The Cargo Policy Shows $1 Million. The Electronics Sublimit Is $100K.

A broker I know — good operation, been running freight for twelve years — booked a load of consumer electronics. Laptops, tablets, $840,000 FOB origin out of a distribution center in Memphis. He pulled the carrier's insurance cert, checked off $1 million cargo coverage, and moved on. Carrier had a clean record. One BASIC alert in HOS, nothing alarming. Eighteen months of authority.

The load was stolen off a drop trailer in a truck stop lot in Cookeville at about 2 AM.

The carrier filed the claim. The insurer paid $100,000 and closed the file.

The carrier's policy had a sublimit on electronics — $100,000 per occurrence, buried in an endorsement rider that never appeared anywhere on the ACORD 25. The headline limit was real. The $1 million was real. For furniture, for steel coil, for general commodities. For electronics — $100,000. The broker had no idea. Neither did the shipper until they got the check.

That's the sublimit problem. And it's more common than anyone wants to admit.

The ACORD 25 Is a Business Card, Not a Policy

Every broker asks for the ACORD 25. It's the standard certificate of insurance — the document that shows the carrier's insurer, the policy number, the effective dates, and the coverage limits. It's what you attach to a load, what you scan into your carrier file, what you testify about in a deposition.

The ACORD 25 shows you this: carrier has cargo coverage, policy in force, limit is X dollars.

The ACORD 25 does not show you this: what commodities are excluded, what per-occurrence sublimits apply to specific freight types, whether the policy excludes theft from unattended vehicles, whether there's a deductible the carrier can't actually cover, whether the insurer is admitted in the state where the load is moving.

Those things live in the policy itself — in the declarations page, in endorsement riders, in the exclusion schedule. The ACORD 25 is a summary. It is not the policy. And in twelve years of brokering, I watched brokers treat it like it was.

Here's what lives in carrier cargo policies that the cert never tells you about:

Electronics sublimits are the one that bites the most. Electronics, consumer goods, computers — policies routinely cap coverage at $50K, $100K, or $250K per occurrence regardless of the headline limit. High-value electronics loads are also the highest-theft target in commercial trucking, which is exactly why insurers exclude them from standard coverage. You need a carrier that either has a policy specifically written for high-value tech freight, or a rider extending the sublimit to cover your load value. Most brokers never ask which one they have.

Pharmaceutical and nutraceutical exclusions are the ones that surprise shippers the most. A $500K cargo limit on a carrier policy regularly excludes pharmaceuticals, dietary supplements, and medical devices entirely — or caps them well under the load value. The carrier that hauls your standard over-the-counter health-and-beauty is not automatically equipped to insure the specialty pharma load you just handed them.

Theft from unattended vehicles is exactly what it sounds like: if the driver left the truck, the policy may not pay. Some policies specifically require the vehicle to have been running and occupied at the time of theft. Others allow short stops but require proof of a locking mechanism on the cargo area. A drop-and-hook load at a truck stop overnight — the scenario where most theft happens — sits in a gray area that insurers argue about and frequently deny.

Unenclosed trailer exclusions come up in flatbed. If the freight isn't covered — physically, by a tarp or an enclosure — some policies exclude theft and weather damage entirely. That's most flatbed freight by definition. Specialized flatbed operators usually carry endorsements for it. General freight carriers that also haul flatbed sometimes don't.

Refrigeration breakdown exclusions are the reefer equivalent: cargo damage from mechanical failure of the reefer unit is often excluded unless the carrier can demonstrate proper pre-trip inspection and maintenance of the unit. Post-Montgomery, that's now a paper-trail question, not just a claims question. If the carrier can't show the unit was inspected before the load, the damage exclusion sticks — and so does your negligent selection problem.

