Air Cargo Security Options To Mitigate Costs of Compliance With International Security Requirements - Comments of the Cargo Airline Association

Sep 18, 2026

Comments by the Cargo Airline Association address a Transportation Security Administration (TSA) Request for Information on options to comply with International Civil Aviation Organization (ICAO) international security standards for air cargo. The submission supports providing an alternative to 100% screening for all-cargo air carriers, arguing that cargo assessed as secure through controls in the air cargo supply chain should be exempt. It also proposes additional risk-based, outcome-focused security measures and explains the security context surrounding ICAO standard changes and U.S. program adjustments.

LanguageEnglish

CategoryResearch & Report

FormatPDF

Pages17

Reading Time43 min

AccessFree to download

Introduction

The Security Context

ICAO standards and timelines

Alternatives to 100% screening

BEFORE THE TRANSPORTATION SECURITY ADMINISTRATION ARLINGTON, VIRGINIA Air Cargo Security Options To Mitigate Costs of Compliance With International Security Requirements Docket No. TSA-2020-0001 COMMENTS OF THE CARGO AIRLINE ASSOCIATION Introduction: By publication in the April 10, 2020, edition of the Federal Register (85 Fed. Reg. 20234 et seq.), the Transportation Security Administration (TSA) issued a Request for Information (RFI) asking for public comment on potential options for complying with standards for international security established by the International Civil Aviation Organization (ICAO) .1 The Cargo Airline Association (the Association) is the nationwide organization representing the interests of all-cargo air carriers, as well as other participants in the air cargo supply chain.2 The Association and its members strongly support TSA’s intention to provide an alternative or alternatives to 100% screening to comply with the applicable ICAO standards. The conceptual program outlined in the RFI is one method of achieving this goal and we pledge to work with TSA to provide the information that will allow TSA to move forward with its 1 These Comments were originally due to be filed on or before July 9, 2020 . However, by publication in the June 24, 2020, edition of the Federal Register (85 Fed. Reg. 37958 et seq.), TSA scheduled a public meeting for July 29, 2020, to discuss the concepts set forth in the RFI and postponed the due date for Comments until August 27, 2020 . 2 Association members include ABX Air, Amazon, Atlas Air, DHL Express, FedEx Express, Kalitta Air and United Parcel Service. Many of these members will be filing individual comments herein. concepts. Simply stated, air cargo deemed “secure” because of controls applied in the air cargo supply chain should be exempt from 100% screening by the all-cargo air carriers. In addition, we submit that other risk-based, outcome-focused, security measures can accomplish the same or greater levels of security and should also be part of any alternative frameworks. The Association submits the following comments in support of these thoughts, as well as answers to the specific questions posed by TSA. The Security Context: On September 1, 2016, ICAO notified member states that they should phase out elements of their air cargo security programs that are inconsistent with ICAO Standard 4.6 no later than June 30, 2021 .3 As a practical matter, in the United States this notification means that the existing Account Consignor program for export freight would need to be eliminated for the U.S. to meet the new ICAO standards. Atthe same time, this new ICAO standard does not necessarily mean that 100% of all freight outbound from the United States must be physically screened. On the contrary, ICAO itself sets forth three alternatives to achieve compliance: • Subject all cargo to 100% screening before loading on a commercial aircraft; or • Establish a Known Consignor program for entities that meet certain security standards; or 3 On April 22, 2020, the Association, along with Airlines for America (A4A) and the National Air Carrier Association (NACA) filed a request for TSA to delay implementation of this standard in the United States until June 30, 2022 . This request was formally denied by letter from John Beckius dated August 5, 2020 . ICAO denied a similar request proposed by the Global Express Association (GEA) . These requests were based primarily on the time lost due to the chaotic aviation environment caused by the coronavirus pandemic, a situation that continues unabated today. In addition, since the filing of this extension request, TSA has postponed the due date for Comments herein by approximately seven weeks, making it extremely difficult for TSA to finalize, and industry to implement, the required alternative framework in time to meet the June 30, 2021, deadline. • Establish an alternative framework recognizing an entity other than

FAQs

What request for information does TSA make in this document?

TSA issues an RFI seeking public comment on potential options to comply with ICAO international security standards for air cargo.

What is the Cargo Airline Association’s main position on 100% screening?

The Association supports TSA’s intention to provide alternatives to 100% screening, arguing that secure cargo under supply-chain controls should be exempt.

What alternatives does ICAO provide for achieving compliance?

ICAO outlines options such as 100% screening prior to loading, establishing a Known Consignor program, or using an alternative framework based on security controls for eligible entities.

Sep 18, 2026

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