TAXUD/B2/2013 EU PRECISE. Evaluation Report

Transcription

1 EUROPEAN COMMISSION DIRECTORATE-GENERAL TAXATION AND CUSTOMS UNION Security & Safety, Trade Facilitation & International coordination Risk Management and Security Brussels, 15 November 2013 TAXUD-B2/ (2013) TAXUD/B2/2013 EU PRECISE Evaluation Report This document contains the evaluation report of the EU study on preloading consignment information for secure entry (PRECISE) jointly prepared by the Project group with a view to presenting main results to the Customs Policy Group (CPG) meeting in December Commission européenne/europese Commissie, 1049 Bruxelles/Brussel, BELGIQUE/BELGIË - Tel Office: LX40 04/042 - Tel. direct line

2 I. Introduction Following the EU action plan on Air Cargo Security the EU started testing the feasibility of data submission prior to loading in the different air cargo business models, first with the express industry. The evaluation of the express courier pilot, conducted in 2012, showed that a set of 7+1 data (the so called "raw data") is sufficient for a first layer of security risk analysis for air cargo. Based on the findings of the express courier pilot 1 it was decided to test the feasibility of gathering pre-loading information and the appropriateness of the raw data approach in the traditional air cargo business model (air carriers and freight forwarders). Due to the limited time frame to present results to the Customs Policy Group in December 2013 it was decided that this fact-finding exercise endorsed by the Customs Policy Group, called EU PRECISE, should take the form of a desk top study instead of pilot activities. II. Scope and objective of EU PRECISE The study was conducted in accordance with published Terms of Reference (ToR) 2. The study focused on the questions which entity in the traditional business model has the "raw data" 3 at which point in time in the business process and which entity is able to submit the data to customs early enough and with the sufficient quality to enable Customs to conduct a first layer of security risk analysis. III. Governance/Participation The study was conducted by the customs administrations of eight EU Member States: Belgium, France, Germany, Italy, Luxemburg, Netherlands, Sweden and United Kingdom. Industry representatives: Trade Associations: IATA AEA / FIATA - CLECAT / TIACA / EEA Airlines: 1 Express Pilot Evaluation Report (TAXUD/B2/064/2012), 4 December ToR EU PRECISE vs 30 April, incl. Annex 3 Raw data is a set of 7 data elements (name & address consignor; name & address consignee; goods description; piece count; weight) plus an Identifier, i.e. HAWB number) 2

3 AIR FRANCE, (AF) Air Canada, British Airways (BA), Cargolux (CV), Delta, (DL) KLM/Martinair (KL), Lufthansa Cargo (LH), SAS, (SK) Singapore Airlines (SQ), ALITALIA (AZ). Freight forwarders: DHL Global Forwarding, Expeditors, TLF OVERSEAS, (representing a number of French freight forwarders) DB Schenker (Air/Ocean Freight), Anama, Kühne + Nagel, Logwin Air Ocean, Interline Luftfracht. 4 Other Participants: Cologne Bonn Airport, AOC Fiumicino, Cargonaut (IT service provider), ground handlers. Other Industry stakeholders who did not participate in the study had the opportunity to contribute to the Sections 1, 8 and 9 of the questionnaire. 5 The project group held four meetings between April and November November meeting served to discuss the findings and adopt the evaluation report. The Between the the meetings COM visited two MS (DE, NL) to observe the study activities and conducted bilateral discussions with Industry stakeholders (IATA, CLECAT, AEA). IV. Methodology Although EU PRECISE was intended to be conducted without real time processes, in some cases the study activities closely reached real time levels. Some MS used real cargo information (IATA CARGO IMP messages as FHL, FWB, FZB) from former flights or by automatically sending a copy of the forwarder message to customs (MS analysed thousands of shipments). MS analysed data already available in the supply chain, either by extracting data from operators systems or after receiving data Information currently available in ICS was also used, together with documentation available at arrival. Participants analysed data from several origins worldwide, such as US, Russia, South America, Africa, Asia, and Middle East. Some MS tested flights for which they were not the MS of first entry and consignments transhipping through the EU. Additionally, MS conducted the study by meetings with industry (carrier, freight forwarders), on-site visits of relevant companies, examination of trade documentation and process. As a direct result of the study one MS was actively involved in the drafting of customs security requirements in the Cargo 2000 master operating plan (MOP). 4 MS reported that despite the efforts from CLECAT/FIATA very few SME forwarders were willing or able to join the pilot 5 The reply by American Airlines, United Airlines, Air Canada, Air Canada Rouge, Emirates Airlines was compiled by IATA Customs Advisory Group & Cargo Security Task Force. 3

