CBP AMENDS AIR CARGO ADVANCE SCREENING REGULATIONS
December 8, 2025
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On November 21, 2025, U.S. Customs and Border Protection published an interim final rule amending regulatory requirements for the Air Cargo Advance Screening (“ACAS”) program. While inbound air carriers and other eligible filers were already required to transmit specified air cargo data through ACAS as early as practicable (i.e., no later than loading of cargo onto aircraft), CBP determined that existing regulations were inadequate to successfully identify certain high-risk air cargo. To address new and emerging air cargo threats, ACAS requirements were modified to require inbound air carriers and other eligible filers to submit additional data elements. In addition to existing requirements, new mandatory and conditional data elements implemented by the interim final rule include the following:
- Consignee email address (mandatory)
- Consignee phone number (mandatory)
- Shipment packing location and/or scheduled shipment pickup location (mandatory)
- Ship to party (mandatory)
- Verified Known Consignor (conditional)
- Shipper email address (conditional)
- Shipper phone number (conditional)
- Customer account name (conditional)
- Customer account issuer (conditional)
- Customer account number (conditional)
- Customer account shipping frequency/volume (conditional)
- Customer account establishment date (conditional)
- Customer account billing type (conditional)
- Unmasked internet protocol address or media access control address of the device used during account creation (conditional)
- Unmasked internet protocol address or media access control address of the device used to initiate the shipping transaction and the unmasked IP address, or MAC address of the device used to file the ACAS filing each time an ACAS filing is submitted (conditional)
- Shipping cost (conditional)
- Biographic data (conditional)
- Link to product listing (conditional)
To provide sufficient time for regulated entities to comply with the new data elements, CBP will exercise enforcement discretion for 12 months after the effective date so long as inbound air carriers and other eligible ACAS filers make good-faith efforts during that time to comply. In other words, inbound air carriers and other eligible filers should work diligently over this 12-month period. to update their policies, procedures, and technology so that they can begin transmitting enhanced ACAS data elements in accordance with new requirements. When phased enforcement concludes on November 21, 2026, CBP will take prompt enforcement action against inbound air carriers and other eligible filers who fail to submit the enhanced ACAS data elements. Interested parties are encouraged to submit comments on the interim rulemaking by January 20, 2026.
Eckert Seamans’ Aviation Blog is intended to keep readers current on developments in the law. It is not intended to be legal advice. If you have any questions, please contact Evelyn Sahr at 202.659.6622 or esahr@eckertseamans.com; Drew Derco at 202.659.6665 or dderco@eckertseamans.com; Jay Julien at 202.659.6648 or jjulien@eckertseamans.com; Tyler Myers at 202.659.6642 or trmyers@eckertseamans.com, or any other attorney at Eckert Seamans with whom you have been working.
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