purposes as well—is still undergoing the legislative process. Until then, a sensible strategy for TSL looks like this:
We provide a step-by-step guide on how a company can have a seal made—including what documents to prepare and how long the process takes—in our guide: Documents to make a qualified electronic seal.
The digital waybill is no longer just a novelty—the e-CMR has been legally valid in Poland since 2019, and thanks to eFTI, at the latest since July 9, 2027. Electronic transport data will be accepted by regulatory authorities throughout the EU. 2026 is the best time to prepare both people and systems.
As authorized partner Certum We help transportation and freight forwarding companies select and implement trust services: mobile qualified digital signatures for management, freight forwarders, and drivers, as well as a qualified digital seal for integration with TMS/ERP systems.
📞 Call us: +48 22 417 05 55 or write to us at: [email protected] — Advisors are available at their offices in Warsaw, Krakow, Wrocław, and Radom, as well as online or at a location of your choice.
Related products:
The e-CMR is issued and signed on the e-CMR platform: the shipper authenticates the document with an electronic signature, the driver confirms receipt of the goods in the mobile app, and the recipient acknowledges delivery (ePOD). The Protocol to the CMR Convention requires a „reliable electronic signature”—these requirements are most certainly met by a qualified electronic signature (QES), which is recognized throughout the EU.
Yes. The Additional Protocol to the CMR Convention has been in force in Poland since September 11, 2019 (Journal of Laws 2019, item 1487). The e-CMR has the same evidentiary value as a paper CMR consignment note and may be used for shipments between countries that have adopted the protocol—and there are already nearly 40 of them.
The regulations do not require companies to use the e-CMR—the digital consignment note remains voluntary. However, the role of regulatory authorities is changing: according to the timeline set out in the eFTI Regulation (EU 2020/1056), as of July 9, 2027, enforcement authorities in all EU countries will be required to accept electronic transport information provided by certified eFTI platforms.
No—they are complementary tools. A qualified digital signature identifies a person and expresses their declaration of intent (e.g., acceptance of goods), while a qualified digital seal confirms that the document originates from a specific company and has not been altered (presumption under Article 35 of eIDAS). A seal works very well for automatically securing documents generated in bulk from TMS/ERP systems.
Transport law (Article 47(3)) permits the use of an electronic waybill. In the practice of roadside inspections, paper documents still play a significant role, and an amendment explicitly establishing the national „e-waybill” is currently undergoing the legislative process—until it enters into force, it is advisable to maintain a cautious approach.
e-CMR is an electronic consignment note (contract of carriage and delivery confirmation). SENT is a mandatory system for monitoring the transport of sensitive goods (e.g., fuels, alcohol), while e-TOLL is a toll collection system. The digitization of the waybill does not exempt a carrier from SENT or e-TOLL obligations, and vice versa.
