About APIS
CBP APIS Frequently Asked Question
- APIS Pre-Departure Final Rule
- Timing of Transmissions
- APIS Data Elements
- Unique Identifiers
- Updates to APIS Transmissions
- APIS Batch
- AQQ Interactive
- Response Messages
- Unsolicited Messages
- Flight Close-Out Messages
- eAPIS
- Connecting Passengers
- Verifying Passenger Information/Provisional Boarding Passes
- System Outages
- Data Monitoring/Fines
- Secure Flight
- Support
- Miscellaneous
Operational Questions
APIS Pre-Departure Final Rule
- What is the date of implementation for the APIS Pre-Departure Final Rule requirements?
Answer: The date of implemention for the APIS Pre-Departure Final Rule requirements is February 19, 2008.
- For non-US flagship carriers, does the APIS final rule apply for all flights into/from the US?
Answer: All commercial carriers, into and out of the United States, are required to transmit the appropriate APIS data, at the times indicated in the APIS Pre-Departure Final Rule.
- Is there a change to Crew APIS processing within the final rule for air carriers?
Answer: There were no changes to the current Crew APIS transmission requirements in the APIS Pre-Departure Final Rule.
Timing of Transmissions
- Is it OK to send interactive batch APIS transmissions for passengers who have APIS data in their Passenger Reservation Data (PRD) but are NOT “checked in” yet? Understanding, that we would send an updated message if any changed/different data at time of airport check-in. Additionally, can this message be sent in addition to the interactive individual message?
Answer: Passenger data can be submitted and a screening response will be returned for passengers who have not already checked in for the flight. Complete APIS data for each passenger is required no later than 30 minutes prior to securing of the aircraft for batch submissions and no later than up to securing of the aircraft for APIS Quick Query (AQQ) submissions. Carriers are encouraged to develop batch interactive and AQQ capabilities.
- Why is there a restriction on issuing boarding passes prior to -24 hours? If we pass APIS at -36 hours and the response is cleared or a selectee, why can’t we print the boarding pass at that time?
Answer: Although carriers are encouraged to transmit data earlier in the process, the CBP APIS Pre-Departure Final Rule requirement does not change any restrictions on issuing boarding passes prior to the -24 hour timeframe. Currently there is an Emergency Amendment (EA) issued by TSA stating aircraft operators are prohibited from issuing boarding cards more than 24-hours prior to flight time. Please refer to EA 1546-01-18E SELECTEE INTERNATIONAL dated 7-8-04.doc
- A combination of batch and AQQ is allowed. Is there total flexibility regarding the timing of the switch from batch to AQQ? E.g. Could a carrier send a batch manifest at -6 hours and then switch to AQQ after that or can the AQQ only take place after -30 mins batch manifest?
Answer: A combination of batch and AQQ submissions is allowed. Complete APIS data for each passenger is required no later than 30 minutes prior to securing of the aircraft for batch submissions and no later than up to securing of the aircraft for APIS Quick Query (AQQ) submissions. Carriers are encouraged to develop batch interactive and AQQ capabilities. Switching from one transmission method to another is at the discretion of the aircraft operator.
- If a batch manifest is opted for and no boarding passes can be issued until the vetting response comes back from DHS, will we have to wait until -30 and then print the boarding passes?
Answer: The submission of a batch manifest is a “No Later Than” timing event and provides flexibility for carriers operational processes. A carrier can send a batch manifest much earlier, and carriers are encouraged to send data 72 hours prior to the flight when available. If a traveler provides complete APIS data at 72-hours prior to the flight, the carrier can submit complete APIS data at that time. If the traveler provides limited data such as a name and date of birth only, the carrier can still send that data at 72-hours and receive a screening response. Complete APIS data must still be provided, for a batch submission, “No Later Than” 30 minutes prior to securing of the aircraft doors.
- Flights from UK to USA are subject to a TSA EA which requires final APIS at -15 Push Back. Does the Final Rule override the current TSA requirement for UK-USA flights?
Answer: The CBP APIS Pre-Departure Final Rule requires complete APIS data for each passenger is required no later than 30 minutes prior to securing of the aircraft for batch submissions and no later than up to securing of the aircraft for APIS Quick Query (AQQ) submissions, for all flights.
- If carriers transmit their batch manifest data 30 minutes prior to departure and are cleared before the 30 minutes are they ok to leave? If so, is this in writing anywhere?
Answer: This accommodation is established as part of the APIS Pre-Departure Final Rule, published in the Federal Register, August 23, 2007, page 48324, (b) Connecting Passengers, states, “Finally, where the interactive batch transmission option is employed and connecting passengers with boarding passes arrive at the gate (or other suitable location) within the 30-minute window, the carrier is not required to wait 30 minutes from the time the data is transmitted to secure the aircraft and depart, provided that appropriate vetting results are received, and validation occurs, before any connecting passenger is boarded.”
