CBP REMINDS CARRIERS OF BIOMETRIC EXIT PROGRAM

September 26, 2025

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On August 27, 2025, U.S. Customs and Border Protection (“CBP”) published a letter reminding Carrier Liaison Program members about biometric entry and exit requirements. Under 8 C.F.R. 103 Subpart B, CBP has authority to conduct biometric operations on flights which includes the capture of photographs of travelers departing the United States at exit locations. Currently, CBP has biometric exit partnerships at 57 locations across the United States. CBP reminds its airline partners that United States citizens may opt-out of biometric collection by requesting alternative processing, which typically involves a manual review of their travel documents by a CBP officer. All non-United States citizens, including crew and pre-boarded passengers, are subject to biometric collection. Notwithstanding, unless a biometric exit is conducted by CBP, non-United States citizens may request to opt-out of the process subject to document check and manual identity verification.

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;  Scott Phillips at 202.659.6689 or sphillips@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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Evelyn D. Sahr Photo Washington, D.C.

Evelyn D. Sahr

Member - Washington, D.C.

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Drew M. Derco Photo Washington, D.C.

Drew M. Derco

Member - Washington, D.C.

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Scott R. Phillips Photo Washington, D.C.

Scott R. Phillips

Member - Washington, D.C.

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Jay Julien Photo Washington, D.C.

Jay Julien

Associate - Washington, D.C.

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Tyler R. Myers Photo Washington, D.C.

Tyler R. Myers

Associate - Washington, D.C.

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