4 V. EU PRECISE evaluation and results Evaluation indicators were set up in the ToR. The evaluation was performed through a questionnaire which was answered by the PRECISE participants and where applicable by Industry stakeholders who did not participate in the study itself. Participants' answers were generally provided jointly by the participating Member States Customs administrations and the respective industry participants. 1. Findings regarding the Traditional Air Cargo Business Model While the Traditional Air cargo business model is very diverse with regards to the business products, the number and size of parties involved etc., in the vast majority of cases (more than 95%) there are two main parties involved in moving the goods: freight forwarders and carriers (including their ground handlers). Messaging standards There are different established standards for the traders that can support the advance cargo information provision, such as standard messages like IATA CARGO IMP format messages (FWB, FHL,XFZB) which were used by most of the EU PRECISE participants. However, industry participants highlighted that there is no single universally applied standard. Although all airlines message standards being used comply to the WCO data model. As a common denominator in the traditional air cargo business model, air carriers and freight forwarders presented the following jointly agreed high level process overview (based on e-freight / Cargo 2000 processes). 4

5 Importance of non-disclosure agreements (NDA) 6 Non-disclosure agreements are a common business practice, but not systematically in place between forwarders and the carriers. For freight forwarders the shipment data (i.e. shipper, consignee) are commercially sensitive. In the case where an NDA is applicable, the electronic transmission of the shipment data, e.g. FWB and FHL data, is triggered by the completion of the MAWB. This task is usually completed before the truck, delivering the freight to the carrier s warehouse, leaves the freight forwarder s premises. In cases where no NDA was signed bilaterally, only a reduced set of data might be available to the carrier. Latest acceptance time (LAT) A common definition for the time limit for presentation of the consignments and the data by the freight forwarder or shipper before loading or the departure of the aircraft in the traditional air cargo business model is the so-called latest acceptance time (LAT). 6 An NDA - also known as a confidentiality agreement - is a legal contract between at least two parties that outlines confidential material, knowledge or information, that the parties wish to share with one another for certain purposes, but wish to restrict access to or by third parties. 5

6 The LAT is defined and published by the carrier depending e.g. on the product loaded, the characteristics of the location etc. For example some airlines require that physical cargo and documents have to be lodged-in at least 4-6 hrs before departure (STD) Data availability and timeliness prior to loading Availability of the data During the process flow of the traditional air cargo model both the carrier and the freight forwarder have the data necessary for a first layer of security risk analysis, i.e. raw data elements (7+1), but at different points in time. The freight forwarder collects the customer and shipment data that was received from the shipper (upon obtaining the shipper s letter of instruction). The freight forwarder enters the (7+1) data in the (HAWB) and, if using Cargo IMP standards, the FWB/FHL message is subsequently generated. In the latter case, after completing and printing the MAWB, the FHL/FWB is sent by the forwarder before acceptance in the carrier domain. 8 Timeliness of the data The earliest point in time at which all the required data (7+1) are available is upon completion of the HAWB (FHL/XFZB) by the freight forwarder. Participants reported in general that all of the 7+1 raw data are available in standard IATA cargo imp messages and that there is no difference between the data elements with regard to availability. Regarding the goods description one industry participant reported that it depends on the detail level that will be required: it may vary between receipt of the shippers letter of instruction and check-in of physical freight (receipt of accompanying documentation like commercial invoice, packing list etc.) in the freight forwarders warehouse. Late in the study process, the provision of the MAWB number, as an additional data element, was also raised. Several industry participants reported that the MAWB was available at the earliest when preparing the consolidation and at the latest when the consolidation is closed. 9 7 Participants however noted that the LAT is respected but not standardized; for example, in case of exceptions some airlines accept shipments as late as 1 hour to departure depending on the nature of the goods. 8 Some participants mentioned the new IATA standard FZB (through XML format) which is triggered before the consolidation is over thus anticipating the information of the FHL/FWB. This will be in the future the earliest point in time. 9 Some participants did not test this during the study as it was a new raw data element, with focus of the study on the HAWB number. 6