- If a batch of most of the passengers is sent before the 30 minute deadline, what are carriers to do with the passengers waiting?
Answer: Complete APIS data for each passenger is required no later than 30 minutes prior to securing of the aircraft for batch submissions and no later than up to securing of the aircraft for APIS Quick Query (AQQ) submissions. Carriers are encouraged to develop batch interactive and AQQ capabilities. If a carrier has not developed AQQ functionality and they have less than 30 minutes before the scheduled time of securing the aircraft, the carrier is still obligated to submit APIS data for all passengers on the flight and wait for a boarding pass authorization, which may take up to 30 minutes to process and return a boarding pass result.
- If the carriers can’t comply by 2/08 would CBP be able to complete watchlist vetting if all carriers closed flights at -30 and what would be the expected time response from CBP?
Answer: The CBP system currently has the functionality to conduct watchlist screening of passenger APIS transmissions submitted no later than 30 minutes prior to securing the aircraft. Under most circumstances, the CBP system processes transmissions in a matter of minutes and will have the ability to provide a screening response within minutes of receipt of the message.
- Can DHS be more specific with regards to the statement within the regulation related to the amount of time it will take to respond to an interactive message (‘seconds’) and a batch interactive message (‘a minute or two’) response time?
Answer: For carriers using the APIS Quick Query (AQQ) transmission method, DHS will provide a response within 4 seconds of receipt of transmissions containing 10 names or less. For the batch interactive transmisisons method, DHS will provide a response within 30 minutes. The 4 seconds is based on the amount of time it will take the CBP system to process the message internally and provide a vetting response. The 4 seconds does not take into consideration the latency involved in the delivery of the message from the carrier to CBP or the latency involved in returning the message to the carrier from the CBP process.
- Air carriers are already transmitting PNR data at intervals of 72 hours, 48 hours and 24 hours prior to departure. Why is this information not used for vetting? While presently the Unique Identifier Number and Date of Birth are not datafields of the PNR, one may change the PNR structure accordingly. Would this be a possible alternative?
Answer: The format that PNR data is transmitted is different than the international standard used to meet the APIS requirements. In order for the message to be processed and meet APIS requirements, the message would need to be in the recognized UN/EDIFACT format. Once that is accomplished, the 72, 48 and 24 hour transmissions would be received and processed for vetting.
- Pg 33/66 Table 7 of the Consolidated User Guide references the Transmission Triggers. One line references APIS data submission but should there be multiple references to the timing triggers because it would differ if carriers use the non-interactive batch option, the interactive batch, or the interactive individual option?
Answer: The discussion of data submission provided in the Consolidated User Guide is a point of reference. When submitting APIS data, all data must be submitted prior to securing of the aircraft doors.
- APIS-30: Is there any requirement that states that the Passenger Manifest cannot be sent more than 30 minutes before departure? One solution is to set up transmittal to automatically generate 30 minutes prior to scheduled departure (if the flight delays, we’ve sent it at least 30 minutes prior to departure).
Answer: The APIS Pre-Departure Final Rule indicates the submission must be “no later than” 30 minutes prior to departure. Therefore, the message can be transmitted well in advance of the 30-minute time frame.
APIS Data Elements
- The Guide states that the values for all UNA sub-items will always be as stated. Our understating (and actual current use) of this element is that the carrier can specify their own separator characters. For UA we currently use an ‘open parenthesis’ instead of the ‘plus sign’ for the Data Element Separator (UNA2). Also we currently use a ‘dollar sign’ instead of a ‘single quote’ for the Segment Terminator (UNA6). Will UA be allowed to continue the use of their current optional values? Will DHS only send back to the carrier the UNA stated values that appear in the guide? Why do the examples in the Guide show an ‘asterisk’ for the ‘space’ separator character? (Note: Page 51 Section 4: states that a different set of control characters may be specified in the UNA)
Answer: The section you are referring to was extracted directly from the WCO/IATA dictionary for UN/EDIFACT coding. As stated in previous versions of the UN/EDIFACT Implementation guide, CBP will support carrier’s versions of the UNA segment identifiers and will return messages based on the identifiers provided. Clarification will be made to the UN/EDIFACT PAXLST Implementation guide, in this particular section
- The Transaction Reference Number (TRN) is presented as conditional, and is “Used at the discretion of the aircraft operator to manage messages.” We assume this applies to the appended, Message Sequence Number (MSN) as well. What issues if any, does DHS foresee if the carrier chooses to not use the TRN + MSN elements in their AQQ messages
Answer: As is with a number of Conditional fields, they are identified as Conditional in the UN/EDIFACT dictionary of data elements. Due to their purpose and use, they can be considered Mandatory. In addition, CBP and Secure Flight will be utilizing the TRN and MSN elements for auditing and message management purposes. Therefore, the TRN and MSN elements should be considered mandatory and the carriers need to incorporate them in their message structure.
