GACAG Urges U.S. Customs to Work with Industry on Advanced Air Freight Screening Pilot Programs

The air cargo industry and national regulatory authorities need to continue working together on pilots to test the feasibility and processes for advance electronic data for air cargo shipments, the Global Air Cargo Advisory Group (GACAG) told Alan D. Bersin, Commissioner of the U.S. Customs and Border Protection (CBP), at a meeting in Washington DC. Industry and regulatory authorities should also assess whether advance data can help support a risk-based approach to air cargo screening. GACAG representatives also met with senior officials from the Transportation Security Administration (TSA) and communicated a similar message.

GACAG further said that pragmatism, flexibility, and joint evaluation of pilot results will be ‘critically important’ to realizing the goals of the Air Cargo Advanced Screening (ACAS) program. Further, GACAG hopes to support CBP and TSA outreach efforts to international institutions, to help communicate about ACAS, and about lessons learned from the approach taken in the United States.

The CBP and TSA meetings were attended by representatives of the four founding members of GACAG; The International Federation of Freight Forwarders Associations, The Global Shippers’ Forum, The International Air transport Association and The International Air Cargo Association, and also addressed broader issues related to automation, harmonization and security. During discussions with Commissioner Bersin and other CBP officials, for example, GACAG members said automation systems should require only those data elements that are legitimately needed to ensure compliance with pertinent regulations, and should be in standardized, harmonized formats. According to GACAG, any newly requested data elements should be checked against the content of the World Customs Organization (WCO) Data Model and incorporated if they do not exist. Thereafter, new data elements should be added to those already within the WCO Safe Framework of Standards to ensure global coverage.

Addressing the ACAS pilot program in the United States, which has been expanded from express operators to include some passenger airlines and forwarders, GACAG said it was ready to work with CBP and the TSA on the initiative and urged continued open dialogue between government and industry to jointly evaluate ACAS at every stage of the process. The Group also called for shippers to be invited to the ACAS discussions.

In a statement, GACAG said: “We understand and support the need for comprehensive risk assessment. A verified secure supply chain is one of the ways this can be accomplished with traders, forwarders, ground handlers and airlines all fulfilling their important roles. The interface and interaction between forwarders and airlines in this regard is paramount. This can only be efficiently accomplished through cooperative coordination of their respective submissions, particularly when it comes to the provision of advance information under the dual filing procedure.

The Group added: “Many issues must still be resolved through the ACAS pilots. In extending the pilot to passenger airlines, we need to take a pragmatic approach, given the many different ways of doing business in the air cargo sector, and the number of parties involved.”

The discussion with CBP also covered GACAG’s support of a paperless environment for air cargo imports and exports. Ultimately, GACAG said it would like to see the processing and authorization of secured data to be shared between air cargo operators and relevant participating government agencies where the responsible parties transmit a standard set of data once enabling a “one stop shop” practice.

Moving towards a paperless environment will require collaboration and cooperation from customs and other border authorities, GACAG said. It will pursue this objective at the WCO. GACAG wants the WCO to review the need for all existing supporting documents and to replace those deemed necessary with equivalent electronic messages using an internationally standard format.

GACAG believes that, at a minimum, the following should be accomplished through electronic means:

• Export and import goods declarations to customs from exporters, importers and/or their forwarders or customs brokers;

• Export, import and transit cargo declarations to customs from airlines;

• Release into free circulation following completion of the Customs formalities;

• Supporting documents should be provided by exception only (e.g. in case of an examination) and printout of electronic records should be accepted;

- Air waybill, house waybill and manifest transport documents exchanged between forwarders and airlines and only provided to customs exceptionally – not regularly;

- All key commercial documents (e.g. commercial invoice, packing list, hazardous materials documentation, certificates of origin) when needed;

• Recordkeeping and archiving for all participating parties (shippers, forwarders, airlines, etc.). There should be no requirement for participating parties to print documents (for example, complete airline manifest and supporting printout for all U.S. departed flights) unless by exceptions (e.g. in case of an audit), and printout of electronic records should be accepted.

U.S. Customs and Border Protection has posted an article about this meeting with the Commissioner on its website http://www.cbp.gov/xp/cgov/newsroom/highlights/trade_groups_day.xml.