01JUL26 saw two unrelated regulatory shifts come into effect on the same day, affecting the air cargo and e-commerce logistics industries, and causing consternation and challenges for freight forwarders. One reshapes the contractual backbone of air freight documentation, the other rewrites the economics of low-value e-commerce imports into the European Union.
The first shift concerns the IATA Direct Air Waybill (DAWB) framework – the standard documentation used across much of the air cargo industry. Amendments to that framework were adopted by IATA’s Cargo Agency Conference under an expedited procedure, with implementation set for 01JUL26.
The trouble is that the normal safeguards around such changes appear to have been bypassed. FIATA, the global freight forwarding federation, had exercised its formal right under the Cargo Agency Conference (CAC) Resolution 801c to request a review of the decision and postpone the effective date to 01OCT26, accordingly. Yet, the IATA-FIATA Consultative Council did not convene in time to make a recommendation back to the Cargo Agency Conference, despite repeated requests. Thus, the amendments went ahead as scheduled. FIATA Director General, Dr Stéphane Graber, emphasized: “The review mechanism exists for an important reason: to ensure that significant changes affecting the rights, responsibilities and liabilities of all affected market players – including freight forwarders, shippers and airlines – are properly considered before they take effect. That critical procedural safeguard has not been respected before the scheduled implementation date. In the absence of a meaningful review, airlines should provide complete transparency regarding the contractual framework they intend to apply from 01JUL26. Freight forwarders cannot reasonably be expected to assume significant new contractual obligations or liabilities outside of their function without legal certainty or a proper opportunity to assess the resulting operational and insurance implications.”
FIATA and AfA unhappy with IATA
The Airforwarders Association in the U.S. echoed FIATA’s request for clarity from the other side of The Pond. Its concern is concrete: the revised framework could shift liability for cargo misdeclaration, hidden dangerous goods, or packaging failures away from the shipper – the party actually creating the risk – and onto the forwarder, an intermediary whose day-to-day role has not changed. AfA’s Executive Director, Brandon Fried, framed the core objection simply — forwarders shouldn’t be on the hook for cargo they don’t own, pack, or control. He warned: “Businesses should not assume their existing cover will automatically respond if contractual liability changes. Smaller and medium sized freight forwarders, in particular, should carefully review both their contractual position and insurance arrangements before accepting shipments under the revised framework [as the changes potentially create] significant legal, operational, and insurance consequences for freight forwarders. Forwarder liability insurance is designed around the services freight forwarders actually perform, not around assuming shipper obligations.”
IATA’s guidance leaves much to be desired
Compounding the confusion, IATA’s own guidance points forwarders towards a patchwork solution – engaging bilaterally with individual airlines to clarify what contractual terms will actually apply before cargo is accepted, and noting that shippers can still appoint forwarders as agents and negotiate to keep existing DAWB arrangements in place carrier by carrier. In other words, there is no single, industry-wide answer to “what are the new rules?” – only an instruction to go and ask each airline separately.
That advice has proven necessary in practice. Early signals suggest airlines are not moving in lockstep: some carriers reportedly have no intention of applying the revised framework from 01JUL26, while others are proceeding. FIATA has written to airlines worldwide seeking confirmation of their intentions and how, practically, the new framework will be applied to shipments. AfA’s Fried also warns: “The possibility that all airlines may not implement these changes in the same way creates unnecessary confusion at a time when the industry needs clarity. We strongly encourage freight forwarders to seek written confirmation from every airline regarding the contractual framework being applied, rather than assuming a consistent approach across the market.”
The inconsistency between carriers is itself part of the problem. A forwarder working across multiple airline networks may now be operating under different liability regimes depending on which carrier is used for a given shipment – precisely the kind of fragmentation that undermines confidence in a documentation standard that is not, in fact, standard.
And now: the EU change on low-value imports
The second change that came into effect on 01JUL26, was the European Union’s abolishment of the long-standing customs duty relief for imported goods valued at EUR 150 or less. In its place is a temporary flat-rate customs duty of EUR 3, intended to remain in force until 01JUL28, when a broader customs framework – built around the EU Customs Reform Package and a future EU Customs Data Hub – is expected to take over. The EUR 3 charge mainly applies to B2C e-commerce: goods bought remotely, often through online marketplaces, and sent directly from outside the EU to a consumer inside it – and regardless of how import VAT is handled, though there are certain exceptions. Goods qualifying for preferential tariff treatment under a free trade agreement or customs union continue to receive that treatment instead, and other existing customs duty provisions outside the new mechanism remain unaffected.
The calculation method matters for anyone handling volume, as the EUR 3 is charged per line on the customs declaration, with identical goods under the same tariff code generally consolidated onto one line. In other words: a parcel of five identical t-shirts under one commodity code draws a single EUR 3 charge, while a parcel containing a t-shirt, headphones, and cosmetics – three different codes – draws EUR 9. Accurate tariff classification can therefore become a direct cost driver – though who eventually pays the charge depends on individual agreements between importers, marketplaces, logistics providers and end customers.
The EU’s stated rationale is to close a gap that had reportedly been exploited through undervaluation and outright customs fraud, to level the playing field between EU and non-EU sellers, and to strengthen consumer protection while the fuller reform package is built out.
How are freight forwarders affected?
For forwarders and customs representatives active in cross-border e-commerce, the customs change brings a list of to-dos from reviewing representation arrangements so customers understand the new charging structure, to tightening up tariff classification given its direct link to cost, checking that declaration systems can handle the per-line calculation, and revisiting comprehensive guarantees and deferred payment arrangements since higher duty volumes can affect the reference amount those guarantees are based on. Contracts with importers, marketplaces and supply chain partners will likely need updating to reflect the new charge, and forwarders should brace for a rise in customer queries about why import costs have changed.
And there are more changes to come in the EU’s bid for modernized e-commerce regulations. Mandatory Product Identifiers for qualifying low-value e-commerce imports will arrive from 01NOV26, meaning IT and declaration systems face a second adjustment on the horizon before the transitional customs duty itself is expected to give way to the full reform package in 2028.
The common thread
What links the two developments isn’t subject matter – one is a contractual documentation standard, the other a fee mechanism – but timing and effect. Both took hold on 01JUL26 without the settled clarity forwarders would normally expect from a change of this scale. On the DAWB side, a review process that was meant to test the amendments before they took effect was overtaken by the implementation date itself, leaving forwarders to individually chase down each airline’s position. On the customs side, the mechanics are clearer on paper, but the operational load – tariff accuracy, guarantee reviews, contract updates, system changes – has all come at the same time, with more change already scheduled for November.
