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Forwarder - Advocacy Issues
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Requirement to provide HAWB data elements to destination country authorities for risk analysis prior to loading on aircraft



Ground handlers

Forwarders may file data, but may not be able to resolve screening instructions.

May need to establish e-filing to carriers in advance of consolidation or physical transfer, so that risk analysis can be done and not delay shipments


Xxxx uuuuuu etc.

Ground Handlers

Closely engaged with ICAO and WCO on high level principles

Work with TSA, CBP, EU, Transport Canada, CBSA on currently developing programs ACAS, PRECICES, PACT

Promoting Govt sponsored and or neutral filing platform to enable small forwarders to file direct w/o cost of linking to destination regulators

Data elements being finalized in WCO SAFE framework

.developing language for security programs with ICAO/WCO, meetings in October2015.


Account Consignor

ICAO considering removal of this category of shipper, or replace with government inspected site visits




Shipments transported on passenger and all-cargo airlines. Forwarders and Regulated Agents may be unable to validate their shippers directly

Working with ICAO AVSEC WGACS to discuss alternatives and industry-supported measures to validate shippers globally

Preparing position paper for discussions at ICAO WGACS in Paris, September 2015

TSA mutual recognition(EU and Australia near-term)

Mutual recognition allows carriers to use origin state security programs rather than origin AND destination programs. Simplifies training and reduces cost. TSA programs are all for 3 year periods, and renewal as well as renewal timing or advance warning is essential for effective operations. Any changes should be determined well in advance. Threats should be identified and discussed with industry to develop solutions.



PAX and Cargo Carriers, RA’s, Forwarders,


Changes to programs in place after 3 years require training and increased operational cost to PAX and Cargo Carriers, RA’s, Forwarders,

GH industry segments.

Working with TSA, as well as EU (DG MOVE) to extend current programs, or at very least, provide extended advance notice of any changes, as well as explanation.

US/Australia is in extended modification period. Continuing dialog with TSA and MOVE to extend US/EU program intact

WCO SAFE PLACI standards

Risk analysis segments for any PLACI must be standardized globally. Procedures for transmitting and receiving messages must also be standardized and coordinated with any CAA regs Multiple procedures across similar platforms will be confusing, costly and ineffective. Pilots have tested only part of PLACI data sets. Risk algorithms must be same (or closely similar) to avert risk of transit shipment delays.


PAX and Cargo carriers, RA’,

Forwarders, GH

PAX and Cargo carriers, RA’,

Forwarders, GH may need to file multiple times to several customs regimes, at extra cost, and potentially off load shipments en route if common rules are not in place

Working with WCO and customs official, successful in standardizing “7+1” data set, significant work ahead to standardize transmission of data, response mechanisms, and risk algorithms.

Participant in WCO/ICAO JWGACI, as well as directly with current customs regimes (CBP, CBSA, EU DG TAXUD), to clarify issues and develop workable rule sets

EU TAXUD implementing and delegating acts

EU is ahead of other PLACI regimes, and is developing MS IA and DA for effect in 2016. Combines customs and CAA measures in single procedure. Challenge for industry to implement. Difficult for transit cargo thru EU states with different IA timelines. Rule set language remains confusing

RA’s, PAX and Cargo carriers, postal operators, GH, Forwarders

RA’s, PAX and Cargo carriers, postal operators, GH, Forwarders may incur Shipment delays, high costs to implement with different MS at different times.

Coordinating with other industry Assns. to pressure DG TAXUD to revise and modify language in IA, DA as well as transitional programs, and include industry in further discussions before sending regulatory language for EU Parliamentary proceedings

Follow up on letters to EU (July), further meetings and discussions in accord with others. Next meetings planned for October but prelim discussions in September

TSA all-cargo program

Interim program was issued in early 2015. TSA did not include simplified procedures as requested by industry, or include risk-based measures as discussed

Program remains unwieldy and confusing, requires multiple amendment to accommodate different modes

Cargo and express carriers, forwarder/RA’s will be better able to transfer shipments between modes utilizing same or similar training methods, reducing operational costs

Working with TSA to help develop language to include measures described

Ongoing discussions with TSA and through the ASAC cargo subcommittee, headed by TIACA

Private canine screening

Most cargo screening by canines performed by Govt operated units. Resources are limited, and restricted in most cases to “on airport” screening at carriers

Enabling privately operated (and regulated) canine teams provides for more efficient screening, off airport, by other authorized parties, and enable screening of larger (skid/ULD) configurations more efficiently


Airlines, forwarders, GH and postal operators

Airlines, forwarders, GH and postal operators can screen larger configurations based on their own schedule and reduce cost by screening larger configurations

Primarily a TSA issue, but can be implemented elsewhere. Working with TSA Operations, Legal and Technology units to design program and gain approval

Ongoing, long term, both 1:1 with TSA, and via ASAC committee discussions

DHS ACAS rule sets

ACAS pilot risk algorithms in place since 2012, will need modification when pilot moves to regulatory language to align with CAA programs

Changes to rule sets may result in higher percentage of cargo targeted for higher risk screening measures.


