Air Cargo Security in 2026: ACAS, Screening and Known Consignor Status

Two different rules both get called "air cargo security", and confusing them is one of the most common reasons a shipment sits on the ground. One is an advance data rule: US Customs and Border Protection wants information about your shipment before it is loaded onto the aircraft. The other is a physical screening rule: someone has to x-ray, hand search or otherwise examine the freight before it can fly as secure cargo. Different agencies, different triggers, different consequences when you get them wrong.

This guide sets out what each regime actually requires as of September 2026, with the regulatory citations so you can check any claim here against the source rather than taking it on trust. Both regimes have moved recently. CBP's Enhanced ACAS rule took effect on 21 November 2025 and its enforcement deadline has already been pushed back once. The EU replaces national haulier approvals with a single EU-wide approval on 1 January 2027.

The short version

• ACAS is advance data, not screening. It is filed under 19 CFR 122.48b for cargo flying to the United States, and it has to reach CBP before the cargo is loaded onto the aircraft.
• The mandatory ACAS data set grew from six elements to ten on 21 November 2025.
• Full enforcement of the new elements is 1 May 2027, not November 2026. CBP extended the phased period, and a lot of published guidance still quotes the original date.
• Verified Known Consignor status switches off thirteen conditional data elements. This is the most commercially useful and least discussed part of the rule.
• Physical screening is a separate regime with its own rules: TSA programmes on the US side, and a regulated agent and known consignor chain in the EU.
• The account consignor no longer exists. ICAO phased it out by 30 June 2021, and the EU rewrote its consignment security statuses in 2022 to match.

Advance data and physical screening are not the same thing

Before anything else, separate the two. A shipment can be perfectly screened and still be refused loading because the ACAS filing was late or incomplete. It can also have a clean ACAS response and still be unable to fly because nobody applied a recognised screening method to it.

The rest of this guide takes them in that order.

ACAS: what it is and where it comes from

The Air Cargo Advance Screening programme requires that specified data about US-bound air cargo reaches CBP early enough for a risk assessment to happen before the aircraft is loaded. CBP then either says nothing, asks for more information, or issues a Do Not Load instruction.

Two points about its legal status are widely misreported and worth stating plainly.

The correct citation is 83 FR 27380, published 12 June 2018. A different number circulates in freight content and in some training material. The rule is codified at 19 CFR 122.48b.

ACAS has never been a final rule. The 2018 measure was an interim final rule with a request for comments, which closed on 13 August 2018. CBP never issued a final rule off the back of it. When CBP amended the programme in November 2025, it did so through another interim final rule, at 90 FR 52796, with a fresh comment period that closed on 20 January 2026. So the programme has been running on interim rules for over eight years and through two comment periods. If a document you are reading calls ACAS a final rule, it is wrong, and that is a reasonable signal to check its other claims too.

The enforcement date has already moved

The Enhanced ACAS interim final rule took effect on 21 November 2025, and CBP said it would exercise enforcement discretion for twelve months, which put full enforcement at 21 November 2026.

That is no longer the date. CBP has extended the phased enforcement period to run from 21 November 2026 to 1 May 2027, announced through its Cargo Systems Messaging Service. Most published summaries of the rule, including several written after the extension, still quote November 2026. If you are planning a compliance project around the original date, you have roughly five and a half more months than you think, and if you are being sold urgency on the November date, that urgency is out of date.

The ten mandatory ACAS data elements

Under 19 CFR 122.48b(d)(1), ten elements are required at house air waybill level. Six of them are the original set. Four were added by the Enhanced ACAS rule.

Two things follow from that table that shippers routinely miss.

First, "seven minimum elements" is two revisions out of date. It is a stubbornly common figure in freight content and it has not been right for some time.

Second, three of the four new elements are things only the shipper knows. Your forwarder cannot invent a packing location, and it cannot supply a consignee email address that you never gave it. The practical effect of the Enhanced ACAS rule is that a booking which used to be filable from the air waybill alone now needs information that has to come from you. If your bookings currently travel with a bare consignee name and a company switchboard number, that is the gap to close before May 2027.

Ship to party is not always the consignee

Worth calling out separately, because it is the element most likely to be filled in wrongly out of habit. The consignee is the party the shipment is consigned to on the air waybill. The ship to party is where the goods are actually going. On a drop-ship, a fulfilment-centre delivery or an order routed through a buying agent, those are different addresses, and CBP asked for the second one precisely because it was not already captured. Copying the consignee into both fields defeats the point of the amendment.

The Verified Known Consignor shortcut

This is the part of the rule that has real commercial value and gets almost no coverage.

