Mandatory Pre-load Air Cargo Targeting

Summary#

This is a proposed change to the Canadian Aviation Security Regulations, 2012 to make the Pre-load Air Cargo Targeting (PACT) program mandatory. In practice, it would require air carriers bringing cargo into Canada to send advance cargo details to Transport Canada before the cargo is loaded, so the government can screen shipments for security risks and order extra checks or a “Do Not Load” hold if needed.

What it does#

• Requires all air carriers carrying cargo to Canada from abroad to submit specific advance cargo information before loading. The information includes the air waybill number, shipper and consignee names/addresses, a description of each piece, piece count and total weight.
• Requires carriers to send flight details after departure and before arrival in Canada.
• Transport Canada would run an automated risk check (using AI-assisted analytics) on the submitted data. A human would review flagged results.
• Depending on the outcome, carriers could be asked for:
  • more information about a shipment,
  • to screen the cargo, or
  • to stop the cargo from being loaded with a “Do Not Load” (DNL) notice.
• Carriers must not transport cargo until they receive confirmation of receipt from Transport Canada (the program aims for confirmations within about five minutes for routine low-risk shipments).
• The proposal exempted mail and passenger baggage, and it would not apply to flights departing from Canada.
• Non-compliance could lead to administrative monetary penalties (AMPs): up to $25,000 for serious failures (e.g., not screening when ordered or transporting cargo after a DNL) and up to $10,000 for information-reporting failures.
• Changes also tidy other cargo/mail wording in the regulations and set data-retention and system rules (records generally kept up to 18 months unless a threat is identified).

Who's affected#

• Air carriers that bring cargo to Canada (both Canadian-based and foreign operators) — they would have to submit the advance data and respond to screening or information requests.
• Freight forwarders and data aggregators that submit cargo details on carriers’ behalf could be affected when they act as the data provider.
• Shippers and consignees, indirectly — their shipment details are part of the data set and shipments could be held, re-routed, or subjected to extra screening.
• Transport Canada would run and staff the system; the government estimates ongoing program costs.
• The proposal estimates total incremental costs (present value over 10 years) of about $6,353,576, split roughly as $4,245,622 for government and $2,107,954 for industry. A small number of Canadian small air carriers (five) would be affected; estimated cost per small business is about $615.
• It’s a proposal (Canada Gazette, Part I). Stakeholders were invited to comment within 75 days of publication (March 18, 2023).

Why it matters#

• The measure aims to catch high-risk cargo before it gets on board and enters Canadian airspace. That reduces the chance of a catastrophic incident that could harm people, infrastructure, or commerce.
• It brings Canada into alignment with similar advance-cargo screening programs used by other countries. That can simplify international cooperation and information sharing.
• For carriers and shippers it means extra data-sharing steps and the risk that a shipment may be delayed, re-screened, or refused loading if flagged. There are also real financial penalties for failing to follow the rules.
• The government says the public-safety benefits are potentially large but hard to quantify precisely; the proposal therefore describes those benefits qualitatively while providing an estimate of the program’s monetary costs.