INTERNATIONAL FEDERATION OF FREIGHT FORWARDERS ASSOCIATIONS (FIATA)

國際貨運代理協會聯合會 Updated 22 Oct 2026

·     Direct Air Waybills: Aligning Liability with Operational Reality

The IATA amendments to the Direct Air Waybill (DAWB) liability framework entered into effect on 1 July 2026 following an expedited adoption process. The changes have generated concern across the air cargo industry, with freight forwarders, shippers and insurers questioning whether the revised framework appropriately reflects operational realities. Since the proposal was first raised, FIATA has actively engaged through IATA governance processes, consistently highlighting the practical and legal implications of reallocating liability to freight forwarders acting solely as agents of the shipper. FIATA has continued to call for broader stakeholder consultation while issuing interim guidance to assist freight forwarders in navigating the new framework.

A DAWB structure is commonly used where the shipper is identified directly on the air waybill and the freight forwarder acts as the shipper's agent rather than as the contracting carrier. Such arrangements are often required for commercial, regulatory or documentary reasons and are widely used across international air cargo operations.

A central concern is whether liability is being allocated to parties that neither created nor controlled the underlying risk. In many DAWB shipments, freight forwarders do not control the packing of goods, their technical composition, or the accuracy of information provided by the shipper. Risks such as misdeclaration, concealed dangerous goods or fraud generally originate at shipper level and should be distinguished from risks arising from the forwarder's own activities, such as documentation or handling errors. FIATA recently published an update to FIATA Members clarifying that, under the amended framework, freight forwarders tendering shipments under a DAWB are treated as shippers for the purposes of shipper obligations and indemnities, regardless of the party named in the shipper box, unless an alternative arrangement is agreed with the carrier. FIATA also confirmed that it is working with external legal counsel on the appropriate legal action.

FIATA’s AFI Chair provided a more detailed analysis of the DAWB liability changes and their implications for freight forwarders in an article which can be found here.