- Please explain the difference between APIS data elements and PNR data elements? (Table 3 & 4 of the Consolidated User Guide) Are we only sending APIS data elements via AQQ? If yes, when/how are the PNR data elements sent, or are they
Answer: The APIS Final Rule of 2005 established the data elements required as part of an APIS transmission and carriers often submit APIS data from their Departure Control System (DCS). The CBP APIS Pre-Departure Final Rule establishes transmission methods and time requirements for commercial carriers transmitting APIS data for travelers arriving into or departing from the United States. Passenger Name Record (PNR) information found in a carriers’ reservation system is separate from and not mandatory as part of the APIS Pre-Departure Final Rule. The PNR data element listing in the Consolidated User Guide is provided as part of one of several message examples.
- Full name is defined as first and last. Yet, page 10 of the Consolidated User Guide states middle is mandatory if available. Can you please clarify the definition of "Full Name"?
Answer: The APIS Final Rule of 2005, establishes full name as; last, first, and, if available, middle. Full name can often be obtained by swiping the Machine Readable Zone of the DHS approved travel document.
- Full name is defined as it appears on the travel document. Does CBP compare the full name to the actual PNR and boarding pass?
Answer: The carrier is required to submit the APIS data found in the individuals DHS approved travel document, this often occurs through swiping the Machine Readable Zone (MRZ). While CBP does not compare the full name to the PNR or boarding pass, CBP does compare data found in the DHS-approved travel document with the APIS record.
- Passport and address details are in most cases not known until a short time before departure (during check-in process). What is the minimum information that must be sent to receive a vetting response?
Answer: For international transmissions, the minimum data required to receive a screening response is, full name and date of birth. Full name is based on a last name of at least one character, not containing special characters other than a hyphen (-) or an apostrophe (‘), a first name of at least one character, not containing special characters other than a hyphen (-) or an apostrophe (‘). Date of birth containing a valid month, day and year.
- What is meant by ‘inadequate’ data
Answer: In order to properly screen a traveler on an international flight, a minimum of full name and date of birth are required. Please refer to the description of full name and date of birth, as answered in a previous question.
- Is CBP working with IATA to develop standard messages to support the collection of the additional elements proposed for Secure Flight
Answer: CBP has identified what is believed to be data elements not currently accepted in the UN/EDIFACT PAXLST format dictionary. Once we have identified the final new data elements expected in a Secure Flight transmission, CBP will work with the WCO/IATA counsel to achieve acceptance.
- Pg 26 of the Consolidated User Guide - Various Doc Type Codes Section 4.2.1 and 4.2.2 - PNR Data Elements, these two tables appear out of sync. One lists F for Facilitation Document, and the other lists F as Deportee/Consular Letter. Are all temporary travel docs/parole letter/single journey letters defined as doc type F?
Answer: As of October 1, 2007, the only acceptable ‘F’ type documents will be deportees or travelers with consular letters.
- Pg 28 of the Consolidated User Guide - 4.2.2 PNR Data Elements Table - references US destination Address twice - Once as a mandatory element, and one as not mandatory. Which is it
Answer: The Consolidated User Guide will be updated to reflect address APIS transmission requirements for visitors.
- Pg 44/66 of the Consolidated User Guide - The receipt of an error message due to invalid data submissions would prevent boarding of a passenger. Does this mean we can issue a boarding pass for an error condition provided we restrict/catch at boarding? Or that a boarding pass can not be issued for an error condition? There is inferred reference that the error is considered a not-cleared, is that the same as inhibited? What constitutes 'invalid data?
Answer: An error message means that a boarding pass cannot be issued, as the data is deficient to conduct an adequate screening. Invalid data is considered, but not limited to, no date of birth for an international traveler, invalid date of birth, no last name provided or no first name provided.
- Section 4.9.34 of the Consolidated User Guide - Error response when you fail business rule edits, what specifically are the edits that will generate an error response? Please provide a comprehensive list
Answer: An error response is based on the following comprehensive list of rule edits for international flight transmissions:
Missing last name
Missing first name
Missing date of birth
Invalid last name – characters other than alpha, hyphen (-) or apostrophe (‘)
Invalid first name – characters other than alpha, hyphen (-) or apostrophe (‘)
Invalid date of birth
Error messages returned are not a part of the APIS sufficiency rate.
- For AQQ qualified vs. informational data for a vetting response. For Secure Flight is full name the only data element required? This would be a difference between what is written and indicated in table 9
Answer: Table 9 refers to Secure Flight requirements. In order to receive a vetting response for an international transmission, a minimum of full name and date of birth are required.
- Can we use Type B headers for transmission of data
Answer: Yes, CBP will save and reuse the header in its response back to the air carriers.
- Regarding the Clear Passenger Request on Page 68/69 of the UN/EDIFACT Implementation Guide (BGM type 745):
What is a Clear Passenger Request?
