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Introduction

Singapore has implemented the Regulated Air Cargo Agent Regime (RCAR) since 1 April 2008 to enhance air cargo security on commercial aircraft to fulfil the requirement by the International Civil Aviation Organization. This measure is necessary to ensure the safety and security of commercial flights in view of the global terrorist threat.

Principles of RCAR

RCAR is based on the underlying principle that aircraft shall operate in secured environment, thereby requiring consignments of cargo transported on commercial aircraft to be subjected to the required level of security measures before they are loaded onto the aircraft. Security measures will be used to screen and clear cargo. Cargo that has been cleared shall then be protected from unlawful interference or contamination until they are loaded onto the aircraft.

Why you should become a Regulated Air Cargo Agent

Air cargo agents may register to be Regulated Air Cargo Agents (RACAs) and be included in the List of RACAs maintained by Police. Air cargo agents who do not wish to register as RACAs may continue their current operations but entire consignments of their cargo will be subjected to full security measures at the airfreight terminals. Charges will be imposed for the application of these security measures and they will be borne by the respective air cargo agents.

RACAs on the other hand, will enjoy lower level of screening of their known cargo as they would have already adopted an acceptable level of security measures in their business operations.

Criteria to be a Regulated Air Cargo Agent

In order to qualify as a RACA, the air cargo agent must be a legal entity registered in Singapore. The air cargo agent will be required to put up a security programme as part of its registration application which will detail the basic security measures and procedures across its entire supply chain including the storage, packing and transportation of cargo.

Registration

To register as a RACA, the air cargo agent shall submit a duly completed application form and the following documents to support its registration:

  1. the name, registration number and address of the air cargo agent’s business, company or limited liability partnership;
  2. the business profile of the air cargo agent’s business, company or limited liability partnership including details of its:
    principal activities;
    1. principal activities;
    2. principal place of business;
    3. trading name if it differs from the name of the business, company or limited liability partnership; and
    4. sole proprietor, managers, partners, directors, office bearers and shareholders;
  3. the air cargo agent’s Security Programme

Security Programme

The security programme is a document that describes the security measures and procedures to be used by RACA in securing and clearing consignments of cargo. It contains details of the RACA and its operations as well as a list of security personnel and third party service providers. In addition, it also specifies the standards of protection for cargo including the physical security of these premises. This security programme must be submitted to Police for approval. The approved security programme must be fully implemented and complied with by the RACA. RACAs can expect to be audited by the Police on its compliance with the security programme.

Security Screening at Airfreight Terminals

Security measures will be carried out by the Cargo Terminal Operators when RACAs lodge their cargo at the airfreight terminals. It is important that RACAs differentiate their cargo into known and unknown and inform the Cargo Terminal Operators accordingly so that the correct levels of security measures can be imposed on the different cargo. This can be done by indicating on the export control form accordingly. Known Consignor should be represented by indicating “KC” on the export control form just beside the MAWB number. Similarly, for Unknown Consignor, it should be represented by indicating “UC” on the export control form.

Only cargo from known consignors and RACAs will be deemed as known cargo. Unknown cargo, referring to those that are not from known consignors or RACAs, shall be fully screened and the screening charges borne by the air cargo agent.

The criteria to recognise a consignor as known consignor is determined by the Police and will be made known to the RACAs.

(Note: This practice shall only apply to RACAs)

Audits

RACAs are expected to audit their own operations and self-evaluate their compliance to the approved security programme and to maintain records of such audits. Police will conduct surprise audits on the RACAs to ensure that the RACAs implement their security programme in its entirety and that it complies with all the conditions imposed by Police.

The RACAs are also required to engage an accredited auditor (who are recognised by Police) to audit its compliance with the approved Security Programme not more than 6 months before the expiry of its 3-year registration. RACAs will bear the cost of this audit and will need to pass the audit 1 month before the current registration validity expires before its registration can be considered for renewal.

Criteria to be a Regulated Air Cargo Agent

To be a regulated air cargo agent, the air cargo agent shall have fulfilled the following criteria:

1. The applicant is a legal entity and is a business, company or limited liability partnership which is registered under the relevant law in Singapore.  
2. The applicant including its sole proprietor, managers, partners, directors, office bearers and shareholders are fit and proper persons
3. The applicant’s security programme complies with the specified requirements.
4. The applicant’s inclusion in the List of Regulated Air Cargo Agents will not pose a significant risk to aviation security.
5. The applicant agrees to seek Police’s approval before making any change to security arrangements which may impact the air cargo agent’s ability to maintain security standards.

Applicant’s Details

The applicant must be the owner, partner, manager or director of the business or company, and whose name appears in the company’s ACRA business profile.