7 Earliest point in time for data submission to Customs 10 The Freight Forwarder can submit the data to Customs upon completing the HAWB and, at the latest at consolidation closing time. One participant reported that full ENS data including conveyance data (as per confirmed carrier booking) would be available at this moment in time for transmission. For Carriers, the earliest point in time to make the raw data available to Customs is when the carrier has received the data by the freight forwarder either electronically (via FWB/FHL or FZB messages) or manually, at the latest at acceptance of the goods. Regarding the percentage of consignments for which either "raw data" or the full enhanced ENS can be submitted to Customs in a certain time slot before loading answers among participants varied greatly. More than 8 hours prior to loading: the results vary between 30 and almost 90 %, one MS participant reported even "virtually %", 4-8 hours prior to loading: results vary between 10-92%, 2-4 hours: results vary between 5 20%, Less than 2 hours: most participants report variances between 2 15%, but two MS report around 30%, Cases in which no data was available prior to loading were deemed exceptional cases, most answers varied between 0-10%. The overall conclusion was that this depends on different factors, as flight routing, origin, commodities, customers, the presence of EDI, products (e.g. express vs. standard), nature of goods. During the study participants took into consideration different business products, such as passenger and all cargo flights, long and short haul flights, transhipments 11, and consignments both destined for and not for the EU. However, there were no significant findings, as the business models and processes are similar. Exceptions Regarding possible exceptions industry participants highlighted that certain goods or business products are delivered very late to the aircraft (e.g. live human organs, material and spare parts for aircrafts on ground (AOG), just-in-time express consignments regardless of them being bulk or unitized), but it is not possible to present an exhaustive list of such goods or business products. Data for organs or AOG will in any cases be available like for any other goods or business products prior to departure of the aircraft. 10 Customs participants stressed that pre-loading data should be sent in one single message when the operators has all of them (not one by one) and are relatively stable - and if possible not be amended - as early as possible to conduct a first layer of security risk analysis. 11 NB: Customs concept of transhipment - goods unloaded to be reloaded in another transport conveyance. 7

