What are the new US Enhanced ACAS rules for 2025?

Effective 21 November 2025, U.S. Customs and Border Protection (CBP) will implement new Enhanced Air Cargo Advance Screening (ACAS) rules. Mandatory data will now include consignee contact details and shipment packing locations. A new "Verified Known Consignor" programme will offer streamlined filing. Shippers without this status face extensive conditional data requirements, including providing unmasked IP addresses, detailed customer account information, and, in some cases, biographic data from government-issued ID.

The landscape of US air cargo security is about to undergo its most significant transformation in years. Citing evolving security threats, including recent incidents involving incendiary devices in Europe, U.S. Customs and Border Protection (CBP) has published an Interim Final Rule for its Enhanced Air Cargo Advance Screening (ACAS) programme.

Published in the Federal Register, this rule formalises a host of new data requirements for all air cargo shipments destined for the United States. With an effective date of 21 November 2025, businesses across the supply chain have a clear deadline to adapt their processes and systems for compliance.

This is not a minor update. The economic impact assessment estimates the cost to industry will exceed one billion dollars over ten years, signalling the scale of the operational changes required. Here is a detailed breakdown of what is changing.

The "Why": Responding to a New Threat Environment

The rule explicitly states that these changes are a direct response to a heightened threat environment. The July 2024 incidents, where incendiary devices caused fires at European air cargo facilities, highlighted vulnerabilities that adversaries could exploit. The enhanced data requirements are designed to give CBP and the Transportation Security Administration (TSA) a more complete and timely picture of who is shipping what, allowing for more precise risk-based targeting before cargo is ever loaded onto an aircraft.

Key Changes in the Enhanced ACAS Programme

The core of the rule expands the data you must file for every house air waybill. The requirements are tiered into mandatory, conditional, and optional elements.

New Mandatory Data Elements

The following information will be required for all ACAS filings:

• Consignee Email Address and Phone Number: Direct contact details for the recipient are now essential.
• Shipment Packing Location and/or Scheduled Shipment Pickup Location: CBP needs to know the physical origin of the goods, which may differ from the shipper’s corporate headquarters.
• Ship to Party: The name and address of the party physically receiving the shipment after customs release.

The Verified Known Consignor (VKC) Programme: The Path of Least Resistance

The most critical strategic element of the new rule is the "Verified Known Consignor" (VKC) programme. This initiative creates a trusted trader status for shippers who meet rigorous security standards recognised by CBP.

The benefit is immense: if a shipper has an approved VKC status, the ACAS filer is exempt from providing most of the new, highly detailed conditional data elements. This creates a powerful incentive for shippers to pursue this designation to streamline their shipping process. CBP has indicated it plans to recognise established programmes, such as the EU’s known consignor programme, which is welcome news for global shippers.

New Conditional Data Elements (If the Shipper is NOT a VKC)

If the shipper is not a Verified Known Consignor, the filing burden increases substantially. These requirements are designed to provide CBP with a deeper look at less-known or one-off shippers. Key conditional data includes:

• Shipper Email and Phone Number
• Detailed Customer Account Information: This includes the account name, issuer, number, establishment date, and billing type.
• Unmasked IP or MAC Address: In several scenarios, filers must provide the unmasked Internet Protocol (IP) or Media Access Control (MAC) address of the device used to create the customer account or initiate the shipping transaction. CBP has stressed this is a critical security feature to verify identity and location, and that masked addresses from VPNs or proxy servers will not be acceptable.
• Shipping Cost: The total charges for delivering the shipment.
• Link to Product Listing: For many e-commerce transactions, the filer must provide the URL or SKU of the product being shipped.
• Biographic Data: For "walk-in" shipments or shipments of personal effects, the filer must transmit biographic data from a government-issued photo ID (like a passport or driver's licence) of the person presenting the cargo.

A Major New Compliance Step: Record Retention

In a significant new requirement, when biographic data is collected, CBP may notify filers that they must obtain and retain a copy of the government-issued photo ID used. This copy must be kept for three years and be provided to CBP upon request. This introduces a new and sensitive data retention process for many businesses.

Compliance Timeline and Public Comment

• Effective Date: The rule is effective from 21 November 2025.
• Phased Enforcement: CBP has committed to a 12-month phased enforcement period. During this time, the agency will focus on assisting the industry to comply, provided filers are making a good faith effort. However, willful and egregious violations will face enforcement action from day one.
• Comment Period: As an Interim Final Rule, it is open for public comment until 20 January 2026.

How to Prepare Now

Given the scale of these changes, immediate preparation is vital.

1. Analyse Your Data Gaps: Review the new data elements, especially the challenging ones like unmasked IP addresses and biographic data. Identify where this information exists in your organisation and where you will need to build new processes to capture it.
2. Prioritise the VKC Programme: If you are a shipper, investigate what it will take to become a Verified Known Consignor. If you are a forwarder, start communicating with your key shipping clients about the importance of this programme.
3. Update Systems and Processes: Begin discussions with your IT department and software providers. These changes will require significant system updates to capture, store, and transmit the new data. You will also need new operational procedures for tasks like ID verification and record retention.
4. Engage Your Supply Chain Partners: From e-commerce platforms to local shipping outlets, everyone in the chain will be affected. Clear communication and collaboration will be essential to ensure data can flow accurately and efficiently.
5. Consider Submitting Comments: If your business has specific concerns about the rule's implementation, the public comment period is an opportunity to provide formal feedback to CBP.

This enhanced ACAS rule represents a new baseline for air cargo security. While the compliance journey will be complex and costly, starting the process now is the only way to ensure your shipments continue to move smoothly into the US market.

Source: https://www.federalregister.gov/documents/2025/11/21/2025-20606/enhanced-air-cargo-advance-screening-acas