When would it be used?
What would trigger this message type? Note: we would need an example of this type of message
Should this type message be able to be done by Feb. 19?
Answer: A Clear Passenger Request is used to submit passenger APIS data (partial or complete) and request authorization to issue a boarding pass. This type of message is expected for the February 19, 2008 date.
- Regarding Cancel Reservation/PNR on Page 68/69 of the UN/EDIFACT Implementation Guide (BGM type 745, Document ID – XR with example on Page 202, B.14. Cancelled Reservation):
When would this message be used?
What would trigger this message type?
Should this type of message be able to be done by Feb. 19?
Answer: The Cancel Reservation/PNR is primarily a Secure Flight proposed requirement. However, it can also be used for APIS submissions, e.g. an APIS submission has been provided and the traveler subsequently does not travel. Normally, for international transmissions, this would be accomplished in a Flight Close-Out message; however, a carrier may choose to use the Cancel Reservation/PNR option when maintaining APIS records. It is not expected for February 19, 2008, as the carrier will most likely accomplish it through a flight close-out message.
- Regarding Cancel Flight on Page 68/69 of the UN/EDIFACT Implementation Guide (BGM type 266 Document ID – XF with example on page 206 B.16. Cancelled Flight):
Will we be doing the cancel flight type message?
What would trigger this message type?
What about leg cancel – will there by anything different for a leg cancel as opposed to a flight cancel?
What about when flight (leg) cancellation is rescinded?
Should this type message be able to be done by Feb. 19?
Answer: Cancel Flight was created at the request of the carrier industry. Often, a flight will be cancelled and, since numerous names will already have been submitted for APIS and boarding pass authorization, carriers asked if there would be a way of submitting a single message indicating a flight was cancelled. The Cancel Flight message is for the information associated with the international leg of a particular flight; therefore if the leg cancellation is associated with the international leg, the message would be a flight cancellation message. If a flight cancellation has been submitted and the cancellation is rescinded, the carrier will need to re-submit a complete APIS manifest. The flight cancellation function will not be required by the February 19, 2008 date.
- In reference to the requirement of full/complete APIS no later than 30 minutes prior to departure and/or up to door close: Does this mean that all APIS data elements (including the US Destination Address, when applicable) are required no later than 30 minutes prior to door close or just the MRZ APIS data fields? Or does this mean just the data required for vetting purposes, and that, in actuality, a carrier could follow-up with a final APIS transmission to CBP upon flight close?
Answer: As stated in the APIS Pre-Departure Final Rule, full and complete APIS data must be received prior to securing of the aircraft doors. Full and complete APIS data is based on the information required under the APIS Final Rule. That data includes the following data fields:
Last name
First name
Middle name (if available)
Valid date of birth
Gender
Document type
Document number
Document country of issuance
Document expiration date
Country of citizenship/nationality
Country of residence (arrival only)
Address while in the United States (arrival only, visiting foreign nationals)
- Is the APIS-30 pre-departure manifest the same message we send today, which does not include the unique passenger ID
Answer: Generally speaking, the message submitted by carriers today is the APIS non-interactive batch message. In order to meet the APIS interactive batch message, there are changes to the message format, specifically in the UNB segment.
- Can both the pre-departure manifest and the Flight Close-Out message be sent using teletype until we have the MQ with AQQ
Answer: Yes, pre-departure transmissions and Flight Close-Out messages can be sent using a telex address.
- The Consolidated User Guide states AQQ must use UN/EDIFACT and Secure Flight must use UN/EDIFACT or XML. Other places in the Consolidated User Guide reference DHS in conjunction with UN/EDIFACT or XML. Another area says AQQ will only accept UN/EDIFACT and SF will accept either. Will CBP accept XM
Answer: XML is an option for purely domestic transactions. CBP will not accept XML formatted messages for international transactions.
- How do the requirements differ between full and complete APIS and boarding pass request
Answer: In order to receive a boarding pass printing result all that is needed is full name and date of birth. Providing this information does not meet APIS submission requirements. Carriers choosing to submit full name and date of birth to receive a boarding pass printing result will still need to provide full and complete APIS data, prior to securing of the aircraft doors.
- We don’t currently print boarding passes for infants with no seat and an infant name field is not required. Can we add the word INFANT to the adult unique reference ID if traveling with an infant so both passengers have a unique reference numbe
Answer: APIS data is required for all passenger’s onboard international flights. What is provided in the unique reference for the infant is a carrier decision, as long as it meets data field limitations.
Unique Identifiers
- Does the airline assign the Passenger Reference Number or does DHS assign this number?
Answer: The Passenger Reference Number is assigned by the aircraft operator.