Beyond the ten mandatory elements, 19 CFR 122.48b sets out a set of conditional elements:

• The master air waybill number, under 122.48b(d)(2), required in three defined situations and encouraged otherwise.
• If the shipper holds Verified Known Consignor status with a CBP-recognised body, then under 122.48b(d)(3) the filing carries the registration number for that status plus a CBP-specified code identifying the designating body. That is two fields.
• If the shipper does not hold that status, 122.48b(d)(4) applies instead, and it runs to thirteen further data elements: four required on every filing, five tied to shipping-frequency codes, two more for shipping outlet, walk-in, immediate and occasional codes, and two required only in defined situations.

Read those together and the trade is explicit in the regulation itself. A Verified Known Consignor supplies two fields. Everyone else supplies thirteen, and several of the thirteen are genuinely intrusive: device identification data, customer account details, biographic information, product listing links.

For a business shipping to the United States by air at any volume, that is a concrete reason to pursue the status rather than a compliance box to tick. It is also a reason to ask your forwarder a direct question: are they filing us as a Verified Known Consignor, and if not, why not? A forwarder that cannot answer is filing thirteen elements on your behalf that it may be guessing at. Our guide to the credentials you can check yourself covers how to test claims like this rather than accept them.

When ACAS has to be filed

The trigger is set out at 19 CFR 122.48b(b)(1), and the wording is worth quoting because paraphrases of it are usually wrong. ACAS data must be submitted:

as early as practicable, but no later than prior to loading of the cargo onto the aircraft

Under 122.48b(b)(2), the data must then be updated if it changes or becomes more accurate, up until the time frame in 19 CFR 122.48a(b).

Three corrections follow.

There is no "at the last foreign port" rule. That phrase appears nowhere in 19 CFR part 122 subpart E. It circulates widely and it is not the standard.

The hours-before deadlines belong to a different rule. If you have seen four-hour or wheels-up deadlines quoted for air cargo, those come from the separate advance electronic air cargo data requirement at 19 CFR 122.48a, which serves customs entry purposes rather than pre-loading security. ACAS and 122.48a are two filings with two different clocks, which is exactly why 122.48b(d)(2) makes the master air waybill number conditional on whether the same party is doing both.

"As early as practicable" is an obligation, not a courtesy. Filing at the last possible moment before loading is compliant on its face, but it removes the time in which a CBP referral could be answered without the shipment missing the flight. Every referral answered on the ramp is a filing that should have gone earlier.

Physical screening in the United States

Screening is TSA territory rather than CBP's, and the milestone that matters for international freight is 3 December 2012, when 100% screening became mandatory for cargo carried on international inbound passenger aircraft. Domestic passenger-aircraft cargo had reached that point earlier.

For cargo leaving the United States, the practical mechanism is the Certified Cargo Screening Program. It lets shippers, indirect air carriers and independent screening facilities screen cargo upstream, so it arrives at the airline already secure rather than queueing for carrier screening at the airport. For anything palletised or awkward, upstream screening is usually the difference between flying today and flying tomorrow, because a built pallet that has to be screened at the airline is a pallet that gets broken down.

One expiry that still catches shippers out: TSA's temporary "Impractical to Screen" amendments expired in October 2023. Cargo that used to move under an ITS exemption now has to enter the supply chain through the CCSP or be screened by the air carrier. There is no longer a category of freight that is simply too difficult to screen.

How you pack determines how painful screening is. Dense, uniform, well-documented pallets clear x-ray; mixed consolidations with unlisted contents get opened. Our guide to export packaging and palletisation covers the build side of this, and the ULD types and dimensions reference covers what the unit has to fit into afterwards.

Physical screening in the European Union

The EU builds security into the supply chain rather than concentrating it at the airport. A consignment can arrive secure because it came from a known consignor whose own premises and procedures are approved, or it can be screened by a regulated agent. Either way the consignment carries a security status and a stated reason for it.

The account consignor is gone, and the term still turns up

There used to be a third route. An account consignor was a shipper whose procedures were good enough for its cargo to fly on all-cargo and all-mail aircraft only, without approval by the national authority. That route no longer exists.

The ICAO Council decided in 2016 that account consignors not subject to approval by the appropriate authority should be phased out within five years and at the latest by 30 June 2021, notified through State Letters AS 8/2-16/85 and AS 8/2-20/126. The deadline was explicitly confirmed as unchanged despite COVID-19. The reasoning was straightforward: the account consignor was never a concept under ICAO Annex 17 in the first place. What remains is known consignor status, unknown-consignor cargo subject to 100% screening, or an entity approved by the authority.

