The Legal Status of IoT Data in NCD Convention “In-Transit Transfer” and the Boundaries of Liability

The United Nations Convention on Negotiable Cargo Documents (NCD Convention), adopted in 2025, creates a legal framework for negotiable cargo documents across transport modes. Although the Convention does not require Internet of Things (IoT) data, real-time cargo verification may become commercially important in some non-maritime NCD transactions, particularly those involving high-value or condition-sensitive goods. This article uses doctrinal and comparative research together with limited Chinese practice. It argues that, after an eNCD has been issued and especially after it has been transferred, changing IoT readings should ordinarily remain outside the document. The eNCD may identify the external data source, while the current holder uses the external data to assess the goods and, where appropriate, to exercise rights under the NCD and the transport contract. The article therefore distinguishes liability arising from the carriage of the goods, information contained in the NCD, the holder’s exercise of rights, and failures in the IoT service. It concludes by considering implications for Chinese law, electronic evidence, cybersecurity, and cross-border data governance.