8 Some industry participants stressed that if regulations mandate the requirement to provide data at acceptance then 100% of all consignment would have the data before this point in time. However, some airlines stated that this would have a significant detrimental impact on their existing business models. Amendment of data Most participants stated that changes of substance to shipment data (around 1%) 12 are very rare, 13 but changes of conveyance data occur more often (due to re-bookings and reroutings by carriers). 14 The latest point in time at which amendments are made is normally before the current ICS timeline (4 hours prior to arrival), in very rare cases last amendments are made upon fiscal clearance at destination. Predictability of routing to the EU The information on which aircraft the consignments will be loaded is available upon completion of loading. 15 Most participants stated that the definite routing of the aircraft and the MS of entry is known at the moment of the confirmed booking with the carrier. However, it can be subject to changes before the departure of the aircraft (take-off) which means that the customs office of entry might change. Participants estimate that cases in which changes occur are between 1 and 20% Data quality/risk analysis All Customs participants reported that the raw data checked in the study is generally sufficient for a first layer of security risk analysis. Some participants reported that the quality of the goods description is not sufficient and would need improvement. Air cargo specific risk criteria (whilst out of the scope of PRECISE) will need to be developed jointly with civil authorities and interior ministries One MS reported that among those changes most cases related to the goods description (up to 35% of the changes of shipment data in total). 13 While these percentages are lower than the percentages on the IATA website on their message improvement programme (MIP), it may be due to the participants and the sample taken 14 Cf. below 15 Freight forwarder participants reported that they normally get an update by the carrier at this point in time. 16 One participant reported that in most cases carriers know the routing up to 12 hours in advance but there are exceptional cases as an urgent shipment or payload issue where they could add/change a shipment on a flight latest 1-2 h before flight departure. One participant reported two types of cases in which changes to the routing occur: (1) last-minute unavoidable diversions due to bad weather etc; (2) changes for commercial and operational reasons, such as landing slot availability, crew rotations, curfews, that are more frequent. Such would normally be decided a day or two before the flight in order to have time to apply to the civil aviation authorities; however this routing change could be even closer to flight departure de-pending on whether the process could be accelerated. 17 The Terms of Reference (ToR) underline the supporting role of Customs in air cargo security. 8

9 Regarding the different (7+1) data elements participants stated slight discrepancies regarding the data quality. In general the shipper and consignee name and address, the weight, the number of pieces, and the airway bill number were satisfactory at over 80%. Depending on several aspects such as the geographical location and EDI capacities, in a reduced number of cases the data quality for the commodity description was seen as a weakness that would need improvement. It was suggested that IT systems would need to be able to reject raw data transmission, especially to take account of insufficient commodity descriptions. In this context, the possibility of a data quality referral could bring added value. One participant requested that the commodity description should be provided in an encoded form (HS Code), although the Terms of Reference refer to raw data as specified in the previous paragraph. Time needed for first layer of security risk analysis Customs participants highlighted that the overriding principle must be that the trader will provide the data as soon it is available due to the need of sufficient time for the risk analysis before loading of a consignment. Customs participants identified three scenarios: Scenario 1: automated process, no risk found, quick response; Scenario 2: IT based hit, additional analysis by customs required, manual process, will take longer than scenario 1; Scenario 3: possible air cargo risk found, additional analysis by customs and consultation of other authorities necessary, will take longer than scenario 2. It must be recognised that under scenario 2 and 3 authorities need time to complete their analysis (including request for additional data to trade etc) Referrals Albeit referrals were outside the scope of the EU PRECISE mandate, industry participants responded to questions based on practical experience. 19 Ability to locate the shipment Industry participants indicated that they would be able to find the shipment in the case of a referral by the unique identifier (e. g. HAWB number) or by a warehouse system. 18 As stated in the Communication on Supply Chain security "the absence of 24 hour/7 days a week (24/7) capacity and support in some Member States (also) inhibits the achievement of common EU standards" (source Comm. 793/ Industry participants reiterated their request for a live pilot which would help to establish these process metrics. 9