The EU implemented this in Commission Implementing Regulation (EU) 2022/1174, which applies from 1 July 2022. Point 13 of that regulation replaced Annex point 6.3.2.6(d), and the replacement text offers only two consignment security statuses:

• SPX: secure for passenger, all-cargo and all-mail aircraft.
• SHR: secure for passenger, all-cargo and all-mail aircraft in accordance with high-risk requirements.

The old third status, SCO (secure for all-cargo and all-mail aircraft only), is not in the replacement text. That was the lane account consignors fed, and it went with them. Note the mechanism: because the amendment rewrote the whole point rather than issuing a deletion instruction naming "account consignor" or "SCO", a keyword search of the amending regulation finds neither term. That is a large part of why both are still quoted in circulating guidance and in some older training material. There is now no all-cargo-only security lane in the EU.

Approved screening methods, including the one people think is banned

Point 6.2.1.1 sets the governing principle: the means or method most likely to detect prohibited articles shall be employed, taking into consideration the nature of the consignment. Point 6.2.1.5 then lists the approved methods.

Metal detection is an approved cargo screening method. A persistent belief in the industry says otherwise. The prohibition people are remembering applies to hold baggage, not to cargo. Under point 6.2.1.6, alternative security controls are available only where none of the listed methods can be applied owing to the nature of the consignment, so the list above is the working set, not a menu of preferences.

The EU haulier change on 1 January 2027

This is the nearest deadline in this guide and the one most likely to affect a shipper who has never thought about aviation security at all.

Moving secured air cargo by road between premises is itself a regulated activity, and until now hauliers have been approved nationally. Under Regulation (EU) 2015/1998 point 6.1.4, as amended by Commission Implementing Regulation (EU) 2024/1255, that changes:

• Existing national approvals lapse on 31 December 2026.
• From 1 January 2027, any haulier carrying secured air cargo or air mail must hold an EU approval and be listed in the Union database for supply chain security.
• The haulier must put its staff through background checks appropriate to their role, appoint a trained security manager, and give initial and recurrent security training to staff who transport or can access secured consignments.

The failure mode is easy to picture: a road leg booked in January 2027 with a haulier whose national approval quietly expired at the end of December, and cargo that consequently loses its secure status and has to be screened again. If any part of your European air freight moves by road between a known consignor site, a regulated agent and an airport, that is a question to put to your forwarder before the end of 2026. If you are not sure who is actually performing that leg, the difference between a 3PL, a forwarder, a broker and a carrier is the place to start.

Six claims about air cargo security that are wrong

Each of these circulates widely. Each is contradicted by the primary source.

What to actually do

1. Fix your booking data before May 2027. Consignee email, consignee phone, packing or pickup location and ship to party now have to be right at booking. These come from you, not your forwarder.
2. Stop copying the consignee into the ship to field. If the goods physically go somewhere else, say so.
3. Ask about Verified Known Consignor status. Two fields against thirteen is a real difference, and several of the thirteen involve data you may prefer not to hand over.
4. File early rather than at the loading cut-off. The margin you leave is the margin you have to answer a referral in.
5. Screen upstream where you can. A pallet screened at the airline is a pallet that may be broken down.
6. Check your European road legs before 31 December 2026. National haulier approvals lapse that day.
7. Distrust undated compliance content. Both regimes changed within the last twelve months, and most of what is published about them predates the change.

Where this fits with the rest of your paperwork

ACAS is a security filing, not a customs entry, and it does not replace anything else you already do. The commercial and transport documents still have to be right, and customs clearance still happens on its own track with its own data. If your goods are also subject to export controls, restricted party screening is a third, separate obligation that no amount of aviation security compliance discharges. For the acronyms in this guide and the several hundred others in freight, the freight abbreviations reference is the fastest way in.

And if air turns out to be the wrong mode once you have priced the security and handling overhead into it, sea-air freight is the middle option worth costing before you commit.

Getting help from a forwarder who handles this daily

Air cargo security is a specialism. A forwarder that files ACAS every day knows which of the thirteen conditional elements your shipment will actually trigger, whether upstream screening is available at your origin, and which hauliers on your European road legs have their EU approval in hand. That knowledge is not evenly distributed, and it is worth asking about directly rather than assuming.

You can browse air freight specialists by country in the CargoLinked directory, or post a freight request and describe the lane, the commodity and the security constraints so that the quotes you get back are priced against what your shipment actually needs.

Regulatory position stated as of 6 September 2026, checked against 19 CFR 122.48b, Federal Register citations 83 FR 27380 and 90 FR 52796, CBP Cargo Systems Messaging Service notices, ICAO guidance on the phase out of account consignors, and Commission Implementing Regulations (EU) 2015/1998, 2022/1174 and 2024/1255. Aviation security rules change, and several of the dates above moved within the last year. Confirm current requirements with your forwarder or the relevant authority before relying on them for a shipment.