Your Carrier Has a $100K Cargo Policy. It Won't Pay on This Load.

MC-1247893 had everything right on paper. Eighteen months of authority, three tractors, no open crashes on SAFER, a satisfactory rating that was current. The ACORD 25 on file showed $100,000 in cargo liability coverage from an admitted insurer. A load broker I know — someone who'd been doing this for eight years — tendered them a $78,000 shipment of consumer electronics headed to a regional distribution center. Laptops, tablets, charging accessories. A straightforward dry van move, five hours, easy freight.

The cargo claim was denied in full. The carrier's policy had an endorsement — buried in the schedule attached to the actual policy, not visible anywhere on the certificate — that excluded "electronic equipment and devices, including computers, peripherals, and consumer electronics, unless separately scheduled and rated." Nobody had separately scheduled anything. Nobody had asked.

The claim that ended up mattering wasn't against the carrier's insurer. It was against the broker, for failing to verify that the carrier's coverage actually applied to this load.

What the Federal Minimum Actually Requires

Most brokers have a vague sense that FMCSA sets a floor on cargo coverage, so a carrier that files a BMC-91 is "covered." That's not really what the rules say.

49 CFR Part 387 establishes minimum financial responsibility for motor carriers of property. The requirements are predominantly about public liability — the bodily injury and property damage coverage that protects third parties when a truck is in an accident. The one place cargo coverage minimums appear explicitly is 49 CFR § 387.303(b)(2), which applies specifically to household goods carriers: $5,000 per vehicle, $10,000 per occurrence. For general freight — dry van, flatbed, reefer — FMCSA doesn't mandate cargo insurance at all.

A dry van carrier can haul a $400,000 machine with zero cargo coverage, be in complete regulatory compliance, and have a clean BMC-91 filing showing nothing but their public liability policy. The filing tells you they have liability insurance for accidents. It tells you nothing about what happens to your freight.

This surprises brokers who've been doing it for years. The assumption is that because carriers file insurance forms with FMCSA, and because FMCSA regulates them, the system protects the cargo. It doesn't. That protection comes from the carrier's own cargo policy — a voluntary product the carrier buys, with terms, exclusions, and limits that vary enormously by insurer and endorsement schedule.

What the ACORD 25 Tells You

The certificate of insurance shows four things worth knowing:

The insurer's name — and whether that carrier appears in FMCSA's Licensing & Insurance database with an active filing for that company. If the certificate says one insurer and L&I shows another, you have a problem.

The policy period. You want dates that are current. You also want to know whether there was a lapse before this renewal. A carrier who let coverage lapse and reinstated it three weeks later has a gap in their history. FMCSA's L&I system shows that history if you know where to look.

The coverage types and limits as written on the declarations page. "Cargo: $100,000" or "Motor Truck Cargo: $250,000 per occurrence."

Whether your organization is listed as a certificate holder — which gives you the right to be notified if the policy cancels, but does not make you an additional insured and does not give you any claim rights under the policy.

What the ACORD 25 does not show you: commodity exclusions, per-occurrence sub-limits that trigger on specific load types, deductibles, "unattended vehicle" theft exclusions, refrigeration breakdown carve-outs, or whether coverage applies in all states or only where the insurer is admitted. All of that lives in the endorsement schedule — the pages that attach to and modify the base policy. Those pages are not part of the certificate.

The Six Places Coverage Disappears

I've seen cargo claims fail in predictable ways. They cluster around the same handful of policy exclusions.

Electronics and high-value technology. This is the most common one. Policies that list it broadly as an exclusion unless "separately scheduled and rated" are everywhere. If you're handling consumer electronics, medical devices, computers, anything with a chip — get the carrier to confirm in writing that electronics are not excluded from their policy, or get a specific endorsement showing they're covered at the stated limit. "My agent says it's fine" isn't documentation.

