On 1 July 2026, amendments to the IATA Direct Air Waybill (DAWB) framework – the standard documentation used across much of the air cargo industry – entered into force following an expedited procedure adopted by IATA’s Cargo Agency Conference (CAC).
The implementation has been met with significant concern across the supply chain. The International Federation of Freight Forwarders Associations (FIATA) exercised its formal right under CAC Resolution 801c to request a review of the decision and postpone the implementation date until 1 October 2026. The European Shippers’ Council (ESC) likewise called for a formal review through the IATA–FIATA Consultative Council (IFCC) and urged IATA to postpone implementation to allow all affected stakeholders sufficient time to assess the contractual, operational, and commercial implications of the changes. However, the IFCC did not convene in time to make a recommendation to the Cargo Agency Conference, despite repeated requests, and the amendments therefore entered into force as scheduled.
According to FIATA, the review mechanism exists to ensure that significant changes affecting the rights, responsibilities and liabilities of all market participants are properly considered before taking effect. ESC similarly stressed that structural changes to the allocation of rights and liabilities should be based on broad stakeholder consultation and a thorough legal, operational, and insurance assessment to preserve legal certainty and market stability.
One of the principal concerns is that the revised framework could shift liability for cargo misdeclaration, hidden dangerous goods or packaging failures away from the shipper—the party creating the risk—and onto the freight forwarder, whose operational role has not changed. Such a shift could have significant legal, operational, and insurance implications, particularly as freight forwarders’ liability insurance is designed around the services they actually perform rather than around assuming the obligations of shippers.
From the shipper perspective, ESC underlined that clarity regarding contractual responsibilities and the flow of information is essential for tendering, vendor selection, and contract design. During consultations with shippers, freight forwarders, airlines, and insurers, stakeholders expressed concern that certain elements of the revised DAWB framework may disconnect liability from operational control. Such misalignment could undermine insurability, reduce the predictability of claims handling, and ultimately affect shippers’ risk management and procurement decisions.
Timing has also been identified as a major concern. According to ESC, the proposed changes were communicated only a few months before implementation, leaving businesses with insufficient time to review and renegotiate framework agreements, update compliance programmes and operational procedures, or assess whether changes in liability could translate into higher freight rates, insurance premiums, or other charges. Where transport costs increase, shippers may also need to recalculate product cost prices and margins across multiple markets—an exercise that normally requires planning aligned with budgeting and contractual cycles.
Adding to the uncertainty, IATA has advised freight forwarders to engage directly with individual airlines to determine which contractual terms will apply. Rather than providing a single industry-wide approach, airlines may implement the revised framework differently, meaning forwarders operating across multiple carrier networks could find themselves working under different liability regimes depending on the airline used. FIATA has therefore written to airlines worldwide seeking clarification, while the US Airforwarders Association (AfA) has similarly encouraged freight forwarders to obtain written confirmation from each airline before accepting shipments under the revised framework.
For both freight forwarders and shippers, the absence of a harmonised approach risks increasing legal uncertainty, contractual disputes, and administrative complexity. ESC has warned that without broad stakeholder consensus and alignment between contractual responsibility, operational control, and insurable risk, the industry risks fragmented practices, weaker supply chain resilience, and higher costs throughout the air cargo chain.
ESC remains committed to working constructively with IATA and other stakeholders to develop a balanced and operationally workable framework that preserves legal clarity, market stability, and alignment with established international liability principles, including the Montreal Convention.