- How does CPB/DHS view the ‘life’ of the carrier-created unique identifier? Will CBP/DHS attempt to use this for ‘the life of the PNR’? If a passenger becomes an AQQ-selectee on their outbound, DEN-YVR trip, does your process want to know that this same passenger (based on the RFF values supplied by the carrier) on his return trip, is the same guy that was a Selectee two days previous on the outbound tri
Answer: CBP views the unique passenger ID for the life of the directional travel. In the above example, the selectee response is to be used for the departure transmission of DEN/YVR. When the traveler returns, the carrier is expected to submit another clear passenger request, with a new boarding pass authorization result.
- Consolidated User Guide v1.0 Part 1, pg 42, Table 11 (APIS Data Submission Rules) indicates that the PNR never changes. In fact the record locator can change in various situations. Should this change to "informational" instead of "never changes"? For example: a party of two are in the same PNR, they both check-in and get a cleared boarding pass printing result; we then divide the record for some reason and passenger 2 gets a new record locator, but is still cleared because the original boarding pass is still valid.
Answer: If the carrier chooses to use the PNR as the single indicator of reference to a traveler, the carrier cannot change the PNR due to the fact the DHS system will see a second PNR as a new traveler. If the carrier and carrier system provides the PNR and Unique Identifier in the submission, the change of PNR will be received and can be seen as an informational update.
- With AQQ/Secure Flight requiring unique PaxID, if a carrier were to send the same passport info for two individuals in a PNR, how exactly would CBP/Secure Flight handle
Answer: For an international transaction, the AQQ process will process the information and determine if the name, date of birth and document number are associated with a record found on a watchlist.
Updates to APIS Transmissions
- If a passenger checked in and was cleared for one flight to the US, and the passenger is moved to another flight because the flight is full, should the aircraft operator send a cancel reservation (BGM XR), and then a new AQQ request for the new flight?
Answer: Passengers that are reported on one flight and for various reasons do not fly, will be identified through either the Flight Close-Out message or the cancel reservation submission. Since an APIS submission is required for each commercial flight arriving into or departing from the United States, the passenger data must be submitted as part of the new flight.
- Would a Change Passenger Data submission (as defined in Table 11 of the Consolidated User Guide for qualified vs. unqualified changes) be all that is required for a cleared passenger rebooked on another flight? Or do we need to develop the capability to send a Change Flight message for February 19, 2008
Answer: The Change Passenger Data submission is a Secure Flight proposed requirement and is not expected for the February 19, 2008 date. APIS data is required for all travelers on a flight crossing international borders. Therefore, a passenger rebooked onto another flight would require a re-submission of APIS data, to indicate the passengers new flight information.
- Is it possible to move several passengers from one flight, by using a single submission that shows the original flight, followed by the new flight?
Answer: The international UN/EDIFACT transmission standard employed by CBP does not support a message transaction to move passengers from one flight to another. Under the current APIS Pre-Departure process, a carrier can submit a list of passengers on a flight, if these passengers cancel from their original flight; their status will be identified through the Flight Close-Out message or by sending a cancelled flight message.
- The Consolidated User Guide indicates that itinerary is a "qualified" category. How does CBP expect this to work on standby and non-revenue customers? The customer’s itinerary could change numerous times within a day.
Answer: Passengers that are reported on one flight and for various reasons do not fly, will be identified through the Flight Close-Out message or the cancel reservation submission. Passengers traveling on multiple international flights, within a given day, will require separate APIS transmissions for each flight. Since an APIS submission is required for each commercial flight arriving into or departing from the United States, the passenger data must be submitted for each new flight.
- When there is an unscheduled extra-stop after the passenger has departed, or a diversion enroute, do we need to inform the government via a passenger update message
Answer: Under the initial stages, unscheduled stops, that do not afford the ability for a passenger to de-plane, will not require a re-transmission. It is possible this will change, based on the final determination of the Secure Flight rule.
- Can we retain the original vetting indicator if a passsenger is rebooked for a flight on the same day, to the same destination, if the PNR address changes, or if the flight was delayed into the next day
Answer: Under the APIS Pre-Departure Final Rule requirements, an individual that is rebooked on to another flight would require a new APIS transmission. That new APIS transmission will initiate a new screening response from the CBP system.
- If a flight is delayed for its arrival or departure and the new time is a different date, does the carrier have to submit a new APIS manifest for each passengers
Answer: Whenever an international flight departure from or arrival in to the United States changes dates it requires a complete re-submission of data for travelers.
- Consolidated User Guide page 59, Section 5.3.3 Data Validation – Please confirm that a message validating the data does not have to be sent for AQQ, only Secure Flight
Answer: Section 5.3.3 of the Consolidated User Guide has a CBP-specific response which states that carriers are required to validate data previously submitted with that being presented by the traveler. In accordance with the APIS Pre-Departure Final Rule published August 23, 2007, validation must be done prior to the traveler gaining access to their intended aircraft. If the data provided matches that which was previously submitted for APIS compliance, then a subsequent message is not required.
