ABSTRACT
This chapter deals with the question of whether the CMR applies directly to road legs within multimodal contracts of carriage. When the individual legs of a multimodal contract of carriage are not directly governed by one of the unimodal conventions, they are governed by the law applicable to the multimodal contract of carriage. Several countries, however, including Argentina, Brazil, China, Germany, India, Mexico and the Netherlands, have incorporated mandatory provisions on multimodal contracts of carriage in their legislation. All the different legislations have adopted a more or less similar network system, also known as the chameleon system. The regime that applies to the sea leg depends on the transport documentation. The domestic network system cannot override the direct application of mandatory conventions. The multimodal carrier's liability under the network system is governed by the legal rules that apply to the leg where the damage occurred.