Application Procedure

The applicant is required to complete and submit a hardcopy of the completed application form together with:

1. the final copy of the Regulated Air Cargo Agent Security Programme (RACASP);

2. the latest copy of the business profile obtained from the Accounting and Corporate Regulatory Authority (ACRA) (not more than a month from the application date); and

3. a copy of the cargo agent’s industry certification (STP, TAPA Cat A or B, C-TPAT Tier 2 or 3) where applicable

For more information on STP, please refer to the following website:
https://www.customs.gov.sg/businesses/customs-schemes-licences-framework/secure-trade-partnership-stp

For more information on TAPA, please refer to the following website: 
https://www.tapa-apac.org

For more information on C-TPAT, please refer to the following website: 
https://www.cbp.gov/border-security/ports-entry/cargo-security/CTPAT


The completed application form and relevant documents may be submitted to the following address:

(By Post)  Regulatory Development Unit / Security Regulatory Branch
Airport Police Division
35 Airport Boulevard Road
Singapore 819645 
(By Hand)  Security Regulatory Branch
60 Airport Boulevard
Changi Airport Terminal 2
#047-004
Singapore 819643

 

General

1. What is the Regulated Air Cargo Agent Regime about?

The Regulated Air Cargo Agent Regime (RCAR) is a security measure to enhance air cargo security on commercial aircraft. Singapore has implemented the RCAR since 1 April 2008.

2. How will RCAR affect air cargo?

The RCAR is based on the underlying principle that an aircraft shall operate in a secured environment, thereby requiring consignments of cargo transported on commercial aircraft to be subjected to the required level of security measures before they are loaded onto the aircraft. Security measures will be used to screen and clear cargo. Cargo that has been cleared shall then be protected from unlawful interference or contamination until they are loaded onto the aircraft.

3. Is there any legislation governing the RCAR?

The legislation governing the RCAR would be known as the Air Navigation (Regulated Air Cargo Agents and Known Consignors) Regulations 2017.

4. What is a Regulated Air Cargo Agent (RACA)?

An air cargo agent refers to a registered business, company or limited liability partnership in Singapore that carries on the business of handling cargo intended for carriage on commercial aircraft and delivers such cargo, whether by himself or a third party, to an aircraft operator. Air cargo agents may register to be Regulated Air Cargo Agents (RACAs) and be included in the list of RACAs maintained by Police.

5. How can I apply to be a RACA?

Forms can be downloaded from the RCAR website at www.spf.gov.sg/rcar. To register as an RCA, the air cargo agent shall submit a duly completed application form and the following documents to support its registration:

  1. the name, registration number and address of the air cargo agent's business, company or limited liability partnership;
  2. the business profile of the air cargo agent's business, company or limited liability partnership including details of its:-
    1. principal activities;
    2. principal place of business;
    3. trading name if it differs from the name of the business, company or limited liability partnership; and
    4. sole proprietor, managers, partners, directors, office bearers and shareholders;
  3. the air cargo agent's Security Programme 

6. Is it compulsory to be registered as a RACA?

Air cargo agents who do not wish to register as RACAs may continue their current operations but entire consignments of their cargo will be subjected to the full extent of security measures at the airfreight terminals. Charges will be imposed for the application of these security measures and the charges will be borne by the respective air cargo agents. RACAs, on the other hand, will enjoy a lower level of screening of their cargo that is from known consignors as they would have already adopted an acceptable level of security measures in their business operations.

7. Are 3rd party service providers required to be registered as an RACA?

No. If you are a third party service provider e.g. involved in cargo transportation or storage, there is no registration required. The RACA shall be responsible to ensure secured operations throughout their entire supply chain. The RACAs will therefore have to ensure that its third service providers comply with the RCA's security programme.

8. Will I need to change the way I do business?

If a suitable security regime is already in place and you have applied all of the security measures that the RCAR requires, then your operations will be largely unaffected.

9. Are there any changes that I will have to notify the Police?

Yes, if at any time details in the information (e.g. particulars of company) that you supplied in the registration form changes, you must notify the Police within 7 days of the change in such form as the Police may require.

10. How is cargo from a known consignor routed through a non-RACA treated?

Cargo from non-RACAs would be treated similar to cargo from unknown consignors and will be subjected to 100% screening.

11. Cargo could be built up and consolidated to enjoy better shipping rates. However, this may include both known and unknown cargo. Is there a need to break down the cargo in the consolidation so that the unknown cargo can be screened?

No. If the consolidated cargo consists of both known and unknown cargo, the entire consignment of cargo will be treated as unknown and will be subjected to 100% screening by the cargo terminal operator.

12. Most of the cargo handling processes are outsourced and run by third party service providers. Why are they not regulated by the State under RCAR?

As the cargo agent still retains overall responsibility for the cargo, the State has thus chosen to regulate at the cargo agent level to promote accountability. Even though the cargo handling processes may be outsourced and taken care of by third party service providers, RACAs must ensure that the security of the cargo is not compromised. This should be enforced through the cargo agent’s service contracts with the third party service providers.

13. Can I recognise a consignor as a known consignor for RCAR if my company regularly handles inbound cargo from him?

No. To recognise a consignor as a known consignor, the shipping history strictly applies to local outbound cargo only and does not include shipping history for inbound cargo.

14. Is RCAR applicable to cargo transported on freighter aircraft?

The RCAR is applicable to cargo transported on all commercial aircrafts.

