Executive Summary
US Customs and Border Protection’s Enhanced Air Cargo Advance Screening (ACAS) program, published in the Federal Register on November 21, 2025, substantially expands data requirements for inbound air cargo to the United States. New mandatory and conditional data elements provide CBP and TSA enhanced capabilities for risk assessment and threat identification before aircraft loading. Understanding these requirements, particularly the strategic importance of Verified Known Consignor status, enables air cargo stakeholders to develop effective compliance strategies balancing security objectives with operational efficiency.
Enhanced ACAS: Navigating Expanded Air Cargo Security Requirements and Compliance Strategies
(增强型ACAS：应对扩大的航空货运安全要求与合规策略)
1 · ACAS Program Background and Enhancement Context
The Enhanced ACAS program represents evolution of existing air cargo security framework addressing emerging threats and vulnerabilities in international aviation cargo systems.
Original ACAS Foundation
Program Establishment: The Air Cargo Advance Screening program became mandatory on June 12, 2018, requiring advance submission of cargo information for shipments arriving in the United States from foreign locations.
Security Objectives: ACAS enables CBP and Transportation Security Administration to conduct targeted risk assessments identifying high-risk cargo before aircraft loading. Early assessment supports Do-Not-Load instructions or additional screening requirements preventing security threats from reaching US-bound aircraft.
Operational Framework: Participating air carriers and other eligible parties transmit cargo data to CBP systems before departure. CBP analyzes submitted information using risk-based targeting algorithms producing disposition decisions including proceed to load, request additional information, or do not load instructions.
Enhancement Drivers
Threat Evolution: Ongoing aviation security threats and emerging vulnerabilities necessitate enhanced screening capabilities:
Specific Incidents: Incendiary devices causing fires at European air cargo facilities in July 2024 demonstrated continuing threats to air cargo supply chains, informing CBP’s decision to enhance ACAS requirements.
E-Commerce Growth: Explosive growth in cross-border e-commerce creates challenges for traditional security frameworks as millions of small parcels enter international air cargo systems from diverse, often unknown shippers.
Supply Chain Complexity: Modern air cargo supply chains involve numerous intermediaries, digital platforms, and business models creating opacity that traditional data elements inadequately address.
Regulatory Authority
Legal Foundation: Enhanced ACAS requirements derive from CBP’s authority under various statutes including Trade Act of 2002 Section 343(a), Aviation and Transportation Security Act Section 109, and related provisions establishing CBP and TSA security responsibilities.
Rulemaking Process: The Enhanced ACAS rule underwent formal rulemaking including proposed rule publication, public comment period, and final rule development incorporating stakeholder feedback.
2 · New Mandatory Data Elements
Enhanced ACAS establishes several data elements required for all shipments regardless of shipper characteristics or circumstances.
Consignee Contact Information
Email Address Requirement: All ACAS submissions must include consignee email address at lowest air waybill level.
Telephone Number Requirement: Consignee phone number is similarly required for all shipments.
Operational Rationale: These contact data elements enable CBP to better identify parties involved in shipments and facilitate direct communication during security events or cargo holds. Rapid communication capability supports efficient exception resolution and emergency response.
Data Quality Considerations: Contact information must be accurate and current. Systematic validation of email addresses and phone numbers during booking processes helps ensure data quality supporting effective CBP communication when needed.
Location Information
Packing and Pickup Locations: Filers must provide either shipment packing location or scheduled pickup location (or both if available).
Distinction from Shipper Address: These location elements identify where cargo was physically prepared for transportation, which often differs from shipper’s corporate or billing address appearing on documentation.
Risk Assessment Value: Precise origin location information enhances CBP’s ability to assess geographic risks, identify patterns, and target resources effectively. Understanding actual cargo origin supports more sophisticated risk modeling than shipper business address alone provides.
Implementation Approach: For shipments picked up at shipper facilities, pickup location may coincide with shipper address. For shipments delivered to consolidation facilities, packing location identifies where final packaging occurred before acceptance by carrier.
Ship-to Party Information
Definition and Requirement: Ship-to party represents name and address of first deliver-to party scheduled to physically receive shipment after CBP release.
Distinction from Consignee: Ship-to party may differ from consignee listed on air waybill. Consignee might be freight forwarder, customs broker, or other intermediary, while ship-to party is ultimate physical recipient.
Supply Chain Transparency: Identifying actual physical recipient reduces ambiguity in supply chains and supports more accurate risk assessment. Understanding who actually receives goods provides intelligence value beyond party paying for transportation or clearing customs.
3 · Verified Known Consignor Framework
The most strategically significant Enhanced ACAS element is the Verified Known Consignor designation providing compliance pathway substantially reducing data requirements.
