The.New.York.Tiraes.November^I.IOSQ.
MERCHANTS ISSUE
NEUTRALITY DATA
Interpret Act as It Applies to
Ordinary Shipments to
Belligerents
TITLE TRANSFER DEFINED
Straight, Bill of Lading Fills
Legal Requirements,
Bulletin Asserts
In an effort to clear up confusion
concerning the requirements of the
Neutrality Act with reference to
ordinary commercial shipments by
exporters to belligerent - nations,
the Merchants Association yester-
day Issued a bulletin defining Its
understanding of the measure/ The
statement, officials of the group
said, "was prepared after- care^
'fur consultation, with authoritative
[sources."
After reviewing general provisions
of the act and its requirements that
title must be transferred to the
buyer before goods are shipped to
a belligerent country, the bulletin
added that a declaration of transfer
of title is required for the follow-
ing shipments:
1. All shipments on any vessel to
European    belligerent countries
(Great-; Britain j France and Ger-
many) and to all French and Brit-
ish colonies and territories on the
Mediterranean.
2. Ocean   shipments  on United
States and neutral vessels to New^l
foundtand and to Canadian ports
east of 66 degrees west longitude
(includes Halifax).
Zi Shipments on belligerent ves-
sels to any belligerent territory, In-
cluding all parts of tho British Em-
pire Australia, New Zealand. South
Africa, Hong Kong, etc., and to all
French colonies. (Title need not be
transferred if shipped on a United
States or neutral vessel to belliger-
ent countries other than those speci-
fied In 1 above.)
4. All shipments of arms, ammu-
nition and implements of war to
any belligerent territory.
W^th regard to what constitutes
a transfer of title within the mean-
ing/of the act the bulletin said:
"The issuance of a consignee's
straight bill of lading, regardless of
the method of payment, Is recog-
nized as constituting definite trans-
fer of title as required by the act.
Such bill of lading must -be con-
signed to a foreign Individual, part-
nership or corporation. The fact
that the foreign corporation may
be a subsidiary of the American
shipper does not affect such trans-
fer.
"Shipments under a 'To Order'
bill of lading do not constitute
transfer of title. No transfer of
title occurs in the oase of ship-,
menls to branches or affiliates of
American companies unless such
branches are foreign corporations.
"No ruling is yet available as to
whether or not this declaration is
to be required for freight shipments
less than $25 value, mall, parcel
post shipments or air express ship-
ments, for which shippers' export
declarations are not required. The
act specifically oxompu rail and
Inland waterway shipments to Can-
ada.
"At the time of making oath there
must be no American lien or claim
on the articles exported."
f^u fJV  1*2- ^