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Advocacy Report


TIACA is pleased to share the Advocacy Report outlining our advocacy efforts on members' behalf. The report will be updated on at least a monthly basis, with interim updates on any breaking news. Activities of the various Industry Affairs Subcommittees will also be incorporated here as we go forward.


TIACA welcomes your input, feedback as well as thoughts on how we can continue to improve. 




 Account Consignor (AC) Changes |  Pre Loading Advance Cargo Information (PLACI)


TIACA Advocacy Initiatives







North America


1.     TIACA engaged in an active dialog with industry colleagues globally to clarify the status of ICAO work on interpreting Amendment 13 to Annex 17, regarding potential changes to shipper categorization and recognition within a secure air cargo supply chain. This is a subject that will be discussed at the upcoming meeting of the ICAO Working Group on Air Cargo Security in September. TIACA’s Secretary General will participate in this session. We will continue discussions on this topic within the IAC Security and Safety Subcommittee on possible paths forward. This process will likely take months, as it involves learning more about current approaches employed by ICAO States as well as identifying approaches that are operationally feasible. The work will also entail discussions within ICAO’s relevant groups. This issue could potentially affect all air cargo supply chain partners - airlines, forwarders, ground handlers, and shippers – as it may have an impact on security procedures, requiring additional measures and training.


2.    TIACA conducted an initial review of a Federal Register notice by the Environmental Protection Agency in which EPA proposes finding that greenhouse gas emissions from aircraft cause or contribute to air pollution that could endanger public health and welfare, and provides advance notice of a proposed EPA rulemaking The TIACA Environment and Infrastructure Subcommittee discussed the notice as a first step in determining our response and comments to the proposed rule. The notice is related to ongoing work at ICAO, where the Committee on Aviation Environmental Protection (CAEP) has been developing a standard on carbon dioxide aircraft emissions. This process will culminate in February 2016, when CAEP is expected to adopt a standard for new and in-production aircraft. The ICAO Council is expected to adopt the CAEP standard in March 2016.


EPA has been engaged in the CAEP work, and plans to adopt the ICAO standard as the U.S. standard. The July 1 notice is part of the regulatory process for dovetailing the two. In addition, the advance notice of proposed rulemaking lays out additional steps EPA might take. In its notice, EPA invited comments from interested parties, and set a deadline of August 31. Subcommittee members determined that TIACA should submit comments to EPA, which are currently being prepared. The overall economic impact of these potential changes on each element of the supply chain is as yet undetermined, but will be felt in future years.



3.    TIACA met with the TSA on numerous levels to discuss the need for R&D aimed at the air cargo environment, and specifically at delivering viable new technologies for use in screening air cargo shipments. Savings which can be obtained through the use of newer, more efficient and standardized technologies will reduce the cost of screening procedures and compliance for CCSF shippers and forwarders in the US, as well as airlines. In addition, broader acceptance globally of new technologies and platforms will reduce global costs for these segments.



4.    As the industry co-chair of TSA’s Air Cargo subcommittee within the Aviation Security Advisory Committee, we chaired an all-day meeting of the Subcommittee on July 30. There were detailed discussions on a range of subjects, including R&D geared toward the cargo environment; reconstituting an air cargo office within TSA; renewal of TSA’s mutual recognition agreements with other global regulators for air cargo; the ACAS pilot status and procedures; paperless initiatives; and potential expanded use of private and/or government sponsored canine screening teams. The new Administrator of TSA, Peter Neffenger, joined the meeting and expressed his desire to learn more about our industry and issues.ACAS pilot issues include support of a portal to enable forwarders to file advance data directly, enabling them to remain competitive without assuming additional costs; and screening protocols that will enable host country procedures, thus reducing training costs for regulated agents, postal operators, handlers and carriers. More specific to the US, expansion of canine screening would enable the forwarding community to take advance of screening larger cargo configurations more efficiently.


5.    TIACA has been working closely with regulators to extend Mutual Recognition programs.  The US-Australia mutual recognition program has been extended  to enable gradual phasing in of piece level screening measures.   . Carriers have 45 days from August 1st to file  a proposal for an amendment to the TSA's Standard Security Program. The proposed amendments are to include aggressive timelines for meeting the current and future requirements of both Governments.


