CBP Plans to Start Forwarder Air Cargo Security Pilot, Etc.

(Following the Yemen incidents in October, CBP, the Transportation Security Administration (TSA), and the air cargo industry engaged in constructive dialogue which ultimately led to a greater emphasis being placed on pre-departure data but was aligned within existing air cargo business models.)

After Yemen, CBP Started Pilot Program with Express Consignment Operators

After the October incidents, CBP began to look at what its practice was for processing air cargo in order to reduce the security gap. CBP first began its efforts with an express consignment operator pilot program, as they were the largest group to work with and had the strongest control over the process.

(Last year CBP processed 74 million air cargo shipments into the U.S., on average approximately 202,000 shipments/day. Of those 74 million, about 55 million (74%) were brought in by express consignment operators -- the big four being UPS, DHL, FedEx, and TNT.)

Under Pilot, Carriers Submit 7 Manifest Data Elements Early for Cargo from North Africa, Middle East

Under this new express consignment operator program, the carriers submit seven manifest data elements to CBP electronically through the targeting system for air cargo from 28 countries in North Africa and the Middle East as soon as it is available.² Carriers participating in the pilot provide the following seven data elements on the manifest:

• Shipper name
• Shipper address
• Consignee name
• Consignee address
• Cargo description
• Weight
• Quantity

Under the pilot program, CBP has been receiving the data 24, 36, and even as early as 70 hours in advance of the flight taking off -- much earlier than the current requirement.³

UPS, FedEx, DHL Already Submitting Data, TNT Will Soon

CBP stated that UPS was the first to begin transmitting the data elements, and that these transmissions began in the middle of December. FedEx started at the end of January, DHL at the end of March, and TNT is scheduled to begin transmitting soon (within weeks). CBP noted that it has been bringing the consignment operators in incrementally in order to make sure that its system could handle the data being fed in.

As of April 14, CBP has been able to receive the advance data on over 506,000 air cargo shipments. So far, they have not had to issue a do not load (DNL) since the program began.

After All Express Consignment Operators Participating, to Start Forwarder Pilot

CBP said that after it has all express consignment operators on board and submitting the seven air manifest advance data elements, it will then turn to the passenger/freight forwarders and begin that pilot.

The all-cargo carriers will fall into line within one of the two models -- either the consignment operator model or the passenger/freight forwarder model.

Forwarders and All-Cargo Carriers Handle 26% of Air Cargo Shipments

According to CBP, freight forwarders shipping on passenger carriers and all-cargo carriers handle the remaining 26% of air cargo, and present more challenges. Express consignment operators “own the process from start to finish, by and large,” while air passenger carriers rely heavily on freight forwarders and all-cargo carriers either own the process or rely heavily on freight forwarders.

For the air passenger carrier/freight forwarder or all-cargo/freight forwarder relationship, CBP has examined who is in the best position to provide the data to them earlier in the process.

While air passenger carriers typically receives the cargo about 4 hours before takeoff, freight forwarders obtain the data much sooner, when they are collecting the cargo from different customers. CBP is working on a model that includes engagement with the freight forwarders and the air passenger carriers to determine how CBP can obtain the seven air manifest advance data elements.

Need to Let Pilots Mature, then Want Pilot Programs to Go Global

As CBP moves forward, the intent is to let the express consignment operator and freight forwarder pilots mature. The goal will be to have these programs go global, and timing will be an issue as CBP works to achieve this goal. The official noted that “at some point, this will be rolled out globally in a logical process.”

(See ITT's Online Archives or 12/17/10 news, 10121729, for BP summary of CBP and TSA announcing the pilot programs.

See ITT’s Online Archives or 03/07/11 news, 11030729, for BP summary of a CBP official stating that Commissioner Bersin thinks the way that CBP, TSA and the trade can resolve issues such as the Yemen bomb plot is informally instead of making new laws or involving legislation.

See ITT’s Online Archives or 03/15/11 news, 11031522, for BP summary of TSA officials saying that even 5-10% screening of all-cargo aircraft would be a challenge.)

¹The April 3-6 NCBFAA conference, April 12 COAC meeting, April 13-14 Annual CBP Trade Symposium

²While there are 12 air manifest data elements on the manifest, five of those do not provide a lot of value to CBP from a pre-departure targeting standpoint.

³The Trade Act of 2002 requires the electronic submission of the advance manifest data; for the air environment, manifest data is required 4 hours before the plane lands in the U.S. or wheels up if it is less than a 4 hour flight. According to officials, in order to address risks for shipments before they land in the U.S., they need to have data much earlier in the process.