Policy & Compliance
A summary of the changes to the China Maritime Code While the revised code does not single out
shipment to shipment. For one consignment, you may act purely as an agent passing instructions. In another, you may issue documents or contract in your own name and find yourself treated as a contracting carrier, NVOCC. The revised code does not single out freight forwarders, but it does shift risk towards the party closest to the transport contract and the transport record. In practice, that can be the forwarder. Historically, China operated a two-track system, one covering international maritime journeys, the other domestic movements. The Maritime Code’s carriage of goods chapter was focused on international sea carriage, while domestic coastal carriage between Chinese ports often defaulted to general civil and transport law. The distinction disappears under the revised code. A ‘contract of carriage of goods by sea’ now expressly
freight forwarders, it does shift risk towards the party closest to the transport contract and the transport record. In practice, that may be the forwarder
C hina’s revised Maritime Code, which became effective on 1 May 2026, is the fi rst comprehensive overhaul since the code entered into force in the early 1990. It reshapes several rules that freight forwarders deal with every day, often without conscious reference to the law behind them. BIFA is examining the code and seeking guidance on key areas, but felt it appropriate to advise Members of the changes identified to date. The freight forwarder’s legal role can change from
14 | June 2026
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