As the phase in is gradual, forwarders/regulated agents may not see an immediate effect or change, but should work with the carriers they use from Australia to the US for any future changes.


Further details of the agreement have been published on the Australian Government Department of Infrastructure and Regional Development website, under “The Way Ahead” section, found here:


6.   TIACA participated as a panelist at ALPA’s July 23 Air Safety Forum. We discussed TIACA and its work on security and safety issues. The panel provided an opportunity for pilots to learn more about TIACA’s priorities, and for TIACA to do the same for pilots’ top objectives.  As a result of this dialog, TIACA and ALPA learned that ACAS (and, more broadly, PLACI) is a key priority for both organizations, and we also agreed on the need to remain engaged with each other as we move forward.





1.    UCC Implementing and Delegating Acts

TIACA participated in the EU’s 41st TCG meeting. The discussions were centered largely on the next steps regarding the Delegating Acts/Implementing Acts (DA/IA) for the revised UCC, which include measures for PRECISE, as follows:

o   IA:  the written procedures on the IAs were to  be finalized by July 28, after which they will go to the European Council & European Parliament. Considering that between July 15 and August 20 is Brussels summer break, the 2 month-period which Council + EP have for review will start on August 20 and end by October 20.

o   DA: the usual committee procedure will apply. Discussions at the Customs Committee are expected to take place beginning in September/October.

o   During our discussions with  DG TAXUD, it appears that  a number of EU Member States (MS) want the IA/DA to be adopted as they are so that concrete work can start to align business processes with these currently unfinalized  legal texts.

o   A new Project Group is being created this autumn to discuss Centralized Clearance, Access to records, and other issues, in lieu of all MS having separate systems for customs procedures (separate from PRECISE)

o   Once adopted the final DA/IA will be made available for public discussion.

·         Transitional DA’s:

o   Transitional DA’s are being developed separately from the IA/DA, and will affect all parties, including carriers, regulated agents, ground handlers and postal operators.  The document on the Transitional DA’s is expected to be finalized by end of August. We are concerned about this issue as there was only one consultation with our industry, which took place in early on May 2015. There has been no update or feedback to the TCG since then. Consultation on how to implement these Transitional DAs will only take place after October. TCG estimates this will be not sufficient, as the Transitional legal texts will regulate trade’s requirements until 2020.

 o   In addition, we engaged in   extensive discussion about the “cut-out” date when and how the new IT system(s) will be implemented.

We as industry  are  of the unanimous view that we should have one single switch-over date when a new IT system is replacing an existing one, as working on different dates in different Member States  will be an operational challenge for all industry segments.

TAXUD representatives have confirmed they understand and even agree with this reasoning, but they are however faced by some strong opposition by some (unnamed) Member States. Such discussions will take place in the context of the UCC Work Program. A working document on the transition strategy is expected within the next month. (Philip Kermode, Director of DG TAXUD also committed to organize joint meetings between MS and trade to discuss this sensitive topic.


Based on the consultation information for the Transitional DA a smaller group of TCG members, including TIACA, drafted a letter to Philip Kermode to request getting more involved in the drafting of the Transitional DA (and also expressing strong concern about the lack of information about Title IX). A single meeting with our industry   in October (while MS and TAXUD will meanwhile meet without our involvement to discuss the transitional provisions, e.g. on Sept 17-18) is not satisfactory, as by October the Transitional DA will be practically finalized by that time. The letter has been transmitted on July 24th, but to date we have not received a response.  




2.    WCO

We are continuing to contribute work with the  WCO to better define the next steps of the PSCG working group, toward developing the future of customs regulations.





Secretary General Doug Brittin spoke at the Singapore Ministry of Transport’s Cyber Security Conference in Singapore. During the 2 day session involving industry and cyber security experts, he noted the increasing importance of programs and measures to prevent not only security breaches, but also to protect against business disruptions and economic harm cyber incidents could cause. With the increasing flow of data between industry partners, as well as to/from regulators (through PLACI-type programs), opportunities for incidents will increase and it is important for industry and regulators to look at all aspects of the issue, to determine what potential regulations and protections may look like. 













