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How does a civil-law carrier's privilege on goods differ from a common-law lien?

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Mosaic portrait of Emperor Justinian I with a jeweled crown and halo, from the 6th-century Basilica of San Vitale in Ravenna, Italy. — Carriage of goods Justinian I, detail of a 6th-century mosaic at the Church of San Vitale, Ravenna, Italy.

In the context of the carriage of goods, the primary distinction between a civil-law privilege and a common-law lien lies in the carrier's authority to dispose of the cargo to satisfy unpaid claims.1

Key Differences

Power of Sale: A common-law lien typically grants the carrier only the right to retain possession of the goods until the earned freight is paid; the carrier is generally not entitled to sell or use the goods unless the parties have explicitly agreed to an "active lien". In contrast, a civil-law privilege inherently confers upon the carrier the power and authority to sell the goods to satisfy their claims for freight and incidental expenses.1
Scope and Duration: The civil-law privilege covers the entire shipment as defined by transport documents and is extinguished once the goods are delivered to the consignee.1
Legal Basis: While common-law jurisdictions rely on common-law, statutory, or contractual liens, civil-law systems provide this privilege specifically to professional carriers operating under a contract of carriage.1

Beyond this privilege, civil-law carriers may also utilize the general law of obligations to withhold delivery until payment is secured.1