10 Least disruptive point for a referral Asked about the least disruptive point in time to segregate / (re-)screen the shipment freight forwarder participants indicated that this would be prior to arrival of the freight at the freight forwarders warehouse at airport of origin. An airlines participant indicated that this point in time would be after goods acceptance, before building up the ULD at either the carrier or the freight forwarder s premises. Current practice regarding aviation security measures Regarding the person that currently conducts the rules based additional screening participants responded that this depends on the legal situation in the country of origin, i.e. if screening services may be executed by privately owned entities or by national authorities exclusively, and the size of freight forwarders operations at airport of origin. Therefore it may be the carrier, the regulated agent or a government entity. Industry participants also reported that currently the additional screening is carried out by the holder of the goods of the time of a referral (if they are regulated to screen, e.g. CCSF in USA) or by the next entity in the supply chain that has the capability to screen. It is also carried out by the carrier due to the fact that the airline company is already considered certified according to the current legislation (ACC3) and also can intervene in the additional screening. Types of referrals Referrals foreseen should best cover: i) data; ii) re-screen; iii) HRC screening (Reg. 300/2008) and iv) DNL (cf. Annex: Referral flowchart DG TAXUD/DG MOVE). 5. Filing options (cf. Annex to the ToR) Participants studied the three options described in the Annex to the ToR and their expected impact and assessed whether these options should be allowed in parallel. During the course of the study, two Member States identified an additional option of a dual filing by both freight forwarder and carrier. Due to the similarities to option 2, the project group decided to treat it as its variance. 20 In addition, the possibility of a full freight forwarder filing was requested by the industry side, but not tested. One Member State (together with the industry participant) stated that their position is a first indication as no detailed description of business processes including with relevant alignment with the current AvSec regulation is available. 20 Cf. process flow cf. Annex. 10

11 Filing option 1: Full ENS prior to loading by Carrier From the MS customs point of view option 1 has the least impact of the options. The only major difference to the current situation is that the timelines of the ENS are shifted prior to loading. The changes in operations and IT would be relatively minor, as the current structure of ICS could be kept. Nevertheless, MS see the need to step up current Risk analysis structures, e.g. provide 24/7 operations, allocate more staff etc. which will have an operational impact this also applies for the other two options. For MS Customs, the advantages of option 1 are the limited costs and the unchanged data volume. In addition, as the full data set would be available ahead of time MS Customs would have more time to perform a fully-fledged risk analysis (including security) and to conduct risk mitigation at an earlier stage. MS participants however acknowledged that this option might not fit the business processes of the traditional air cargo model as the carrier might not have the relevant shipment information at this early point in time. Therefore update messages might be necessary which would increase the data volume. Risk mitigation after consolidation will be very disruptive to the business processes. In addition, as for option 1 data transmission from the FF to the carrier is needed, nondisclosure agreements among the participants will be necessary to enhance data quality. Air carrier participants expressed different positions in respect to their ability to transmit the full ENS to Customs prior to loading due to the various different business models operated. Some raised doubts regarding possible future requirements concerning the ENS ("enhanced" ENS, including the person motivating the transaction). Participating freight forwarders emphasized the disadvantages of option 1 to their business model, as the disclosure of sensitive information, high transmission costs to the carrier and the possible disruption, if referrals occur after consolidation. Filing option 2 and its variance: Raw data prior to loading by Freight Forwarder + ENS prior to arrival by Carrier Participants note that option 2 has the least disruption to the traditional business model, as it requires the information from the right actor (shipment information from the freight forwarder and conveyance information from the carrier), established standard messages (FHL, FWB) can be used, and there is no duplication of data and filing. Under option 2, early risk mitigation is possible, and data quality (regarding the persons motivating the transaction) may improve even without an NDA in place. One MS estimated that in comparison to option 1 the gain of time for conducting the first layer of customs risk analysis would be limited. 11