What Federal Law Actually Requires

Here's the thing most brokers don't realize: federal law doesn't mandate cargo insurance. 49 CFR Part 387 sets minimum financial responsibility for motor carriers, but those minimums are about BIPD — bodily injury and property damage liability. The Bodily Injury, Property Damage minimum for a property-carrying CMV is $750,000 under 49 CFR § 387.303(b)(1) for general freight. That's about covering what happens when the truck hits something. Cargo coverage — what happens when the freight disappears or gets damaged — is not part of that federal floor.

Cargo insurance is contractually required. Your carrier agreement requires it. Your shipper's contract requires you to put a carrier on the load that carries cargo coverage. But the amounts and the exclusions are governed by whatever your contract says versus whatever the carrier's actual policy says. Federal law does not reconcile that gap for you.

The FMCSA's L&I database shows you that the carrier has an active cargo policy on file via the BMC-34 endorsement. It confirms the insurer and the effective dates. It does not show you the sublimits. That's between you, the carrier, and the carrier's actual policy document.

This is why "pulled their certificate" is not a sentence that ends well in a deposition. "Verified coverage against the load value" is better. "Requested and reviewed the policy declarations and confirmed no relevant sublimits or exclusions applied to the commodity" is the sentence that ends the examination.

How This Shows Up After Montgomery

Before Montgomery v. Caribe Transport II, most broker liability exposure ended at the federal preemption wall. A plaintiff couldn't drag a broker into state court for negligent carrier selection because FAAAA preemption blocked the claim. The Supreme Court closed that door unanimously in May 2026.

Now the question a jury will ask is: what did you actually check? And for cargo insurance, "we verified the limit" is going to run directly into "did you verify the limit applied to the specific commodity you were moving?" Those are two different questions. The first is easy to answer yes to. The second is harder.

I've seen the plaintiff playbook now enough times to know where this goes. They subpoena the carrier's policy. The policy shows a $100K sublimit on the commodity your shipper lost $800K on. Then they ask you what you checked and when. If your answer is "the ACORD 25 showed $1M," the expert witness for the plaintiff explains to the jury that the ACORD 25 doesn't show sublimits. You had the means to ask. You didn't ask.

A broker who understands this in advance structures their carrier file differently. Not because they're preparing for a lawsuit — because it's the right standard of care to actually protect their shipper.

The Ask That Closes the Gap

For commodity-specific loads — electronics, pharmaceuticals, medical devices, fine art, alcohol, tobacco, any high-value or high-theft-risk freight — the ask is simple: send me your cargo policy declarations page and confirm in writing that the coverage extends to [commodity] with no sublimit below [load value]. That's one email. Most carriers can produce it in ten minutes.

If the carrier hesitates, that tells you something. If the insurer on the cert is a surplus lines carrier operating non-admitted in your state, that tells you something too — non-admitted insurers can deny claims on procedural grounds that admitted carriers can't.

For new carriers on high-value freight, I now require the declarations page as part of onboarding. DOTScreener's carrier onboarding packet lets you require document uploads as part of the approval workflow — full cargo policy, not just the cert — and flags when required documents are missing before you ever hand the carrier a load. The AI document review pulls commodity exclusions and sublimit language from uploaded policy documents and surfaces them in the carrier file. It's not a legal opinion, but it catches the electronics sublimit that would have cost my colleague $740,000 before the claim ever gets filed.

How I Document This

For loads above $200,000 or commodity-sensitive freight (electronics, pharma, perishables, high-theft goods), my carrier file includes:

• ACORD 25 with effective dates confirmed against load date
• Policy declarations page confirming per-occurrence limit applicable to the specific commodity
• Written confirmation from the carrier that no sublimit below load value applies and no unattended-vehicle exclusion voids coverage for the expected stop pattern
• The commodity specifically named in the load confirmation so the exclusion match is unambiguous
• FMCSA L&I screenshot showing active cargo filing on the date of movement

If a plaintiff's attorney subpoenas that file three years from now, they'll see a broker who verified what the policy actually covered — not one who checked a box.

— Mason Lavallet

Founder, DOTScreener.com