If you ship air freight, there's a quiet shift happening in the contractual fine print that could have a very loud impact on your business.
Back in March, IATA's Cargo Agency Conference pushed through amendments to the Direct Air Waybill (DAWB) framework - the standard documentation used across the air cargo industry. The changes took effect on 1 July 2026. And nearly three months later, the industry is still arguing about what they actually mean.
The Core Dispute: Who Carries the Can?
Here's the short version. Under the old DAWB structure, a freight forwarder could tender cargo to an airline with the forwarder's name in the "issuing carrier's agent" box, while the actual shipper appeared in the shipper box. If something went wrong - misdeclared dangerous goods, a sanctions issue, a customs irregularity - the airline's recourse was to the shipper named on the AWB. Often a company the airline had never dealt with.
IATA's argument is that this created a genuine liability gap. A forwarder could avoid liability for cargo it tendered, while the carrier was left exposed to risks from improperly prepared shipments. Dangerous goods are at the heart of it: if the underlying shipper presented cargo directly, the airline could vet that company. Through a DAWB, that visibility disappears.
The new framework flips the default. Where a forwarder tenders cargo under a DAWB, the carrier and forwarder are expected to agree bilaterally on terms and indemnities. If no such agreement is reached, the forwarder is deemed to accept the same terms as if it were shipping in its own name as shipper.
FIATA, the global forwarders' association, sees this very differently. Its director general, Dr Stéphane Graber, has been blunt: responsibility should sit with the party in effective control of the risk, processes, and information involved. Shifting liability onto parties with limited ability to control the underlying risks is unlikely to provide an adequate solution.
What's Actually Happening on the Ground
Here's where it gets messy. IATA confirmed to The Loadstar that the amendments are already in force across all member airlines, and have been since 1 July. It's "a standing rule, not a phased rollout".
But implementation is anything but uniform. Some airlines reportedly aren't intending to implement the revised framework at all. Others - like Air France-KLM Cargo - said they were still "reviewing the revised DAWB framework and its implications". That creates a patchwork where the same shipment could face wildly different contractual treatment depending on which carrier operates the flight.
FIATA formally invoked the review mechanism under CAC Resolution 801c back in May, arguing that the amendments were adopted following insufficient consultation and could shift liabilities onto forwarders without corresponding operational control. The review wasn't completed before the effective date. FIATA requested a postponement to 1 October. It wasn't granted.
What This Means for Shippers
You might be thinking this is a spat between IATA and forwarder associations. But here's why it matters to anyone moving cargo by air.
The Airforwarders Association has warned that the revised framework could leave forwarders responsible for obligations traditionally carried by shippers - including cargo misdeclarations, concealed dangerous goods, and packaging failures. Brandon Fried, the association's executive director, put it plainly: "Freight forwarders should not be expected to assume liability for cargo they neither own, pack, nor control".
Cargo insurer Breeze has flagged a "significant reallocation of risk" and warned that forwarder liability insurance is traditionally designed around the services forwarders actually perform - not around assuming shipper obligations. Businesses shouldn't assume their existing cover will automatically respond if contractual liability changes.
For shippers, this translates into a simple question: when you hand your cargo to a forwarder using a DAWB, who is actually on the hook if something goes wrong? And more importantly - does your forwarder know the answer?
This Is Exactly Where Experience Matters
At Xiamen AE Global, we've been moving air freight through regulatory shifts since 2018. We're a government-licensed company with IATA, FIATA, FMC, and NVOCC credentials - which means we don't wait for a rule change to hit our clients' shipments before we understand it.
The DAWB amendments are a perfect example. IATA's guidance advises forwarders to engage directly with airlines to clarify contractual arrangements, allocation of responsibilities, and liability frameworks before cargo is accepted for carriage. That's exactly what we've been doing.
- Bilateral Agreements, Not Defaults
The new framework's default position - treating a forwarder as shipper in the absence of a bespoke agreement - is a risk we've been actively mitigating. We work with our airline partners to put bilateral arrangements in place that reflect the actual division of responsibility, rather than accepting a default that could leave our clients exposed.
With over 100 overseas agents worldwide, we have the carrier relationships to negotiate these agreements at scale. We're not a small operator hoping the rules don't catch up with us. We're a forwarder with the credentials and the network to stay ahead of them.
- Technology and Visibility That Support Compliance
We've invested heavily in technology that gives our clients real visibility into their shipments - not just a tracking number, but actual insight into what's happening with their cargo. That matters even more now that the liability framework has shifted. When you need to know who prepared what, when, and how, having a partner with accurate, real-time data isn't a luxury - it's essential.
- Local Knowledge, Global Reach
Based in Xiamen - one of Asia's busiest air cargo hubs - we combine global reach with the kind of local knowledge that only comes from moving all kinds of goods for over a decade. We've moved over 12,000 TEUs in a single year with a 98.6% on-time delivery rate for our SME clients. That's not luck. It's the result of a team that treats regulatory change as something to prepare for, not react to.
The Bottom Line
The DAWB amendments have created real uncertainty. Airlines are implementing them differently. Forwarders are scrambling to review contracts and insurance. And cargo owners are left wondering who's actually responsible for what.
At Xiamen AE Global, we don't just move boxes. We help our clients navigate regulatory complexity - whether that's securing bilateral agreements that protect their interests, ensuring our contracts reflect the actual risk allocation, or simply making sure your cargo gets where it needs to go without surprises on the back end.
Because when the rulebook changes mid-game, you don't need a spectator. You need a partner who's already read the new rules - and knows how to play by them.
Want to make sure your air cargo shipments are protected under the new DAWB framework? Contact Xiamen AE Global today - and let's make sure your contracts reflect where the risk actually sits.