APIS Batch
- What is APIS batch? Is APIS batch intended to send message over TTY or MQ
Answer: APIS batch is generally what carriers are providing today. Non-interactive batch is an asynchronous message. It can be sent over either TTY or MQ.
- What is APIS Interactive Batch?
Answer: APIS Interactive batch is the same batch message sent today, with a change in the UNB segment indicating the carrier is expecting an answer.
AQQ Interactive
- Can the AQQ transmission be applied for an entire family or party within the same PNR at the same time/same counter at check-in?
Answer: The AQQ transmisison option can be used for a reservation containing up to 99 names in a single transmission, however each traveler must be uniquely identified within the transmission to ensure a boarding pass authorization can be uniquely identified to each traveler within the submission. If an AQQ submission contains more than 10 records, the 4 second response time will not be upheld.
Response Messages
- Is it correct that an acknowledgement from air carriers to DHS is not necessary
Answer: Carriers will not have to acknowledge messages received from DHS that were originated by the carrier. If the message is an unsolicated message, the carrier is expected to provide an acknowledgement of this message type.
- If a carrier in the pre-departure (~72 hours) batch process sent a last name/first name and date of birth that matched a name and date of birth on the watchlist, would they get an inhibited response or insufficient data/error response?
Answer: A transmission containing full name and date of birth which matches a name on a watchlist will be returned with an inhibited response. Providing full name and date of birth does not meet APIS data requirements, therefore the response returned is a vetting response and does not include an APIS compliance evaluation.
- If a carrier gets an inhibited response, what are all the ways a they are able to remove the inhibited response before allowing boarding pass issuance
Answer: When a transmission is provided in a pre-check-in environment and the initial vetting result is returned ‘inhibited’, the carrier will be able to provide subsequent information that may resolve the initial ‘inhibited’ response. If the subsequent information is provided through the check-in process and the vetting response continues to be ‘inhibited’ the carrier will be provided a 24-hour contact number to call and to resolve the ‘inhibited’ vetting result. Carriers should contact TSA/OI for further instructions when resolving travelers identified as inhibited.
Unsolicited Messages
- How is the change of status from ‘not cleared’ to either ‘selectee’ or ‘cleared’ communicated to the air carrier?
Answer: In most cases a passenger that is initially identified as ‘not-cleared’, a resolution process will occur. During that resolution process if the passenger is determined to not be the subject of the record, the carrier may be advised to send another vetting request and will then receive a new vetting response, or the carrier may receive an unsolicited message changing the result from ‘not-cleared’ to either ‘selectee’ or ‘cleared’. If a carrier submits using an interactive message, the ‘unsolicited message’ is returned through the same transmission method as the manner in which it was sent. If a carrier uses a SITA connection, the ‘unsolicited message’ will be returned to the sending address.
- Are unsolicited messages only going to be used for status change from 'cleared' to 'inhibited'? If not, what other types of info would be included in an unsolicited message?
Answer: If a traveler is initially identified as ‘inhibited’ and through a resolution process they are identified as either ‘cleared’ or ‘selectee’, dependent on the timing of the resolution and a subsequent vetting request, an unsolicited message may be initiated. In that case the message may be sent with either ‘cleared’ or ‘selectee’.
- What value should the carrier return to DHS, if their system cannot find the passenger referenced by the RFF values in the DHS UNSOL message?
Answer: It has been determined a code of “E” should be added for such a case. The UN/EDIFACT PAXLST Implementation guide will be updated.
- Page 43 of 66, Table 12 lists that an Acknowledge Response is to be used to acknowledge receipt of an Unsolicited Message. Qantas is concerned that this requirement will do little more than increase transaction costs and check-in processing times. If CBP issues an updated Inhibited or Cleared response is it not sufficient for the aircraft operator to simply follow the SOP for the particular message response.
Answer: As it has been expressed to CBP, by the carrier industry, messages are sent and returned. With the importance and impact of such a message, it should be understood, when an update occurs, a response has to be expected.
- Pg 38/66 of the Consolidated User Guide - Unsolicited Messages - States that DHS will develop new processes and enhance existing ones for the scenario when a passenger boarding pass printing result had changed after it had been issued and the flight was enroute. Do you know when the operating procedures will be available?
Answer: The procedures expressed in this section will be determined by the results of the Secure Flight Rule publication.
- How should carrier respond if B/P has already been issued, but DHS has sent an UNSOL stating ‘boarding pass issuance’ is inhibited? Does DHS plan to send UNSOL messages that would update their prior selectee passenger to a now cleared passenger? Or will these UNSOL messages only be used to change ‘cleared’ passengers to some other AQQ status?
Answer: The values for element 4440M will equal either Y, for boarding pass issued, or N, for boarding pass not issued. As for unsolicited messages being returned, an unsolicited message will be returned.