North America

1.    On June 9-10, TIACA participated in the Cargo Council meeting of Airlines for America (A4A) and, on June 17, participated in the Cargo Airline Association’s (CAA) quarterly meeting. Both offered the opportunity to liaise with industry colleagues and regulators, to exchange views on a range of security, environmental, customs, and other issues, and to share TIACA’s perspectives. They also reinforce the necessary contacts to forge coalitions to address key subjects. An example of this is our recent collaborative work, led by TIACA, in which we addressed the process by which TSA is renewing its security mutual recognition agreements. As described in a previous communication to TIACA members, these are carried out under TSA’s National Cargo Security Program (NCSP), and many of the existing agreements are approaching their renewal dates. TSA has raised questions about certain parts of other countries’ security regimes. We have in turn raised concerns about possible sudden changes to security requirements and potential operational consequences. Working together with A4A, CAA, the Airforwarders Association, the Global Express Association, IATA, the Express Association of America, the Association of European Airlines, and the European Express Association, TIACA sent letters outlining these concerns to senior TSA and EU officials. We are actively continuing to work towards a mutually acceptable resolution.


2.    On June 22, TIACA co-sponsored an industry-government meeting to review significant outstanding issues and next steps on the Air Cargo Advance Screening (ACAS) initiative, which is the United States’ PLACI program that has been piloted for the last four years. The meeting was conducted with our fellow associations: Airlines for America, the Express Association of America, and the International Air Transport Association. While this type of meeting was held regularly during the first two years of the ACAS pilot, the June 22 event was the first such meeting since October 2012, and offered industry, CBP and TSA the opportunity to review what has been learned from the pilots, and to identify key outstanding issues.


Doug Brittin moderated a panel on international issues, and TIACA’s Washington DC chair of the industry's international working group, outlined key objectives and work streams moving forward. These include: expanding mutual recognition, interoperability of multiple PLACI systems, and the need for global standards and systems integration. Further discussion centered on possible capabilities for the government to provide a neutral web-based platform, to enable smaller forwarders to readily access the  ACAS system to file directly, and not remain reliant on carriers, a position which TIACA has proposed and supports. At this point no commitment was made, but opportunities for comment will be available when the DHS rulemaking notice is issued, perhaps later this calendar year. US regulators acknowledged that much work remains before the program can be fully operational, and committed to working with TIACA and industry in this effort.


PLACI regimes will have an impact on most air cargo supply chain partners, even in countries that do not implement their own PLACI system, because of the need to provide advance data on shipments that transit or are destined for PLACI countries (which will include the U.S., EU, Canada, Japan and others).


3.     On June 25, TIACA met with TSA officials to discuss the status of various security issues affecting air cargo supply chain partners, including research and development of technologies for air cargo screening, potential expanded use of canines for cargo screening by forwarders and others, and renewal of TSA’s mutual recognition agreements with other countries, stressing the concerns reflected in the earlier meetings.


4.    On June 30, TIACA, along with industry colleagues from the Cargo Airline Association, met with TSA officials to discuss issues related to U.S. screening requirements under the Standard Security Programs (SSPs), and also ICAO's upcoming discussions on air cargo security within the Working Group on Air Cargo Security. The details of the meeting are restricted as they are covered by Sensitive Security Information, but potential changes to SSPs have the potential to affect all supply chain partners, including airlines, forwarders, truckers and ground handlers, potentially adding costs and new screening requirements.



  • On Jun 07 - 08 , TIACA participated at the last meeting of the old WCO PSCG (Private Sector Consultative Group)

o   One main topic was the future of PSCG, its new structure, and which existing members would be elected to continue within the new body. The PSCG provides a direct opportunity for industry to discuss and influence policy issues within the WCO.

o   The second major topic was the preparation of a presentation for the Policy Commission Meeting at Jun 09 to outline the structure going forward.



