Is ICC Opinion R198 Valid Under UCP600?

[shahriar]

dear all,

ICC opinion R198 stipulates

b) The letter of credit requires a certificate of quality and quantity: no detailed description of quality and quantity is specifically required. The certificate presented, without describing the goods and its quantity in detail, certifies that the quality and the quantity of the shipment strictly conform to the invoice giving the correct invoice number. The invoice shows the quantity as well as the shipped goods, which itself indicates the quality.


analysis
A certificate of quality and quantity is a document that is covered by UCP 400 Article 23. Failing specific requirements in a credit, such a document will be accepted as presented, provided that its data content makes it possible to relate the goods referred to therein to those referred to in the commercial invoice presented.

is this analysis valid under ucp 600?

regd

shahriar

[ofei]

UCP600 Art 14 d. Data in a document, when read in context with the credit, the document itself and international standard banking practice, need not be identical to, but must not conflict with, data in that document, any other stipulated document or the credit.
f. If a credit requires presentation of a document other than a transport document,insurance document or commercial invoice, without stipulating by whom the document is to be issued or its data content, banks will accept the document as presented if its content appears to fulfil the function of the required document and otherwise complies with sub-article 14 (d).
From the above stipulations, I think the opinion of R198 is still applicable under UCP600.
Provided the function of certificate of quality or quantity has been satisfied, the document will be accepted. And also the function of such document is not description of goods but the quality or quantity. So it can refers to the wording---as per invoice No. XXX.