Known Consignor Concept
Security Vetting: Verified Known Consignor status indicates shipper has undergone rigorous security vetting by recognized authority and maintains security practices meeting established standards.
Program Recognition: CBP recognizes specific security programs as conferring Verified Known Consignor status including European Union Known Consignor program and TSA’s Known Shipper program. Additional programs may receive recognition through CBP evaluation processes.
Registration Information: When shipper qualifies as Verified Known Consignor, ACAS filer transmits associated registration number and CBP-specified code identifying designating authority.
Strategic Compliance Advantage
Reduced Data Burden: Shippers achieving Verified Known Consignor status typically avoid requirements to provide most Enhanced ACAS conditional data elements. This substantial compliance simplification reduces data collection burden, system complexity, and operational costs.
Risk-Based Approach: The Known Consignor framework embodies risk-based security philosophy focusing enhanced scrutiny on shipments from unknown or unvetted parties while streamlining processes for vetted, trusted shippers.
Incentive Structure: By creating significant compliance advantages for Known Consignor status, regulations incentivize shippers to undergo security vetting and maintain required security standards benefiting overall supply chain security.
Qualification Pathways
EU Known Consignor: European shippers participating in EU aviation security regulatory framework can achieve Known Consignor status through national civil aviation authorities. This status provides regulatory recognition supporting international cargo operations.
TSA Known Shipper: US-based shippers and certain foreign entities may qualify for TSA’s Known Shipper program through security vetting processes. Program participation demonstrates commitment to aviation security standards.
Program Development: Additional pathways to Verified Known Consignor recognition may emerge as CBP evaluates other national and international security programs meeting established criteria.
4 · Conditional Data Elements for Non-Verified Shippers
For shipments from shippers lacking Verified Known Consignor status, Enhanced ACAS requires numerous additional data elements providing detailed supply chain visibility.
Customer Relationship Information
Account Data: ACAS filers must provide information detailing business relationship with shipper including customer account name, account issuer, account number, and critically, account establishment date.
Relationship Duration: Account establishment date enables CBP to assess relationship maturity. Long-standing customer relationships generally indicate lower risk than newly-established accounts potentially created for malicious purposes.
Data Availability: For logistics providers with robust customer relationship management systems, these elements may be readily available. Others may need system enhancements to capture and maintain required data.
Shipping Pattern Characterization
Frequency and Volume Categories: Filers must categorize each shipper’s activity using standardized codes:
Shipping Outlet/Walk-In: Individual presenting shipment at retail location without established account relationship.
Immediate Transaction: Customer initiating shipment through immediate online transaction without prior relationship history.
Occasional Shipper: Customer shipping infrequently, perhaps monthly or quarterly.
Regular/Daily Shipper: Customer maintaining consistent shipping activity with predictable patterns.
High-Volume Shipper: Customer generating substantial shipment volumes indicating established commercial operations.
Risk Correlation: Shipping pattern characterization supports risk assessment as established, high-volume shippers generally present lower risk than walk-in or immediate transaction shippers lacking relationship history.
Digital Device Information
IP and MAC Addresses: For certain circumstances, Enhanced ACAS requires unmasked Internet Protocol addresses or Media Access Control addresses of devices used in various transaction stages:
Account Creation: For accounts established after Enhanced ACAS effective date, IP or MAC address of device used during account creation process.
Transaction Initiation: For low-frequency or immediate transactions, IP or MAC address of device used to initiate shipping transaction.
ACAS Filing: For applicable transactions, IP or MAC address of device used to submit ACAS filing.
Security Intelligence Value: Device addressing information provides digital fingerprints supporting pattern analysis, device tracking across transactions, and identification of anomalous activities potentially indicating security threats.
Privacy Considerations: While IP and MAC addresses provide security value, collection and transmission raise privacy considerations requiring appropriate data handling, security, and retention policies.
Financial Transaction Information
Shipping Cost Reporting: For low-frequency or immediate transactions, filers must report shipping cost in US dollars.
Transaction Analysis: Shipping cost information enables CBP to assess whether charges align with shipment characteristics and shipper profile. Unusual cost patterns may indicate fraudulent activity or other concerns.
Currency Conversion: When transactions occur in foreign currencies, filers must convert to US dollars for reporting purposes using appropriate exchange rates.
Biographic Data Requirements
Walk-In Shipments: For shipments accepted at retail locations from walk-in customers, filers must collect biographic data from government-issued photo identification:
Required Elements: Name, date of birth, identification document type, and identification number from CBP-approved government-issued photo ID.
Document Retention: CBP may require filers to retain copies of identification documents for three years upon prior notification. This retention requirement supports investigative capabilities for shipments later identified as problematic.