12 All MS customs participants agreed that significant changes in current ICS infrastructure to allow for PRECISE filing followed by ENS 21 filing would be necessary to implement this option, including an additional interface Freight forwarder Customs and the integration of the two data sets. One MS participant stressed that it would not be manageable for MS customs IT systems to match and handle messages from multiple parties. Furthermore the volume of messages will double, as two different data sets will be send; each shipment will have to be analysed twice (for aviation security and security & safety). Therefore additional process steps and resources will be required. MS Participants raised doubts how to deal with unknown freight forwarders in third country sending data. The possibility of an MRN message in order to indicate that the risk analysis has been completed without any findings (one participant called this acknowledgement message EU PRECISE compliance ) could be an option but must be further analysed. Regarding the question whether this possibility should be linked to a trusted trader status (such as AEO, RA3) participants recommended that this should be further explored in cooperation with aviation security authorities. Two Member States proposed a variance of option 2 (during the study so called "option 4") in which the raw data is sent by the Freight Forwarder to Customs, the Customs IT System issues an MRN concerning each HAWB (which would mean that the risk assessment had been completed), the Freight forwarders sends the MRNs through the security field, already provided in the IATA file, and the Air Carrier fills up the raw data with flight information in the ENS. 22 NB: Two Member States also expressed the opinion of having a single point of entry for the lodgement and one Member State also for the risk analysis, sharing all the information in a single data base implementing a risk analysis at EU level. (sharing all the information in a single database) Other Member States took a different point of view. Option 3: Filing o Carrier files raw data prior to loading +ENS prior to arrival 23 Participants assessed that the operational changes and IT implications would be similar to those in option 2. As in option 2, earlier risk mitigation and the usage of standard messages (FHL, FWB) are possible. Compared to option 2, it is the carrier who transmits the raw data, which has the advantage that the carrier is known in the EU as it files the ENS and is therefore easier to regulate as an unknown third country freight forwarder. 21 Industry stated that they would like to avoid double filing of the same data. 22 Cf. Annex. 23 Carrier files raw data prior to loading +ENS prior to arrival 12

13 This option is more flexible as option 1 as some of the ENS data that might not available to the carrier at an earlier stage can be provided before arrival. However, one MS participant reported that in comparison with option 1 the gain of time for risk analysis is even more limited as the carrier receives data from the forwarder very close to or at tendering. As in option 1 an NDA is necessary to enhance data quality. Choice between filing options The different groups of participants favour filing options that have a minimal impact on their current practices. Based on the findings in the study most MS participants opted for a combination of option 1 and option 2, while some accept making available all options. One participant noted that option 1 was unrealistic because it does not address industry's needs, one MS questioned the added value of option 3. One MS answered that, because of cost implications, it would only favour the variance of option 2. MS participants acknowledged that all options require changes in the operations (24/7 availability) and additional capacities for the additional layer of security risk analysis. Participating airlines responded that they would like to keep all three options described in the ToR. Regarding the least disruptive impact on the business model participants named both option 1 and 2. The choice between the option of sending the raw data to customs or the freight forwarder sending it would depend on the capabilities of the freight forwarder. Freight forwarder participants 24 clearly support option 2 because they are able to protect the commercially sensitive information and this option mitigates the impact on international trade and their business model. They stated that, depending on the technical capability of the respective entity, technically advanced freight forwarder businesses would prefer to transmit full enhanced ENS data to customs (variance of option 1 "full freight forwarder filing") in order to mitigate the impact of occurring referrals / DNL s. The use of a front end portal to facilitate SMEs to file, must be further explored. In summary, all participants were in favour to consider within an international standard all three filing options (including the variant) in parallel to take account of the diversity of the general cargo business model and different capacities of the stakeholders. For the freight forwarder, the most suitable moment for filing is when sending the FWB/FHL/XFZB to the carrier upon completing the HAWB (before sending shipment to carrier domain). The most suitable moment for carriers is when FWB/FHL/XFZB messages are received by carrier or after manual input at goods acceptance. 24 Note: Very few SME freight forwarders participated in the study 13

