FIATA Regulatory Alert - China’s revised Maritime Code: Key Implications for Freight Forwarders
China’s newly revised Maritime Code entered into force on 1 May 2026, marking the first comprehensive revision of the Code in more than 30 years.
FIATA has published a detailed Guidance Note on the Code, which covers the below key changes relevant to freight forwarders conducting business in China:
- Mandatory application of Chinese law: chapter IV of the Code applies mandatorily to international maritime cargo transport contracts where either the port of loading or discharge is in China, regardless of any contrary choice of foreign law;
- Carrier liability: the fire exemption is now limited to fire occurring on board and cargo loss or damage will be calculated by reference to market value;
- Unclaimed cargo: freight forwarders may be categorised as shippers with implications in the context of unclaimed cargo, where freight forwarders may be liable for storage costs;
- Electronic transport documents: the Code confirms electronic documents have the same legal effect as paper documents, subject to specific requirements;
- Multimodal transport: if the mode of transport used when the loss occurred can be identified, the law applicable to that mode of transport will apply; otherwise, the Code carrier liability provisions apply; and
- Time bars: circumstances in which limitation periods may be interrupted have been expanded.
Freight forwarders should treat the revised Chinese Maritime Code as a prompt to review their operational, contractual and documentary practices before accepting shipments connected to China.
They should clarify their role, assess route and cargo and route-specific risks, ensure transport documents and electronic records reflect the agreed arrangements, and confirm that insurance matches potential liability exposure.
FIATA will continue to monitor developments and provide further updates as necessary. For questions, please contact [email protected].