Flight Close-Out Messages
- There are times when we close the aircraft door and reopen it. Will the final Close-Out Message be required to be sent no later than 30 minutes from the first or last door closure
Answer: Submission of the Flight Close-Out message is required no later than 30 minutes from the last door closure.
- Because of the above reason there are times when we may have a need to send an updated FCO. Is having multiple FCO Messages acceptable when utilizing the Interactive Individual Message option
Answer: Multiple flight Close-Out messages are acceptable. Under most circumstances only one Flight Close-Out message should be transmitted, and submission of the Flight Close-Out message is required no later than 30 minutes from the last door closure.
- If a passenger is booked on a flight, however, a boarding pass request is not submitted and no APIS data is provided and the passenger never checks-in for the flight, is the carrier required to provide the information for this passenger in the Flight Close-Out message?
Answer: If APIS data has not been submitted for a passenger and the passenger does not travel on the flight, passenger information is not required as part of the Flight Close-Out message.
- This section states that the close-out count may update the final count as previously filed on the General Declaration. Does this clarify that APIS counts will override GenDec counts?
Answer: Carriers are required to provide complete accurate and valid information to CBP, for both APIS and entry requirements (General Declaration). The passenger count provided in the Flight Close-Out message will be one method used when determining APIS sufficiency and establishing the carrier provided complete and accurate data for each traveler onboard the flight.
- Is the Flight Close-Out message a mandatory or an optional requirement
Answer: The Flight Close-Out message is mandatory for carriers using the interactive batch and AQQ transmission methods.
- The close-out message applies only to the interactive transmission option? What is the procedure with non-interactive batch transmission option
Answer: The non-interactive batch process is expected to be used by carriers submitting under the eAPIS process and a separate Flight Close-Out message will not be expected.
- Pg 40/66 of the Consolidated User Guide - Is it our understanding that carriers will no longer need to call in the updated counts once a final Flight Close-Out message is sent?
Answer: The Flight Close-Out message will be used to determine the number of passengers on board an aircraft; however, it will not replace the requirement to provide an accurate and complete general declaration.
- In the Flight Close-Out message it was our understanding that a carrier could send the full APIS manifest along with the PAX ID of those passengers boarded. Is that correct?
Answer: The Flight Close-Out message has never been discussed as a message that would complete APIS submission requirements. The Flight Close-Out message occurs after departure. Full and complete APIS data is required prior to securing of the aircraft doors.
- Please clarify if Flight Close-Out message can only report all passengers boarded
Answer: When coding the Flight Close-out Message, the carrier will either use the code indicating that the records provided represent those passengers that were boarded or use the code indicating that the records provided represent those passengers previously submitted but who did not board the flight. This was requested by the carriers in various meetings. Carriers have the option to determine which submission best suits their systems.
- When is the ‘FCO only’ designation to be used by the carrier? BGM + 266 + CL What supporting sub-elements would need to be included? Could an example of this be added to the Appendix
Answer: A scenario that would involve a Flight Close-out only message would be a carrier opting to provide a Flight Close-out message containing those records, previously submitted, that did not board an aircraft and finding that all names previously provided boarded. In order to accomplish a proper Flight Close-out message, the Flight Close-out only option was provided. Section 6.5.2 references a Flight Close-out only message and an example is not provided. The Appendix will be updated to cover an example.
eAPIS
- Can we still use e-APIS for submission of non-interactive batch transmissions?
Answer: The eAPIS Web Portal will continue to be an option for submitting APIS manifest data under the new APIS Pre-Departure requirements.
- If using e-APIS to submit non-interactive batch transmissions how will carriers be made aware of any not-cleared and selectee status? The rule states the CBP system will respond to non-interactive batch transmissions by sending a message to the carrier via a non-interactive transmission method – what does this mean
Answer: The CBP system will send email messages to carriers using the eAPIS non-interactive transmission method. To ensure the correct office is notified, carriers should update their point of contact information with their CBP APIS Account Manager.
- For flights to Cuba, an aircraft is wet leased to a Charter Company. The Charter Company remits eAPIS to CBP via batch. Will Charter Companies continue to be permitted to remit eAPIS and will the Charter Company indicated on the eAPIS transmission or the operating carrier be notified of not-cleared or unsolicited messages
Answer: Charter Companies can continue to submit APIS data through eAPIS, and the submitter will receive the response message.
- The Rule states that if carriers cannot develop AQQ by the 180 day deadline, they must provide APIS by -30 in a non interactive method (e.g. like today). However, the Rule states that boarding passes cannot be issued until after the -30 manifest vetting has taken place.
Answer: Carriers are currently required to provide APIS data no later than15 minutes prior to departure for flights departing from the United States, the APIS Pre-Departure requirement shifts the submission to no later than 30 minutes prior to securing the aircraft for flights departing from and arriving into the United States. The 30 minute timing is, once again, a “No Later Than” requirement. Carriers are encouraged to submit data earlier in the process to meet both the flights security requirements and the carriers’ operational needs.