14 6. Costs/Benefits [Specific Trade associations cost estimate awaited (as done for the Express Pilot). NB: Industry stakeholders are currently unable to provide cost estimates, especially with regard to the challenges at this point (peak) of time of the year and within the required timelines. Cost estimates will be provided beginning 2014 depending on the choice of methodology.] 7. Other relevant information Pre-departure vs. pre-loading Most industry participants prefer the term pre-departure. Some clarified that this would in practice mean "pre-acceptance" according to the industry terminology. Most MS participants showed a clear preference for pre-loading; they highlighted that Customs officers need sufficient time for the risk mitigation before loading of a consignment onto the aircraft. Moreover, it is acknowledged that there is a risk of severely disrupting and delaying the processes if consignments are selected for referrals after consolidation and loading. Therefore it should be in each operator's interest to send the data as early as possible without distinction which term will be used. All participants agree that in order to achieve global standards, the definition will have to be aligned with other countries as US, CAN and integrated into the WCO SAFE Framework. Industry preference for live pilots Industry participants reiterated their preference for live pilots in order to get a clearer picture about the most suitable solutions regarding the traditional business model. In this regard it should be noted that in some MS the study activities of closely reached real time levels (e.g. in several MS thousands of shipments were). It was subsequently agreed that the PRECISE study should be finalised first. Once the study concluded, live testing could be considered. Questions about what would be tested (scope, timeframe etc.), its added value, who would bear any costs and which participants would take part, remain open. Need for global standards for advance data with regards to on-going efforts in other countries, such as ACAS, PACT There was unanimity among the participants that international standards for advance data requirements are necessary to limit the burden for trade. Close cooperation between the US (ACAS), CAN (PACT) and the EU and othersis necessary to avoid conflicting rules for trade. It was suggested - once common standards between the US, EU, CAN and others have been achieved - to include them in the WCO SAFE Framework. The data elements should be in in line with the WCO Data model. 14

15 8. Summary of key findings - Conclusions The study allowed all participants to gain a understanding about the fundamental features of the traditional air cargo business model, including the process flows and the roles of the main parties; Participants see the raw data approach as appropriate for the general cargo business model as the data are available early; they can be transmitted by using industry standards as FHL, FWB and XFZB, and data quality is, generally, appropriate for a first layer of security risk analysis; Participants note the continued need for specific air cargo security risk criteria to be developed jointly by COM and MS (customs, aviation security and interior authorities); Participants concluded that both freight forwarders and carriers should be allowed to submit the data to customs; Customs highlighted the need for sufficient time for the risk analysis before loading of a consignment; Routing information in general is available at tendering, but occasionally may change before loading, hence the first office of entry in most of the times, but not always known when establishing the HAWB, e.g. in the case of diversions, technical stops or rebooking on another flight; Regarding referrals participants estimated that the most appropriate time would be before consolidation. As follow up of EU PRECISE a referral test should be conducted with active contribution of aviation security authorities and industry stakeholders; Findings regarding the three filing options: o Filing option 1 the least impact for customs, but not the easiest one for trade and NDAs are necessary; o Filing option 2 and its variant changes and investment required seems to be the least disruptive for the traditional business model (NDAs are not necessary); o Filing option 3 seems to be the least preferred option for the traditional business model, as NDAs are necessary and the added value in terms of gain of time is limited; All participants were in favour to consider within an international standard all three filing options (including the variants) in parallel to take account of the diversity of the general cargo business model and different capacities of the stakeholders; Global standards are critical. 15

16 9. Follow-up actions to consider Live activities to be defined and considered (cf. point 7); As decided by the CPG 2012, to further develop - under the lead of appropriate authorities - protocols for adequate operators response in case of referrals and possibly test developed approaches (e.g. in one of the MS); Continue cooperation with major partners and international coordination (e.g. WCO SAFE); Analyse and improve the coherency between the EU Customs and EU AvSec legislation. Annexes - Referral overview chart - Flow chart of Variance of Option 2 List of Acronyms ACC3 Air Carrier Third Country 25 RA3 Regulated Agent Third Country CARGO IMP Cargo Interchange Message Procedures FHL Consolidation List message HAWB House Airway bill XFZB HAWB message FFM Airline Flight Manifest message MAWB Master Airway bill FWB MAWB message LAT latest acceptance time NDA Non-disclosure agreement RA Regulated agent STD Scheduled time of departure 25 Air carrier transporting cargo from a third country to the EU. 16