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DeCA vs eCMR vs consignment note: which do you need?

Three different documents with three different jobs, and the industry conversation blends them daily. This guide pulls them apart for good: what each one is, which is mandatory, when each regime applies, and how to pick the right one without opening the official gazette every morning.

Published: 10 min read

The three documents, one sentence each

  • The DeCA (Spain's electronic administrative control document) is anadministrative document: it exists so the authority can control domestic transport. Mandatory — and from 5 October 2026, electronic only.
  • The Spanish national consignment note (carta de porte) is acontractual document: it evidences the transport contract between the parties in domestic traffic (Law 15/2009). It is voluntary: the contract exists even without it.
  • The CMR consignment note — and its electronic version, theeCMR — is the contractual document of international carriage under the 1956 CMR Convention. The convention applies by law to international transport between party countries; the note confirms the contract and is what practice (and inspections) expect to see.

The confusion comes from the three sharing data (parties, origin, destination, goods, plate) and travelling on the same truck. But they answer different questions:can the authority control this transport? (DeCA), what did the parties agree? (consignment note), under which international regime is the carrier liable? (CMR/eCMR).

The table that sorts it out

DeCANational consignment noteCMR / eCMR
NatureAdministrative (towards the authority)Contractual (between the parties)Contractual, international
ScopePublic haulage with origin and destination in SpainDomestic transport (Law 15/2009)International carriage between CMR countries
Mandatory?Yes — electronic from 5 Oct 2026No — issued if either party requests itThe convention governs the carriage; the note is standard practice
RulesOrder FOM/2861/2012 + Resolution of 5 June 2026Law 15/2009CMR Convention 1956 + eCMR Protocol 2008
Electronic formatThe only one accepted (native PDF + QR + unique URL)Allowed (electronic support under Law 15/2009)Allowed with the same value as paper (eCMR, ~40 countries)
SignaturesNot requiredBy the parties, if issuedSender and carrier; consignee at delivery

How to decide in 30 seconds

  1. Origin and destination in Spain, for-hire? You need aDeCA, full stop. If the parties also want the contract documented, they add a consignment note — but the administrative obligation is covered by the DeCA.
  2. Does the transport cross a border? CMR regime: a CMR consignment note (paper, or eCMR where the countries on the route are protocol parties). The DeCA does not apply to that transport.
  3. Mixed fleet? Both worlds at once: DeCA for domestic traffic, eCMR for international work. It is the typical case for exporters — and the reason our platform issues both types from the same account and the same engine, picking the type at document creation.
  4. A journey with a domestic leg and an international leg? Each leg gets its document: a DeCA for the domestic haul and a CMR for the international one, linked by your file references.

Can one document act as another?

The star question, with an official answer: yes, under demanding conditions. Another document (a consignment note, a delivery note, ADR paperwork) can act as the control document if it contains all the art. 6 data of Order FOM/2861/2012 and expressly identifies who the contractual shipper and the effective carrier are. And from October 2026 it must also meet the DeCA's technical requirements: digitally native PDF, embedded QR, unique direct-download URL, metadata.

In practice, few traditional consignment notes clear that technical bar. The realistic path is the reverse: issue the DeCA with a compliant platform and attach whatever contractual or commercial content you need (our documents support, for instance, an integrated delivery note section and your file references printed on the PDF).

eFTI: where the three converge

Regulation (EU) 2020/1056 (eFTI)governs the channel through which European authorities will accept transport information electronically from 9 July 2027. It creates no new documents and does not make the eCMR mandatory: it defines a common dataset onto which existing information obligations are mapped. Spain has notified its control document (Order FOM/2861/2012) into the regulation's Annex I-B, and CMR data serves as evidence within its own scope. Translation: DeCA, consignment note and eCMR all end up in the same data model — one more reason to issue them today on an engine aligned with that vocabulary (UN/CEFACT), like ours. Full detail inwhat is the eCMR and what eFTI changes.

Operational summary

  • Domestic for-hire haulage → DeCA mandatory (electronic from 5 Oct 2026).
  • Documented domestic contract → consignment note if the parties want it.
  • International → CMR/eCMR; the eCMR equals paper in ~40 countries.
  • Mixed fleet → both types, ideally one provider, one engine.
  • 2027 → everything converges on the eFTI dataset; pick aligned tools today.

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