The introduction of the revised Direct Air Waybill (DAWB) framework on 1 July by the International Air Transport Association (IATA) – without due consultation – has prompted furious reactions from the global freight forwarding community.
The concern is not simply that contractual terms have changed. It is that the new framework alters where legal responsibility may sit when things go wrong, despite widespread objections from freight forwarding associations and calls for further industry consultation before implementation.
While the revised rules apply specifically to Direct Air Waybills rather than every air freight shipment, they could have far-reaching implications for airlines, freight forwarders, insurers and, ultimately, cargo owners.
For shippers, the issue extends well beyond contractual wording. If logistics providers assume greater legal exposure, the additional cost and administration are likely to be reflected throughout the supply chain.
An industry concerned about process as much as principle
International freight forwarding organisations have questioned both the substance of the new framework and the manner in which it was introduced. The International Federation of Freight Forwarders Associations (FIATA) has publicly stated that implementation proceeded before the agreed consultation and review process had been completed, raising concerns over governance as well as the practical consequences for the industry.
National forwarding associations have echoed those concerns. The US Air forwarders Association has warned members that the revised contractual arrangements could expose freight forwarders to liabilities that have historically rested with the shipper, including inaccurate cargo declarations, concealed dangerous goods and packaging failures.
The absence of a universally consistent implementation approach has added further uncertainty. Industry reports suggest that airlines may interpret or adopt the revised framework differently, potentially requiring freight forwarders to manage varying contractual arrangements across multiple carrier networks.
Rather than simplifying international air cargo, the changes risk creating greater complexity for everyone involved.
Responsibility is shifting through the supply chain
Traditionally, freight forwarders arranging air transport have acted as agents on behalf of their customers.
Under the revised DAWB framework, airlines may instead regard the freight forwarder as the principal contracting party for certain shipments.
That distinction is significant.
If cargo has been incorrectly declared, inadequately packaged or contains undeclared dangerous goods, airlines could seek recovery directly from the freight forwarder, even where the underlying failure originated with the shipper or manufacturer.
This represents a fundamental shift in commercial responsibility.
Freight forwarders rarely manufacture products, package cargo or prepare goods for transport. Their role is to arrange and coordinate international logistics, yet the revised contractual framework may leave them carrying liabilities arising from activities outside their direct control.
The issue is particularly relevant as air cargo volumes continue to grow in sectors such as eCommerce, consumer electronics and healthcare, where strict compliance with dangerous goods regulations and cargo acceptance procedures has become increasingly important.
Insurance and compliance costs are likely to increase
Most freight forwarder liability insurance has traditionally been designed to cover professional negligence, errors and omissions in arranging transport. It was never intended to provide blanket protection against risks created by third parties.
Insurance specialists have already indicated that existing policies may not automatically respond where a freight forwarder is treated contractually as the shipper under the revised DAWB framework.
If insurers reassess their exposure, logistics providers may face higher premiums, tighter policy conditions and more extensive compliance requirements before accepting cargo.
Forwarders are also likely to introduce additional due diligence processes to reduce risk. More detailed cargo declarations, enhanced dangerous goods screening, stricter documentation checks and closer scrutiny of packaging standards could all become routine before shipments are accepted for carriage.
These measures may improve compliance, but they also add time, administration and cost to the shipping process.
Why this matters to cargo owners
Although the contractual relationship exists primarily between airlines and freight forwarders, the commercial impact is unlikely to stop there.
Additional insurance costs, increased compliance procedures and greater administrative oversight inevitably increase the cost of providing international logistics services. Over time, those costs are likely to filter through the supply chain.
For businesses shipping by air, particularly those moving high-value, regulated or time-critical products, documentation accuracy and product compliance will become even more important.
Working with an experienced freight forwarder who understands dangerous goods regulations, customs requirements and airline acceptance procedures can help minimise delays while reducing the risk of disputes or unexpected liabilities.
As the industry adapts to the revised framework, collaboration between shippers, freight forwarders and airlines will become increasingly important in maintaining efficient and compliant supply chains.
Overcoming regulatory change with confidence
Global Forwarding works closely with customers to ensure documentation, cargo acceptance procedures, dangerous goods compliance and airline requirements are addressed before shipments enter the air freight network.
If you would like to understand how the revised Direct Air Waybill framework could affect your organisation, contact the Global Forwarding air freight team to discuss practical steps that can help reduce risk, maintain compliance and keep your cargo moving with confidence.
