Steplane › Guides › Trading conditions by country
Updated 19 October 2026 · Written by Paul, founder of Steplane, a logistics process specialist with over 13 years in logistics, including at some of the biggest freight forwarders in the world.
In short: Under BIFA STC a claim must be notified in writing within 14 days and sued on within 9 months, with liability at 2 SDR per kg. NSAB 2015 allows 1 year to sue, ADSp 2017 follows German law (1 year), and Dutch conditions bar claims after 9 to 18 months. All apply only if you incorporate them.
Each national association publishes its own standard conditions. They cap what the forwarder pays and set notice periods that are often much shorter than CMR. The table below compares them, with the clause numbers, so you can check the current text yourself.
Without your own conditions, a court applies the general law, and a forwarder may face full liability for the value of the goods and for consequential loss. Standard trading conditions do three things:
BIFA's own guidance says the clause 26 limits apply only if the conditions are incorporated into the contract with the customer.
| Country | Conditions | Publisher | Forwarder liability limit | Notice and claim time limit | Where to get them |
|---|---|---|---|---|---|
| UK | BIFA Standard Trading Conditions, 2025 edition (in force from 1 January 2026; replaces STC 2021) | BIFA (British International Freight Association) | 2 SDR per kg gross weight for loss or damage (cl. 26(A)(i)). Other claims: lowest of the customer's loss, 2 SDR per kg or 75,000 SDR (cl. 26(A)(ii)). Repeated or continuing breaches: 75,000 SDR in total per year (cl. 26(A)(iii)). Delay: at most 2× your charges (cl. 26(B)) | Written claim within 14 days of becoming, or when you ought to have become, aware of the event (cl. 27(A)). Suit within 9 months: under the 2025 edition from delivery for goods claims and from the services for other claims; under 2021 from the event (cl. 27(B)) | BIFA members, through BIFA |
| Netherlands | Dutch Forwarding Conditions (Nederlandse Expeditievoorwaarden), 1 May 2018 | FENEX | 4 SDR per kg gross weight, at most 10,000 SDR per event or series of events with one cause, and never more than the invoice value. The client must prove fault (art. 11) | Claims prescribe after 9 months and are time-barred after 18 months; for goods claims counted from the day after delivery (art. 20) | Deposited at the Amsterdam and Rotterdam district courts; FENEX |
| Belgium | General Belgian Freight Forwarding Conditions 2024 | FORWARD Belgium | 4 SDR per kg gross weight, at most 32,500 SDR per damage event; other claims at most 32,500 SDR; both together at most 40,800 SDR per damage event (art. 6.1.3) | Written claim with grounds within 14 days of delivery; court action within 9 months (art. 11). Invoice disputes within 7 days (art. 4.2) | FORWARD Belgium members |
| Denmark, Sweden, Norway, Finland | NSAB 2015 | Nordic Association of Freight Forwarders, through the national associations | As contracting party: 8.33 SDR per kg; delay: the freight; other loss: 100,000 SDR per assignment (§21). As intermediary: 50,000 SDR per assignment and 500,000 SDR per event (§24). Storage: 500,000 SDR per event (§25) | Claim without undue delay: visible damage at once, hidden damage within 7 calendar days of delivery, other claims within 14 days (§27). Suit within 1 year (§28) | National forwarding associations, for example Transportföretagen in Sweden |
| Germany | ADSp 2017 (German Freight Forwarders' Standard Terms) | German trade and forwarding associations, including DSLV | 8.33 SDR per kg (2 SDR per kg for multimodal including sea where the place of loss is unknown); at most €1.25 million per damage case or 2 SDR per kg, whichever is higher (cl. 23.1). Other financial loss: 3× the cargo limit, at most €125,000 per damage case (cl. 23.4). Per damage event: €2.5 million or 2 SDR per kg, whichever is higher (cl. 23.5). Limits rely on the forwarder holding liability insurance (cl. 28.3) | No own rule, so the German Commercial Code applies: visible damage at delivery, hidden damage within 7 days, delay within 21 days (HGB §438); 1 year to sue, 3 years for intent (HGB §439) | DSLV and the other recommending associations |
| US | NCBFAA Terms and Conditions of Service (revised 9/2023) | NCBFAA (National Customs Brokers & Forwarders Association of America) | $50 per shipment or transaction; for customs business $50 per entry or the brokerage fee, whichever is less (s. 9(c)) | Written claim received within 30 days of the event (s. 3(a)). Suit: 1 year (ocean), 2 years (air), 75 days from liquidation (import entries), 2 years (other) (s. 3(b)). Older versions had other periods: check which text you use | NCBFAA members, or licence holders ($1,000 a year) |
| International model | FIATA Model Rules for Freight Forwarding Services (2019 edition) | FIATA | 2 SDR per kg for loss or damage; delay: the fee for that service; other loss: 10,000 SDR per incident (rule 8.3) | Hidden damage within 6 consecutive days of handover; other claims within 14 days of becoming aware (rule 9). Suit within 9 months of delivery (rule 10) | FIATA, for national associations and forwarders to adopt |
SDR rates change daily; convert at the rate on the date set in the conditions (BIFA: the date the written claim is received). Figures are taken from the published texts listed under Sources. Always check the current text and version before you rely on it, and take legal advice on a real claim.