RA’s, forwarders, all airlines, GH

RA’s, forwarders, all airlines, GH may see a higher number of shipments referred, and incur higher operating costs as well as cost for additional equipment

Working with TSA and CBP to outline industry concerns and recommendations.

Continue discussions

US EPA rulemaking on aircraft emission standards

US will issue draft regulation for industry and public comment, regarding decreasing emissions on new aircraft

All industry segments

Potentially higher cost of operations

Issue response to EPA draft, collaborate with other industry groups

Due by September

Paperless standards for US security programs/alignment

US regs allow some e-reports, but have not arrived at standards. Have not fully adopted E-CSD

RA, all carriers

RA, all carriers will be able to reduce cost of maintaining records and streamline procedures

Working with TSA to define acceptable formats

Ongoing discussions



Lithium Batteries

Testing has increased concerns about potential fires from lithium battery shipments. ICAO is considering additional restrictions. Boeing recently issued guidance suggesting they not be carried on PAX.



Ground handlers




Air carriage of lithium batteries is significant. Changes to the rules could affect virtually the entire sector. Boeing’s guidance and possible additional actions have the potential to dramatically alter current practice.

Has participated in US regulatory and legislative process. Programmed this subject for ES/AGM 2015. We have tracked ICAO’s ongoing work. We are currently assessing next steps.

Dialog ongoing within Security and Safety Subcommittee (with representation from Boeing). Subcommittee will assess next steps and possible TIACA initiatives



Air Cargo R&D

There is a dearth of screening technology geared to the air cargo environment. This limits efficiency, impedes commercial flows, and creates security gaps.



Ground handlers





Screening parties (forwarders, airlines, etc.) have limited options and must structure their operations to the types of screening equipment that are available.

We have called for R&D geared to the cargo environment. We are leading this effort through our work on ASAC and through chairing the ASAC Air Cargo Subcommittee.

ASAC Air Cargo Subcommittee is setting up a special working group on this subject.


E-Commerce Initiatives


The industry has been too slow to adopt e-commerce solutions, including e-AWB and e-freight.




Ground handlers

Software vendors


E-commerce adaptations will have a major impact on the future of the air cargo industry.

Produced the e-commerce Scorecard.

Seeking e-commerce success stories.

Subcommittee to review/revise/update Scorecard. Secretariat to determine how to make it more broadly interactive. Subcommittee to determine next priorities.




While a wide range of transportation and communication infrastructure deficiencies can slow air cargo, the most critical are generally inadequate airports, bad roads, and aging air traffic control systems.



Ground handlers

Infrastructure gaps and bottlenecks limit air cargo’s speed advantage and competitiveness

Published TIACA position paper.

Support NextGen/Single European Sky.



Emissions/carbon footprint

The aviation industry remains a target for emissions limits/reductions.

All industry participants.

Emissions caps, reductions or trading schemes could affect the economics of air cargo transactions.

We have taken targeted actions, e.g. comments to EPA regarding an aircraft emissions standard.

To be evaluated by the Environment and Infrastructure Subcommittee.



Air cargo traffic rights

Currently, aviation market access negotiations are conducted as a package (passenger and cargo rights). Often, cargo issues are settled quickly, but cargo routes cannot be liberalized until PAX issues are settled. This delays cargo liberalization.



Ground handlers


A new approach allowing more rapid conclusion of air cargo agreements could open new routes (“highways in the sky”).

Papers presented to ICAO’s Air Transport Symposium.

Liaise with ICAO working group members to determine status.



Trade facilitation via trade negotiations

Various trade negotiations offer opportunities to obtain trade facilitation commitments.



Ground handlers

Modernized customs procedures could enhance air cargo’s speed advantage.

Under review

Under evaluation by Market Access and Trade Facilitation Subcommittee.



Single window/customs automation

Single window systems and customs automation would facilitate international air cargo transactions.



Ground handlers

Could increase the speed and reduce the cost of global air cargo transactions.

General support for Single Window/automation. Evaluating engagement on US export manifest pilot.

Under evaluation by Market Access and Trade Facilitation Subcommittee.



Intellectual property rights (IPR)

Customs authorities are increasing interdiction of IPR-infringing goods. In some cases, they may seek assistance from intermediaries, such as carriers and forwarders, or even seek to levy penalties on them.




Customs actions could impose new burdens (legal, operational, and commercial) on carriers and forwarders.

Possible TIACA position paper under consideration.

Being evaluation by Market Access and Trade Facilitation Subcommittee.


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