This article analyses the transfer of risk under Incoterms® 2020 in CIF and FOB sale contracts and compares it to English law and the UN Convention on International Sale of Goods 1980. It argues that more precision is required in the Incoterms® 2020 provision, to promote legal certainty in a commercially volatile world. It drafts proposed alternatives to be incorporated into the next revision of Incoterms® and concludes that the "ship’s rail" alternative is to be preferred