Registration

1. Can I process and ship cargo if I am not registered to be RACA?

A non-regulated air cargo agent may continue to ship cargo through the cargo terminal operators. However, all cargo from non-RACAs will be treated as unknown cargo and will be subjected to 100% screening.

2. Can my registration be suspended or cancelled?

Yes, Police may suspend or cancel a RACA's registration and remove it from the List of Regulated Air Cargo Agent if Police is satisfied that the RACA:

  1. RACA has failed to comply with any conditions of registration
  2. RACA has failed to comply with any provisions of the Air Navigation (Regulated Air Cargo Agent) Regulations, whether or not the RACA has been convicted of an offence for the contravention or non-compliance;
  3. RACA is in or is likely to go into compulsory or voluntary liquidation other than for the purpose of amalgamation or reconstruction, or the RCA is declared bankrupt;
  4. RACA has ceased to carry on the business of an air cargo agent in Singapore;
  5. RACA has improperly registered himself as a regulated air cargo agent or provided false information; or
  6. Public interest or national security of Singapore requires.

A regulated air cargo agent whose registration has been cancelled may not reapply to be registered and included in the List of Regulated Air Cargo Agents, until after the expiry of the period of 12 months from the date the registration was cancelled.

Security Programme

1. Why is there a need for a security programme?

The main objectives of a security programme is to safeguard against unlawful interference with aviation by ensuring the security of air cargo handled (or for which arrangements are made) by all parties. Implementing a security programme for its operations will allow the RACA to comprehensively protect air cargo along its supply chain.

2. What should be included in my security programme?

The security programme should include all aspects of the security standards and measures implemented by the RACA. A template listing the various requirements will be given to the applicant.

3. How do I put up my security programme?

RACAs may refer to the SPF RCAR Security Manual for guidelines on drafting the security programme.

4. How do I indicate Known Consignor/Unknown Consignor to the CTOs?

Known Consignor should be represented by indicating "KC" on the export control form just beside the MAWB number. Similarly, for Unknown Consignor, it should be represented by indicating "UC" on the export control form.

5. Is the Known Consignor status transferable between RACAs?

No, it is not transferable.

Security Measures And Enforcement

1. As a RACA, do I have to provide updates of my security measures?

Any changes or updates made to the RACA’s security programme must be submitted to the Police for approval.

2. Will each RCA need a Principal Officer Responsible for Security Matters?

Yes. You will need to nominate a specific as well as an alternate person who will be responsible for your company's policy on security and the development and implementation of all security procedures stated in the security programme. He/She will need to understand the requirements of the RACA regime, in particular, the security measures that are to be implemented, and will also be expected to review the Security Programme as and when directed by the Police by a specified date. The RACA will need to reflect details of the officers responsible for security measures in the registration form.

3. Why do you want the name, address, email address and phone number of a person to receive communications?

It is essential that we have a contact person (who shall be at senior management level e.g.. Security Manager) to deal with, within your organisation. This person will receive (on behalf of your organisation) new information or updates that may affect the RCA regime, as well as any directions that may be issued by Police to review or enhance the RACA's security measures in response to any aviation security threats.

4. Can I outsource the security duties?

Yes, but the RACA is still accountable. You must ensure that the contracted service provider is competent to carry out the specified duties.

5. My company handles transhipment cargo and re-lodges them at the AFT for exports. Would I be liable if the cargo within are found to be contrabands or illegal exports?

If contrabands or illegal exports are found in consignments of cargo, police investigations will be initiated. If your company is found to be lacking in the enforcement of security measures as stipulated in the Security Programme or to have knowingly committed a criminal act, you may be prosecuted.

6. There seems to be a lot of requirements and security measures imposed on the RACAs. This would add to the business cost and increase RACAs’ operational cost. What are the incentives or return of investment that we can benefit from being RACAs?

Better cargo security will enhance your company’s reputation and increase confidence in Singapore as a logistics hub. Furthermore, cargo belonging to RACAs will enjoy lower level of screening, thus incurring less screening costs.

7. What is the cost of the external audit that will be conducted by the accredited auditor? Would this be borne by the RCA? If the cost of such audit is high, it may not be worthwhile for my company to register as RACA if our operations and air freight volume are small.

The police will not intervene in the fees charged by the accredited auditor for the external audit. This will be a business transaction between the RACA and the accredited auditor. The cost will have to be fully borne by the RACA and there will not be any subsidy given by the Police.

Screening Requirements

1. My staff are also trained by the respective X-ray vendors. Can I conduct my own screening?

Police is the approving authority for the certification of x-ray operators deployed at Singapore Changi and Seletar Airports. Currently, screening of cargo are only approved to be conducted at the air freight terminals and premises of Air Express Couriers.

All documents are in Acrobat Format (PDF) unless otherwise stated.

Air Navigation (Regulated Air Cargo Agents and Known Consignors) Regulations 2017 [LINK]

Change of Particulars

Application

* Note: Legislation is reproduced on this website with the permission of the Government of Singapore. Acts of Parliament are available without charge and updated monthly, at the Singapore Government Statutes Online website. To purchase Singapore Legal Publications, please click here for more information.

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