The advent of blockchain bills of lading has attracted the attention of both industry participants and maritime scholars. Concerns are growing about the development of blockchain bills of lading and the construction of a future regulatory framework. This paper will argue that, rather than relying on reform or implementation of positive law instruments regarding blockchain bills of lading, the other layer of regulation in the shipping industry, which consists of relevant self-regulation instruments, should be considered to provide a basis for filling the regulatory gap between the fast evolution of blockchain bills of lading and the inherent conservatism of maritime law.