Carriage of Goods by Sea Act (COGSA) of 1936 — incorporated by reference in every bill of lading for the foreign transport of goods to or from the United States, this Act contains a laundry list of 17 causes of loss for which the carrier or vessel is not liable as long as the carrier exercised reasonable steps to make the ship seaworthy and to handle/stow goods responsibly. COGSA also limits liability to $500 per package or customary freight unit (CFU) unless another amount is specifically mentioned in the bill of lading. That amount, however, can never be greater than the actual loss incurred.