From 1 January 2027, the rules for transporting secured air cargo will change
From 1 January 2027, the rules for the surface transport of secured air cargo and mail within the European Union will change significantly.
Until now, hauliers have been able to transport secured air cargo under a haulier declaration agreed with a regulated agent or known consignor. This arrangement applies only until 31 December 2026.
From 1 January 2027, surface transport within the Union of secured air cargo and mail may be carried out only by specified secure-supply-chain entities, including a haulier approved by the appropriate authority in accordance with point 6.5 of Regulation (EU) 2015/1998.
For transport companies that intend to continue carrying secured air cargo after that date, the transition to Approved Haulier status therefore needs to be addressed well before the end of 2026.
Approval involves much more than submitting a manual
To become an Approved Haulier, an organisation must establish a functioning aviation security system and demonstrate that the procedures described in its documentation are actually implemented in practice.
Under point 6.5.1.2, the applicant must submit an Approved Haulier Security Programme describing how the company complies with Regulation (EC) No 300/2008 and its implementing acts. The programme must be prepared using the standardised template in Attachment 6-K.
The applicant must also submit the Declaration of Commitments – Approved Haulier contained in Attachment 6-D, signed by the legal representative of the company or the person responsible for security.
The security programme covers areas including:
- organisation and security responsibilities;
- the person responsible for implementation of the security programme;
- recruitment, background checks and staff training;
- protection of secured cargo during collection, handling, limited storage, transport and delivery;
- measures against unlawful interference;
- cooperation with authorities and reporting;
- internal quality control and compliance monitoring.
The appropriate authority assesses whether the programme is relevant and complete and subsequently verifies whether the described procedures are actually implemented. In Estonia, the Transport Administration states that the process includes an on-site verification covering at least one operational location in the haulier’s network.
Do not leave the application until the end of 2026
A large number of companies are currently preparing for the new requirement.
In some of the cases we are currently supporting, the Estonian Transport Administration has already extended the review period for submitted security programmes. With the 1 January 2027 deadline approaching, this is a practical reason not to leave the application process until the last moment.
Submitting an application itself is usually not the most difficult part.
The real work is ensuring that the security programme, personnel, training, records and actual operational processes all match.
If a security programme describes procedures that the company does not actually follow, or important requirements are missed in the first version, the result can be additional correspondence, amendments, retraining and changes to operational processes.
That costs considerably more time than building the system correctly from the beginning.
We help you get it right the first time
Aviation Consulting supports hauliers throughout the entire Approved Haulier approval process.
We do not simply provide a generic security programme template. We first look at how your company actually operates and then build the required aviation security system around your organisation.
Our support can include:
- preparation of the Approved Haulier Security Programme;
- preparation of the Attachment 6-D Declaration of Commitments and application documentation;
- gap assessment of your existing arrangements;
- establishment of security responsibilities and the Security Manager function;
- implementation of personnel and background-check procedures;
- initial and recurrent aviation security training;
- procedures for protecting secured cargo during collection, handling, limited storage, transport and delivery;
- access, key, seal and cargo-protection arrangements where applicable;
- development of internal quality-control and compliance-monitoring procedures;
- preparation of checklists, records and forms;
- preparation for the authority’s on-site verification;
- support during communication with the competent authority.
We can also prepare the practical correspondence required during the process — including draft applications, e-mails and responses to authority comments — and help your organisation put the documented procedures into everyday use.
The objective is straightforward:
to make the approval process as smooth as possible and avoid unnecessary rewriting, corrective work and repeated changes to your operational system.
Practical experience matters
Aviation Consulting has already supported an Approved Haulier approval process from beginning to end.
In June 2026, AN-Transport became the first Approved Haulier in Estonia, with Aviation Consulting supporting the company from initial consultation and training through development of the security programme, application preparation, pre-assessment and the authority’s on-site verification.
The process was completed without a single non-conformity.
That practical experience means that our support is based not only on interpreting the regulation, but also on understanding how the requirements are documented, implemented and demonstrated during the actual approval process.
We are currently supporting several companies in Estonia and elsewhere in Europe in preparing for Approved Haulier status.
Starting early makes the process easier
If your organisation transports secured air cargo or mail and intends to continue doing so after 1 January 2027, now is the time to assess your readiness.
A useful first question is simply:
Do we need Approved Haulier status, and how much of the required system do we already have in place?
In many cases, we can answer that during an initial consultation and identify the main steps required for approval.
Contact Aviation Consulting and tell us how your transport operation works. We can help you build a practical route to Approved Haulier approval and make the process as efficient and predictable as possible.
Approved Haulier – 10 frequently asked questions
1. What changes on 1 January 2027?
From 1 January 2027, an independent haulier will no longer be able to transport secured air cargo or mail within the EU solely on the basis of the existing haulier declaration arrangement.
2. Does every transport company need Approved Haulier status?
No.
The requirement concerns organisations transporting identifiable air cargo or mail to which the required aviation security controls have already been applied as part of the secure supply chain.
Whether your company requires approval depends on your role, customers and the type of transport you perform.
3. What is the Approved Haulier Security Programme?
It is the main aviation security document describing how the haulier complies with the applicable security requirements.
The programme must be prepared using the standardised Attachment 6-K – Security Programme of the Approved Haulier.
4. Do I also need to submit Attachment 6-D?
Yes.
In addition to the security programme, point 6.5.1.2 requires the applicant to submit the Declaration of Commitments – Approved Haulier contained in Attachment 6-D.
It must be signed by the applicant’s legal representative or the person responsible for security.
5. Is Attachment 6-D the same as the current haulier declaration?
No.
They serve different purposes.
The existing transport-related haulier declaration is associated with the current arrangements under point 6.6.1.1 and Attachment 6-E, and that arrangement applies until 31 December 2026.
Attachment 6-D, by contrast, is the Declaration of Commitments submitted as part of the Approved Haulier application process.
6. Can we simply purchase a ready-made security programme?
A generic template alone is not sufficient.
The programme must describe your organisation’s actual procedures, and the authority subsequently verifies whether those procedures are implemented in practice.
The safest approach is therefore to build the programme around the company’s real transport and security arrangements rather than trying to adapt operations afterwards to fit a generic document.
7. Does an Approved Haulier need a Security Manager?
Yes.
The haulier must designate at least one person responsible for implementing the security programme and the relevant operations and procedures. The applicable requirements also include an enhanced background check for that person.
8. Do drivers and other employees require aviation security training?
Yes, depending on their duties.
Staff performing the transport of cargo and mail must receive security awareness training. Personnel who also have unsupervised access to secured cargo or mail are subject to additional security-training and background-check requirements.
9. Will the authority carry out an on-site inspection?
Yes, under the standard approval process.
After the security programme has been successfully assessed, compliance is verified on site. In Estonia, the Transport Administration states that the verification covers at least one operational location in the haulier’s network and includes observation of relevant collection, handling, limited-storage, transport and delivery procedures.
10. How long is Approved Haulier status valid, and when should we start?
Following successful approval, the status may be granted for up to five years, after which periodic re-approval is required. The haulier is not considered approved until its details have been entered in the Union database on supply chain security.
As for timing: start as early as possible.
Before approval, the security programme must be prepared and assessed, responsible personnel identified, applicable background checks and training completed, operational procedures implemented and the authority’s verification successfully passed.
Starting early leaves time to correct any gaps without putting your ability to transport secured air cargo after 1 January 2027 at risk.
Planning to apply for Approved Haulier status? Contact us and we can assess your current arrangements and help build the shortest practical route to approval.