CargoForwarder talked to CLECAT’s Director-General Nicolette van der Jagt and policy advisor Aidan Flanagan about ACC3 and other pressing cargo topics, among them pricing and all-in
CLECAT is the umbrella organization of European freight forwarders’ representative based in Brussels. They have dealings with the other stakeholders in the supply chain as well as with the decision makers in Brussels such as the European Commission and the European Parliament.
Before joining CLECAT in 2011, Nicolette worked for 15 years at the European Shippers’ Council (ESC), of which 10 years were spent as Secretary-General. Before joining CLECAT in September 2014 Aidan worked with Hill & Knowlton, in which he had dealings with the World Customs Organisation and had TIACA as a principal.
Q: What is the extent of the impact of the European ACC3 regulation on the freight forwarders?
Aidan: “It is something that we monitor very closely. Complying with the regulation, which is aimed at providing the necessary security in air cargo brought into EU territory from third countries, is the responsibility of the carrier. The whole idea is that it is meant to encourage the secure supply chain, creating an incentive for freight forwarders to become regulated agents. That way you can speed up the process within a secured supply chain and that way you get a much simpler business process for the freight forwarder.”
Q: As an umbrella organisation of national freight forwarders’ associations, surely you cannot encourage individual companies to go for the necessary validations needed for compliance?
Aidan: “No, what we do is follow the legislative development and seek to influence when necessary. The regulated agents/freight forwarders need to know if the carrier they are dealing with has been certified within the ACC3 programme. Normally they tell their freight forwarders that they have the right to fly cargo into the EU.”
Nicolette: “This issue is mostly important for the FIATA members, because they need to know when they need to bring cargo into the EU through air freight.”
Q: Is it always possible for a freight forwarder to know that they are dealing with a licensed carrier?
Aidan: “It is always the carrier’s responsibility to make sure that he posesses a validation. One of the greatest opportunities for confusion is knowing whether the carrier is validated to operate from a particular airport. Because in the way that ACC3 works, a carrier can be validated for airport A, but not for airport B.”
Q: Is it possible to keep track of this type of things?
Aidan: The data are supposed to be gathered into a specific database set up by the European Commission. As CLECAT we keep on pointing out to the European Commission that the process is getting more and more complicated. Within Europe a Regulated Agent (RA) that receives secure cargo has the obligation to check whether the cargo comes from a Known Consignor (KC) that is listed in the Union database on supply chain security. This database contains among others all RAs and KCs that have undergone an independent EU aviation security validation.
In view of an increasing number of KCs, the burden on the industry to verify these various entities is increasing. What we, as an industry, would like to see, is automated access to the database, allowing the freight forwarders to obtain all relevant information required to prevent any risks. This includes not only the RA’s and KC’s, but also the ACC3’s as well as RA3’s and KC3’s. Inclusion of all these entities in one database is without alternative, if we want to avoid confusion, administrative burdens and cost through multiple, separate databases operated by each ACC3.
This is an issue concerning the entire supply chain security issue. CLECAT would like to express its preference for the European Commission to establish and maintain a database with information received by validators (possibly through Member States) and to make this available to the industry. In doing so a certain level of neutrality, which is highly commendable, would be guaranteed. With the current Union database on supply chain security already developed, it would be advisable to extend the functionalities of the existing database rather than constructing a new one.”
Nicolette: “We support all efforts to enhance the quality of a secured supply chain. CLECAT is among the partners of the European project CORE (Consistently Optimised Resilient). This is an ambitious programme aimed at aligning all the public and private stakeholders to provide an efficient, lean and yet secure supply chain.” (One of the so-called ‘demonstrators’ is Schiphol Airport, which is trying to apply a global data pipeline concept to air cargo supply chains, managing air freight specific trade compliance requirements, and offering supply chain visibility in dashboards. It is demonstrated in trade lanes with e.g. Africa, involving multiple inspection authorities, MS)
Q: CLECAT has also to deal with the other private partners in the supply chain. Something that did not go unnoticed were the all-in rates introduced by some Middle-East carriers. They were well applauded by CLECAT and the global freight forwarding community as a whole. Do you think others will follow?
Aidan: ”It is for the airlines to make a commercial decision. Maybe there will be some pressure on the other airlines, but to date we have seen no signal of similar moves. It
will, however, create greater transparency.”
Nicolette: “You mustn’t forget that pricing is often a very difficult issue and a competitive issue as well. We are not making recommendations as this is for individual carriers to decide but transparency is important for customers. For the smaller freight forwarders there may not be a lot of advantages, because they do not have the leverage. But for the very large companies any discussion on transparency may add up.”
Q: Will this be a permanent system of rate calculation or does CLECAT fear a return to the old situation once the fuel prices go up again?
Aidan: “That remains to be seen, as Nicolette has said: the key is transparency. Why prices go up or down has to be justified in a transparent way. Historically, when the fuel prices went up, so did the rates, but there has not necessarily always been a similar downward movement when the fuel got cheaper.”
Marcel Schoeters in Brussels