Personal Effects: Similar requirements apply to shipments containing household goods or personal effects regardless of how tendered.
E-Commerce Specific Elements
Product Listing Information: When consignees initiate shipments through internet stores or online marketplace platforms, filers must provide link to product listing (URL or SKU) and unmasked IP or MAC address of device used by consignee to purchase product.
Marketplace Visibility: These elements provide CBP visibility into e-commerce transaction origins enabling assessment of seller legitimacy, product descriptions, and platform oversight.
Platform Cooperation: Effective implementation may require cooperation from e-commerce platforms providing data access to shippers and logistics providers for ACAS submission purposes.
5 · Encouraged Optional Data Elements
Beyond mandatory and conditional requirements, CBP encourages submission of additional data elements when available supporting enhanced risk assessment.
Commodity Classification
Harmonized Tariff Schedule: CBP encourages reporting commodity codes at HTS-10 digit level providing detailed product classification information.
Risk Targeting Value: Detailed commodity information supports product-specific risk assessment identifying shipments warranting additional scrutiny based on commodity characteristics and associated threat profiles.
System Integration: Many organizations already classify commodities for customs purposes. Extending this classification to ACAS submissions requires system integration enabling data flow from classification systems to ACAS filing processes.
Financial and Transactional Information
Declared Value: Reporting shipment declared value provides additional data point for risk assessment and fraud detection.
Transaction Type: Identifying transaction characteristics such as consumer-to-business, business-to-business, or other types provides context supporting risk evaluation.
Special Handling and Compliance
Dangerous Goods: Special handling codes or dangerous goods identifiers alert CBP to shipments requiring particular attention or following specific safety protocols.
Shipper Credentials: Manufacturer Identification codes, Authorized Economic Operator numbers, or other recognized credentials provide additional verification of shipper legitimacy and security practices.
Strategic Submission
Voluntary Enhancement: While optional elements aren’t required, their submission may expedite ACAS disposition by providing CBP more complete information for risk assessment.
Competitive Advantage: Logistics providers systematically capturing and submitting optional elements may achieve faster processing and fewer holds compared to competitors providing only minimum required data.
6 · Implementation Timeline and Phased Enforcement
Enhanced ACAS implementation follows structured timeline balancing security needs with practical compliance challenges.
Effective Date and Enforcement
Rule Publication: Enhanced ACAS rule published November 21, 2025, establishing regulatory requirements and compliance obligations.
Phased Enforcement: CBP provides 12-month phased enforcement period allowing industry time for necessary business process changes and technical system modifications.
Progressive Compliance: During phase-in period, CBP focuses on education and technical assistance while gradually increasing enforcement expectations enabling systematic compliance development.
System Development Requirements
Technical Modifications: Air carriers, freight forwarders, and other ACAS filers require system modifications to:
Data Collection: Implement processes capturing new required data elements from shippers, consignees, and internal systems.
Data Transmission: Modify ACAS submission systems transmitting expanded data sets in required formats meeting CBP technical specifications.
Quality Assurance: Establish validation and quality control processes ensuring data accuracy and completeness before submission.
Business Process Adaptation
Customer Communication: Stakeholders must communicate new requirements to shipping customers explaining data elements needed and collection processes.
Training Programs: Staff require training on Enhanced ACAS requirements, data collection procedures, and system operations supporting compliant processes.
Documentation Updates: Terms and conditions, privacy policies, and related documentation require updates reflecting Enhanced ACAS data collection and usage.
7 · Compliance Strategy Development
Effective Enhanced ACAS compliance requires strategic approaches balancing security objectives, operational efficiency, and cost management.
Technology and Automation
System Integration: Automated data collection and transmission minimize manual effort and improve accuracy:
Customer Portals: Booking platforms and customer portals should capture required data elements during shipment initiation reducing subsequent data gathering burden.
API Integration: Connections with carrier systems, platform providers, and other stakeholders enable automated data exchange improving efficiency and reducing errors.
Validation Logic: Built-in validation rules identify missing or problematic data before submission preventing rejections and delays.
Known Consignor Promotion
Customer Engagement: Proactively encouraging customers to achieve Verified Known Consignor status benefits all parties:
Reduced Burden: Known Consignor status eliminates most conditional data requirements substantially reducing data collection and submission complexity.
Improved Efficiency: Streamlined processes for Known Consignor shipments reduce processing time and operational costs.
Marketing Approach: Logistics providers can actively market Known Consignor benefits encouraging customer participation in recognized programs.
Data Management and Privacy
Secure Handling: Enhanced ACAS data includes sensitive information requiring appropriate security:
Data Protection: Technical and organizational measures protect personal information, financial data, and business intelligence from unauthorized access or disclosure.