A limit only protects you if the conditions are part of the contract, and the contract is usually formed when the customer accepts your quote or you accept the booking. Terms that first appear on the invoice, after the job is done, come too late to rely on alone.
In the UK, a limitation clause in written standard terms must also pass the reasonableness test of the Unfair Contract Terms Act 1977 (s. 3 and s. 11). Belgian conditions say a contract is formed on written acceptance of the offer, and offers stay valid for 7 calendar days unless stated otherwise (art. 2).
The quote-to-invoice kit includes quote and invoice templates with a place for the conditions clause, and our free freight quote template has a liability wording you can adapt.
Which regime applies depends on your role in the job.
| Your role | What applies | Liability | Time limits |
|---|---|---|---|
| Forwarder as agent (arranges transport by others) | Your trading conditions | For example 2 SDR per kg (BIFA), 4 SDR per kg (Dutch, Belgian) | Short notice periods, for example 14 days; 9 months to sue |
| Forwarder as principal or carrier on international road carriage | CMR, which overrides contrary terms (art. 41) | 8.33 SDR per kg (art. 23) | Hidden damage 7 days, delay 21 days (art. 30); 1 year to sue, 3 for wilful misconduct (art. 32) |
| Your claim against the road carrier | CMR | 8.33 SDR per kg | 1 year; a written claim suspends the period (art. 32(2)) |
Two practical points. First, as soon as a customer reports damage, send written notice to the carrier as well: do not wait to see if the customer's claim is valid. Second, many conditions say that where a mandatory convention applies, its limits and periods replace those in the conditions, so a 14-day notice clause does not shorten a CMR period. See our CMR claim time limits guide and the free claim letter templates.
Seven steps from damage found to a closed claim file: a damage report form, notice and claim letters to the carrier, letters to the customer and an Excel claims log that calculates the CMR or US deadlines, so the short notice periods in your conditions are never missed. EU and US versions.
€49 (about $55) per kit, one-time. EU and US versions. Any 3 kits €99, all 6 kits €199. 14-day money-back guarantee.
Notify the claim in writing within 14 days of becoming aware of the event, and bring suit within 9 months. Under the 2025 edition the 9 months run from delivery; under STC 2021 they run from the event (clause 27).
BIFA's 2025 edition is valid for use from 1 January 2026. A contract that still incorporates the 2021 edition is governed by the 2021 text, so update your quotes, forms and website to the 2025 wording and tell customers the date of the change.
As contracting party, 8.33 SDR per kg for loss or damage, the freight for delay and 100,000 SDR per assignment for other loss. As intermediary, 50,000 SDR per assignment and 500,000 SDR per event. Suit must be brought within 1 year.
8.33 SDR per kg (2 SDR per kg for multimodal including sea where the place of loss is unknown), capped at €1.25 million per damage case or 2 SDR per kg, whichever is higher. Other financial loss is capped at 3 times the cargo limit and €125,000 per damage case. The forwarder can rely on the limits only if it holds liability insurance (clause 28.3).
4 SDR per kg gross weight, at most 10,000 SDR per event, and never more than the invoice value. Claims prescribe after 9 months and are time-barred after 18 months from the day after delivery.
No. Where you act as carrier on international road carriage, CMR art. 41 makes any term that derogates from CMR null and void. Your conditions still govern the services you perform as agent.
Usually not on its own. The terms must be known to the customer when the contract is made, so put them on the quote and the account opening form, and use the invoice as a reminder.
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