Download: PSCG Report to the Policy Commission June 2015


o   On June 08, Secretary General Kunio Mikuriya informed the PSCG members, about the structure of the new PSCG. The complete PSCG will have 21 Members in total, and ideally all regions will be represented.  

o   As the criteria for membership of newly re-constituted PSCG has changed, the key points include:

  • Two-thirds representation from industry companies and one-third from industry associations. • Geographical/regional balance.  The aim is to have at least one company/association from each of the six WCO regions. • Ensuring that a diversity of business sectors is represented. • At the outset, ensuring a balance between experience (existing PSCG members) and new members. • Initially, the length of membership may vary (one year, two years or three years) to ensure efficient and staggered turnover of members. 

o   TIACA will retain its current ability to attend and also to apply in 2016 for a continuing 3 year membership on the PSCG.


  • On June 09 TIACA attended the WCO Policy Commission Meeting

o   There was further discussion and final adoption of the agreed changes at the 2015 version of the SAFE agreement on standards.



Download: SAFE Framework of Standards


o   As there were no real objections against the changes to the policy, the commission agreed and passed the document to the Council for final WCO adoption.

o   TIACA played a significant role over the past 2 years in directing the specific language of these provisions, both directly with the WCO, and through our work on the joint ICAO/WCO Joint Working Group on Advance Cargo Information. (JWGACI). This includes: limiting the selection criteria for Advance Data to "7+1”, when regulators desired using those elements as "minimum” requirement, which would have opened the door for essentially unlimited requests (see Annex III of the SAFE 2015 document); and language to ensure closer cooperation and harmonization of Customs and Civil Aviation measures (highlighted in Sections 2.4 and 2.8 of the SAFE 2015 document). TIACA will continue its efforts to further align these measures globally, to minimize the costs and challenges of implementing multiple measures for forwarders, regulated agents, ground handlers and carriers.

o    The presentation prepared by the PSCG is attached above.



 On Jun 11 - 12  TIACA participated in  the full WCO Council Session

o   The main topics from a TIACA perspective were the final discussion and adoption of SAFE changes as well the new PSCG structure. TIACA provided supporting discussion.

o   Other key topics have been:

  • The Capacity building initiative within WCO
  • WTO’ trade facilitation network and
  • Customs business partnership guidance


 TIACA will continue to attend those meetings and will continuously work together with WCO to help shape direction and policy to ensure all supply chain segment issues are addressed


 On June 25, TIACA participated in  the European Union’s DG MOVE SAGAS (Stakeholders Advisory Group on Aviation Security ) meeting, for discussions between DG MOVE // EU Member States and Trade of the following key topics:


o   Update on the 85th AVSEC Regulatory Committee meeting with all the PLACI developments at JWGACI, WCO, ICAO etc. 

  • Mutual recognition agreements , and:
  • The Inspection activities of TSA and US airports, concerns on consolidating efforts and recognizing mutual procedures
  •  Challenges with TSA and EU mutual recognition, including the next steps discussion on the two letters sent to TSA (as noted in the USA segment above)
  • Cyber Security –steps to identify challenges and opportunities to minimize disruption across the supply chain.



Download: Information Note on Cybersecurity



o   Draft proposal on the latest version of the UCC Implementing and Delegating Acts (IA and DA) for PLACI  throughout the EU

Stakeholders’ activities



Download: TAXUD MOVE Joint Referrals



Discussion on Cargo Screening technology developments and requirements/standardization. EEA gave a presentation on a study they did and asked interested associations for their support to start a joint initiative. TIACA has been a strong advocate of this concept, regionally and globally, and will continue to support all avenues, in the interest of reducing costs of equipment through standardization, with resulting reduced costs in implementation and training,    



Download: Presentation on Study Results - EEA



On June 29 and 30, TIACA participated in  the European Union’s TAXUD ECCG (Electronic Customs Coordination Group) where TAXUD informed, discussed and approved with Member States the latest IT related developments within the EU. Trade is now invited to give input, raise concerns and make proposals how to proceed. Main topics have been:

o   EU Single window Project

o   UCC Business case and BPM activities



Download: Business Case and BPM Activities



o   Customs 2020 Project Group to Examine impact of the UCC related IT requirements on the MS system

o   UCC Customs decisions // overview on MS //TCG comments on Trader portal

o   Customs decisions and Proof of Union status

o   AEO UCC and AES inception phase

o   Business Continuity plan and Customs Union performance


TIACA will be providing information regarding next steps and necessary feedback.








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