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What are the new requirements under the International Civil Aviation Organization’s (ICAO) policy direction?

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In September 2016, the ICAO announced its policy direction that consignors not subject to approval by the authority for aviation security should be phased out by 30 June 2021. Consignors either have to: -

1. be approved by the appropriate authority as a “validated” Known Consignor (KC); or
2. be an “unknown consignor” with all their cargo subject to 100% security screening prior to being loaded on to a commercial aircraft.

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How did Hong Kong respond to meet the security requirements under the ICAO’s new policy direction?

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Hong Kong has an obligation to meet ICAO’s security requirements and has launched the Known Consignor (KC) Validation scheme, for consignors which produce / manufacture or assemble goods for transport as air cargo from secure facilities within Hong Kong, and the Regulated Air Cargo Screening Facilities (RACSF) scheme, to enable and regulate cargo screening in off-airport locations in May 2020 and October 2018 respectively after consultation with air cargo industry representative bodies.

For more details of the KC Validation scheme and RACSF scheme, please refer to the following CAD websites:

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Who are eligible to apply for validation as KCs?

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Any company which operates a secure facility within Hong Kong at which air cargo is originated (i.e. where the production and/or assembly of cargo takes place) are eligible to apply for validation as KCs.

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What is the definition of production/assembly of air cargo to be qualified as KC?

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In general, production includes processes that a company undertakes to transform raw materials into finished goods, and assembly includes processes in which parts, components or semi-finished products are added / put together in sequence until the finished goods is produced. While we acknowledge that there are various business models existing in the market, we would evaluate each KC applicant on whether the applicant can be classified as a producer/assembler of air cargo on a case-by-case basis. Applicants are advised to send the details of the scope of operations of their company to vkc@cad.gov.hk for further assessment if the company can be classified as a producer/assembler of air cargo.

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Is it acceptable for a KC to have multiple sites?

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The registration of KC is site-specific. If an applicant intends to operate facilities at more than one site, separate applications have to be filed to CAD for acceptance of each of these facilities.

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What is the validity period of KC validated by the CAD?

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There is no expiry date on KC registration as long as the KC is able to continuously comply with the relevant requirements. KC is subject to the CAD’s monitoring of the compliance with the KC Security Programme, Handling Procedures for KC, notices and any other directions given from time to time by the CAD. Non-compliance may result in suspension or de-registration of the KC status.

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What is the condition for validated KCs to share Nominated Persons (NPs)?

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As the registration of each validated KC is site-specific, KCs cannot share NPs for overseeing the effective implementation of cargo security operations and their compliance with the requirements of the KC Validation Scheme, including the requirements in the KC Security Programme (KCSP).

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After production/assembly of finished goods, how should they be secured during transportation from site of KC to RAs?

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For the details of the transportation security, the list of methodologies of secure transportation (ST) that are accepted in principle, and the assessment process on new methodologies proposed, please refer to the following CAD website:

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Can secure transportation (ST) of finished goods from KC to RA/RACSF be performed by KC?

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After the production/assembly of finished goods at the KC, the KC operator may either (i) apply ST means and directly deliver the known cargo to CTO/Airline at airport; or (ii) apply ST means and pass the known cargo to RA/RACSF for delivery to a CTO at airport. For option (ii), the responsibility for applying the ST means from the KC facility to the RA/RACSF has to be agreed between the KC and RA/RACSF. Further details are provided in Notice to Regulated Agents 2/2019 downloadable at:

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It is noted that the Secure Transportation (ST) means accepted in principle include – "Box trucks equipped with numbered tamper-evident seals and locks" and "ULD container with metal door and equipped with numbered tamper-evident seals and locks". Is it a must to apply padlock(s) if my seal(s) can lock the door securely without allowing anyone to tamper the cargo?

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Application of a pad lock would not be necessary if the numbered tamper-evident seal(s) are strong enough to serve also the function of a lock, to adequately protects and secure the known cargo.

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Can KC accept cargo from other entities?

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Air cargo not originated (i.e. neither produced nor assembled) in a KC’s premises shall be treated as unknown (UNK) cargo and subject to security screening before allowed carriage onboard an aircraft. The unknown status of air cargo consignment from other sources shall be clearly conveyed to the next entity to receive the UNK cargo for application of security screening by regulated agents (RAs), regulated air cargo screening facilities (RACSFs), cargo terminal operators (CTOs) or aircraft operators.

A KC shall ensure that consignments of cargo intended for carriage by air from other sources (i.e. non-originated items) are segregated from the consignments of air cargo originated from the KC based on the measures as specified in Section 6.4 of the Known Consignor Security Programme.

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What is the minimum premise area required for processing cargo in KC?

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Premises for production, assembly, packing and storage of consignments of air cargo shall be secured and access controlled to prevent and detect unauthorized access such that introduction of explosives and incendiary devices into air cargo consignment can be prevented. The size of cargo processing area is not a factor to be considered for KC application as long as the above principle can be complied with.

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Where can we find the training institutes for KC training?

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A KC shall have at least the two Nominated Persons who have successfully completed a KC Security Training Programme run by training institutes acceptable to the CAD. Currently, the CAD is assessing the KC training programmes proposed by various course organisers. A list of the training institutes and their contact details will be uploaded to the CAD website. Please stay tuned for the latest updates.
Interested parties can contact the organizers direct for enrolment.

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Staff members of my company have not yet attended a KC training course. Can my company submit KC application to the CAD?

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It is not a must for a KC applicant to submit the training certificates of the two Nominated Persons (NP) for cargo security together with the application form. The documents / information can be submitted during or before the pre-registration inspection to be conducted by the CAD.

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Are training required for my contractors?

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All staff members of KC involved in the production, manufacturing or assembly processes and contractors with access to consignment designated as air cargo shall be required to complete both initial and refresher security awareness training to understand the principles of the air cargo security regime in Hong Kong and requirements for KC.

The above security awareness training shall be conducted by one of the NPs who have attended and completed a KC training programme run by training institutes acceptable to the CAD, or a trainer with equivalent qualification.

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Who is qualified to be the personnel conducting the Internal Security Awareness Training?

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Internal Security Awareness Training shall be conducted by one of the KC’s Nominated Persons or other trainers stipulated in KC Security Programme/ Part II/ Section 9(b). Other trainer should also hold a valid KC Training Certificates after the completion of a KC training programme.

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Is a register of KC regularly updated and published for industry’s reference?

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Similar to the practices adopted in RAR and RACSF, a register of validated KC is regularly updated and published by CAD in the following website for industry’s reference.

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Does KC meet the aviation security requirements of foreign civil aviation authorities (e.g. US TSA)?

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The framework of KC in Hong Kong is formulated based on the ICAO’s standards and guidance. More stringent security requirements above ICAO’s standards could be imposed by foreign civil aviation authorities in accordance with foreign states’ own situations.