Unattended vehicle theft. A lot of cargo policies exclude theft if the truck is left unattended with freight on board. "Unattended" is defined broadly — sometimes it means the driver stepped into a rest stop for twenty minutes. If you're booking high-value loads and the carrier plans to drop the trailer overnight at a yard, ask directly. A truck stop in Memphis with a locked trailer doesn't always count as "attended" under the policy language.

Refrigeration breakdown. Reefer policies often cover physical damage from an accident but exclude spoilage from equipment failure unless the carrier bought a specific reefer breakdown endorsement. A carrier hauling frozen food whose reefer unit fails at 3 AM, causing $60,000 in product loss, may have no cargo coverage at all if the breakdown endorsement isn't there.

Deductible shock. Cargo policies with $10,000 or $25,000 deductibles are common, especially for newer authorities trying to keep premiums manageable. A $30,000 claim on a policy with a $25,000 deductible means you're recovering five thousand dollars through the carrier's insurer. The rest is a fight with the carrier directly or a Carmack claim in federal court. Ask about deductibles — they don't show up on the certificate.

Per-piece limits. Some cargo policies write limits per piece of freight rather than per occurrence. "Up to $1,000 per piece" on a pallet of 200 SKUs valued at $150 each works out to $30,000 — which sounds fine until the load is 400 pieces of smaller items where the per-piece limit is actually the binding constraint, not the per-occurrence headline number.

FAK exclusions on specialty goods. Carriers who haul freight-all-kinds have policies written for that. Some of them have broad exclusions for specialty categories — pharmaceuticals, alcoholic beverages, tobacco, jewelry, fine art — that can catch an operator off guard on a load they don't think of as specialty. A pallet of supplement products heading to a gym distributor can trigger a pharma exclusion.

What to Do About It

Collecting the certificate is step one. It confirms the carrier has a policy in force, who the insurer is, and what the face limits are. That's genuinely useful and you should have it for every load.

Step two is knowing whether that policy actually covers this load.

For high-value loads — anything above $50,000, anything with commodities that commonly appear in exclusion schedules — I ask the carrier to confirm in writing that their policy covers the commodity. Not "my insurance will handle it." Specific: "Does your motor truck cargo policy exclude electronics? Yes or no." If they have to call their agent to find out, that's the answer.

For refrigerated loads, ask specifically whether they have a reefer breakdown endorsement. Ask the same question for unattended vehicle theft if the move involves an overnight stop or dropped trailer.

If you're moving very high-value loads regularly — $200,000+ equipment, medical devices, electronics in volume — get comfortable with shipper's interest cargo coverage. It's insurance the shipper or broker purchases directly for the specific load, independent of the carrier's policy. It costs something. It covers what the carrier's policy doesn't. And it means you don't end up arguing policy exclusions with a skeptical adjuster after a $180,000 loss.

One more thing: check the FMCSA L&I database yourself. The certificate shows what the carrier told the insurer to put on the declarations page. The L&I database shows what filing is actually active with FMCSA. When they don't match — different insurer, different effective date, coverage type that doesn't align — that's a question you need answered before dispatch.

How I Document This

In the screening record for every load, I note the cargo limit from the ACORD 25, the policy effective dates, and the date I verified the L&I filing. For any load over $50,000, or any load involving electronics, refrigeration, or pharmaceuticals, I add a note confirming I asked the carrier about commodity exclusions — who I asked, what they said, and when. If they sent me something in writing from their agent, that goes in the file.

Since we added COI collection via Text-to-Screen on DOTScreener — you can reply "COI" after screening a carrier and it sends the carrier a login-free upload link so the certificate comes directly to your dashboard — the collection piece is easier. But I still treat what comes in as a starting point, not an answer. The certificate tells me the policy exists. My follow-up questions tell me whether it pays.

That paper trail is what makes the difference. Not because it prevents accidents, but because when a load goes sideways and someone starts asking questions, you have documented answers. "We collected the certificate, verified the L&I filing, and confirmed with dispatch that their cargo coverage included electronics" is a different conversation than "we got a certificate."

The gap between those two conversations is where lawsuits live.

— Mason Lavallet

Founder, DOTScreener.com