A change to the way air cargo shipments are documented is causing growing concern among freight forwarders, who say the new rules could leave them carrying far more legal and financial responsibility than before.
The revised framework for direct air waybills (AWBs) introduced by the International Air Transport Association (IATA) came into effect on July 1. While IATA says the update is designed to strengthen accountability and improve safety—particularly as shipments of dangerous goods linked to e-commerce continue to rise—many logistics providers believe the changes go too far.
Their main concern is that freight forwarders could now be held liable for problems such as incorrectly declared cargo, hidden dangerous goods or poor packaging, even though those aspects are the responsibility of the shipper.
For many companies, the issue is less about safety than about who carries the risk when something goes wrong.
An air waybill is the legal document that accompanies air cargo, confirming the shipment has been accepted and outlining the conditions under which it will be transported.
In most cases, freight forwarders issue a house air waybill to their customers, while airlines issue a master air waybill covering multiple shipments grouped together by the forwarder.
A direct air waybill is different. It is generally used for shipments that move directly with an airline, often because they contain dangerous goods, perishable products or time-sensitive cargo that requires individual handling.
According to IATA, the changes were introduced because some freight forwarders have been listing the original shipper as the shipper on direct air waybills instead of identifying themselves. The association argues that this weakens the contractual relationship between airlines and the party presenting the cargo, making it more difficult to determine responsibility if an incident occurs.
Freight forwarders, however, argue that they should not be expected to assume responsibility for goods they neither manufacture, pack nor control.
They also say the new framework was introduced too quickly and with insufficient consultation, giving businesses little time to consider the legal, operational and insurance implications.
“It is a major change in liability,” said Matthew Phillips, Chief Commercial Officer at cargo insurance provider Breeze.
Traditionally, freight forwarder liability insurance has been designed to cover mistakes made by the forwarder itself, such as documentation errors or negligence during transport arrangements. If the new framework transfers responsibilities that previously belonged to shippers, insurers may have to rethink policy conditions, premiums and risk assessments.
That uncertainty is already prompting industry associations to advise companies to review their insurance coverage carefully.
The Airforwarders Association is encouraging its members to speak with both their insurers and airline partners before accepting shipments under the new rules. The association says freight forwarders should obtain written confirmation from each airline explaining which contractual framework will apply, rather than assuming every carrier will follow the same approach.
That recommendation comes as another concern begins to emerge.
According to the International Federation of Freight Forwarders Associations (FIATA), not every airline intends to implement the revised framework in the same way or at the same time. FIATA had requested that IATA postpone the changes until October 1 to allow the industry more time to prepare, but the proposal was not adopted.
This complexity is compounded further for freight forwarders operating on multiple international networks where different airlines may have different contractual rules.
Industry groups criticize the air cargo safety efforts, but stress their support for efforts to improve the safety of air cargo, especially for the transportation of dangerous goods, such as lithium batteries.
Their concern is that such significant changes to contractual liability should be introduced only after broad consultation with the industry and accompanied by clear legal and operational guidance.
Many freight forwarders are being cautious for now, reviewing contracts, talking to insurers and seeking clarification from airline partners as they adjust to a framework that could dramatically change how liability is shared across the global air cargo supply chain.