- Under the non-interactive 30 batch option: would the air carrier be required to wait for the response from DHS before:
- printing the boarding pass;
- boarding the aircraft
Answer: Under the non-interactive batch submission option, the primary transmitter of this data will come from the eAPIS functionality. Using the eAPIS function, the carrier would need to receive a screening result before allowing the traveler to gain access to their intended aircraft.
- For batch non-interactive, if we send 10 passengers in a message, and DHS sends one PAXID that indicates they are inhibited', will they send a PAXID for each of the other 9 to indicate they are cleared? The FR indicates that you would only get a vetting result for selectee or inhibited. For those on a manifest where all passengers were cleared, would we get a response without any vetting results? Our IS indicates that this could be problematic, that they would be expecting a response for each PAXID
Answer: The non-interactive batch process is strictly related to eAPIS submissions or submissions that are incorrectly coded in the UN/EDIFACT header, where the system does not see the message as interactive. If the message header is formatted to indicate the carrier expects to receive a response and each name is uniquely identified, within their NAD segment, the vetting response will be returned with an individual vetting response for each record. If each name is not uniquely identified, within their NAD segment, then the vetting response for individual travelers may be significantly impacted.
Connecting Passengers
- For customers who are connecting domestic to international can we transmit AQQ at the origin station, instead of waiting until they get to their connection location?
Answer: The purpose of APIS Pre-Departure is to ensure travelers matching the watchlist do not gain access to their aircraft. Carriers with the ability to provide APIS data at a travelers origin station are encouraged to submit APIS data as early as possible. Steps are being taken to amend Security Directives (SD) and Emergency Amendments (EA), issued by TSA, that will allow carriers to apply vetting responses received from CBP against a travelers domestic itinerary. Until the SD’s and EA’s are amended, carriers are responsible for vetting the domestic segment and would then apply the CBP vetting response for the international segment.
- Can a carrier issue a boarding pass to a traveler traveling from one foreign airport to another foreign airport and then their US destination airport, without receiving a vetting response from the government
Answer: As stated in the APIS Finlal Rule published in the Federal Register on April 23, 2007, carriers with connecting passengers arriving at the connecting airport already in possession of boarding passess for a U.S.-bound flight, these passengers cannot be boarded until all required manifest data has been transmitted and a boarding pass authorization has been received.
- Will a carrier requesting a vetting response for a passenger holding a routing of Cairo-Zurich-New York be able to do so using the AQQ option
Answer: If a carrier provides a travelers complete itinerary within the TDT and LOC segments of their submission, the CBP AQQ process will be able to provide a response to the sender of the message. As stated above, carriers with travelers holding a routing from multiple international airports, prior to their U.S.-bound aircraft, can issue boarding passes, so long as the traveler is not allowed to gain access to their intended aircraft, until a proper vetting response has been received.
- Example routing: Miami – New York – Zurich. Assuming that we received the cleared response for the domestic leg, is there any further vetting necessary for the leg JFK-ZRH
Answer: Under the current Emergency Amendments and Security Directives, issued by TSA, carriers are responsible for the vetting of passengers with domestic legs. The APIS Pre-Departure program will take over the vetting for the international leg only. The transmission of APIS data is required for all international arrivals and departures, the CBP system will provide a watchlist screening response for all APIS transmissions until watchlist screening is conducted by Secure Flight.
- In the scenario with a passenger having an itinerary of London to Chicago on one carrier and an itinerary of Chicago to Omaha on another carrier, is the carrier holding the domestic segment required to get a vetting result and apply all security restrictions on the domestic leg of this itinerary, since there is an international segment within the directional travel itinerary?
Answer: Travelers having an international flight itinerary submitted are required to have complete APIS data provided, prior to gaining access to their intended international flight. Carriers should follow TSA security requirements for domestic passengers and domestic flights.
- Do the requirements change at all for the domestic segment of this trip, if the direction changes (now outbound US) OMA-CHI CHI-LON Would the carrier holding the domestic leg have to get a vetting result on the domestic leg of this trip (and apply all security restrictions boarding/not boarding psgr and baggage)?
Answer: Carriers should follow TSA security requirements for domestic passengers and domestic flights
- Is the vetting result per leg or per trip? The Consolidated User Guide indicates per flight leg. Our IS counterparts say this could be a nightmare in terms of exposure to have a different vetting result per leg vs. one vetting result that applies to entire PNR/trip.
Answer: Travelers having international flight itineraries require complete APIS data submitted, prior to gaining access to their international flight. Carriers should follow TSA security requirements for domestic passengers and domestic flights.
- How would we handle directional travel? For example, for the itinerary YVR-ORD-NYC-LHR
Answer: In the example YVR-ORD-NYC-LHR, the single direction arrival submission should contain YVR-ORD-NYC. The single direction departure should contain NYC-LHR.