Retention Policies: Clear policies govern data retention periods balancing regulatory requirements, business needs, and privacy principles.
Access Controls: Appropriate access restrictions limit data visibility to authorized personnel with legitimate business needs.
8 · Cost-Benefit Analysis and Industry Impact
Enhanced ACAS implementation creates costs for industry while delivering security benefits protecting aviation and commerce.
Compliance Costs
System Development: Technical system modifications, integration work, and testing create substantial one-time costs for ACAS filers.
Operational Expenses: Ongoing costs include additional staff time for data collection, increased customer service requirements, and system maintenance.
Industry Estimates: CBP estimates total net cost ranging from $877 million to $1.04 billion over 10-year evaluation period reflecting substantial industry investment in enhanced security.
Security Benefits
Threat Prevention: Enhanced risk assessment capabilities support identification and interdiction of security threats before aircraft loading.
Intelligence Value: Expanded data collection provides intelligence supporting broader security efforts including pattern analysis and threat network identification.
Catastrophic Loss Prevention: While difficult to quantify precisely, preventing even single catastrophic aviation security incident justifies substantial investment given potential casualties, economic damage, and supply chain disruption.
Operational Efficiency Considerations
Targeted Screening: More sophisticated risk assessment enables better resource targeting focusing intensive screening on highest-risk shipments while streamlining processing for lower-risk cargo.
Process Improvement: Some Enhanced ACAS elements may support operational improvements beyond security including better shipment tracking, improved customer identification, and enhanced exception management.
9 · International Coordination and Harmonization
Effective air cargo security requires international coordination given global nature of aviation supply chains.
Mutual Recognition
Program Acceptance: CBP recognition of EU Known Consignor and similar programs creates mutual recognition framework supporting international commerce.
Standards Alignment: Coordination on security standards and vetting criteria enables consistent approaches across jurisdictions benefiting global operators.
Expansion Opportunities: Additional mutual recognition arrangements may develop as CBP evaluates other national security programs potentially creating broader Known Consignor network.
Data Sharing and Coordination
Government Cooperation: CBP, TSA, and foreign counterpart agencies coordinate on threat intelligence, risk assessment methodologies, and security best practices.
Industry Standards: International industry organizations work toward standardized approaches to data collection, formatting, and transmission supporting efficient compliance across jurisdictions.
Regulatory Evolution
Continuous Improvement: Air cargo security frameworks will continue evolving as threats change and experience accumulates with Enhanced ACAS implementation.
Stakeholder Engagement: Ongoing dialogue between government authorities and industry stakeholders supports practical, effective security measures balancing protection with operational efficiency.
10 · Conclusion: Strategic Compliance in Enhanced Security Environment
Program Significance
Security Enhancement: Enhanced ACAS represents substantial advancement in air cargo security capabilities providing CBP and TSA improved tools for identifying and interdicting threats before reaching US-bound aircraft.
Industry Commitment: Successful implementation requires significant industry investment in systems, processes, and training demonstrating logistics sector’s commitment to aviation security.
Operational Transformation: Beyond compliance obligation, Enhanced ACAS drives operational changes in data collection, customer interaction, and supply chain visibility potentially yielding broader business benefits.
Strategic Success Factors
Proactive Planning: Organizations beginning early implementation planning gain advantages including system development time, customer relationship development for Known Consignor programs, and competitive positioning during phase-in period.
Technology Leverage: Automated approaches to data collection and transmission provide efficiency advantages while improving accuracy and reducing operational burden particularly for high-volume operations.
Customer Partnership: Collaborative approaches with shipping customers sharing compliance burden, promoting Known Consignor participation, and improving data quality create win-win outcomes.
Long-Term Positioning
Competitive Differentiation: Organizations achieving smooth Enhanced ACAS compliance with efficient processes and minimal customer friction gain competitive advantages in air cargo markets.
Security Leadership: Demonstrating strong security practices and effective compliance positions organizations as trusted partners in international supply chains increasingly concerned with security, compliance, and risk management.
The Enhanced ACAS program represents significant evolution in air cargo security requirements creating both challenges and opportunities for logistics stakeholders. Organizations approaching implementation strategically—with appropriate technology investment, customer engagement, and operational excellence—will successfully navigate compliance requirements while contributing to more secure global air cargo systems protecting aviation and international commerce.
This analysis reflects Enhanced ACAS requirements as published in November 2025 Federal Register notice and available implementing guidance. Specific technical requirements, filing procedures, and compliance expectations may evolve through additional guidance and stakeholder engagement. Organizations subject to ACAS requirements should monitor official CBP announcements and consult with customs compliance specialists and legal advisors regarding specific implications for their operations and appropriate implementation strategies.
