- EU Implementing Regulation 2024/1255 makes targeted amendments to EU Regulation 2015/1998, strengthening the application of aviation security measures for cargo and mail. The intervention does not introduce a new regime, but clarifies obligations, responsibilities and protection methods across the entire logistics chain.
- The main impact concerns road hauliers operating upstream and downstream of airports, who are required to guarantee the continuous protection of consignments that have already undergone Avsec checks. Road transport becomes an integral part of the secure chain, with documentary, procedural and training obligations aligned with those of regulated agents and air carriers.
- The regulation also reinforces the recognition of the security status of consignments and the role of Competent Authorities in verifying the continuity of protection. Looking ahead, it consolidates a supply chain model in which security is no longer confined to the airport, but extends to surface transport stages.
EU Implementing Regulation 2024/1255 of the European Commission, adopted on 3 May 2024 and published in the Official Journal of the European Union, amends EU Implementing Regulation 2015/1998, which contains the detailed provisions for implementing the common basic standards on aviation security established by Regulation (EC) No 300/2008. It is a targeted amending act, without autonomous systematic scope, but with significant effects for the air cargo and mail supply chain.
From a legal perspective, EU 2024/1255 does not introduce new categories of operators or new primary obligations, but refines definitions, responsibilities and operational requirements already present in the Avsec framework. The objective is to reduce areas of interpretative ambiguity, strengthening the consistency of measures across the entire supply chain, including surface transport to and from airports. The Regulation therefore acts on the annex to EU 2015/1998, which sets out in detail the requirements for cargo and mail, with particular reference to the protection of consignments after the application of security controls.
At the core of the intervention is the principle of continuous protection against unauthorised interference. EU Regulation 2015/1998 already provided that cargo and mail, once subjected to valid security controls, must be protected until loading onto the aircraft. EU 2024/1255 reinforces this principle by clarifying that this obligation extends continuously to all stages of the chain, including production, packaging, storage, dispatch and transport, even when these activities are carried out by different parties and at different locations.
Within this framework, the security status of consignments, namely Spx, Sco and Shr, takes on particular importance. Spx status identifies cargo and mail secure for transport on passenger and all-cargo aircraft; Sco status limits transport to all-cargo or all-mail aircraft; while Shr applies to consignments classified as high risk and subject to enhanced measures. The Regulation clarifies that the recognition and maintenance of these statuses depend not only on the application of initial controls, but on the ability of the entire supply chain to guarantee the protection of the load from tampering or unauthorised access.
From a legal standpoint, EU 2024/1255 also strengthens the role of Competent Authorities, which are required to verify not only the internal processes of regulated agents, air carriers and known consignors, but also the way in which these operators manage outsourced activities, including road transport. Avsec validation and inspections therefore become tools for assessing the supply chain as a whole, rather than individual links considered in isolation.
It is in this context that the role of the road haulier takes on new relevance. The Regulation does not formally create a new autonomous legal category, but reinforces what is already provided for under point 6.6 of EU Regulation 2015/1998, according to which a regulated agent may entrust the protection and transport of consignments to a carrier that meets specific requirements. EU 2024/1255 clarifies that such entrustment is not purely logistical in nature, but implies the integration of the road carrier into the security chain.
From an operational perspective, this means that a road haulier transporting cargo or mail that has already undergone Avsec checks must guarantee protection conditions equivalent to those provided in sterile airport areas. The vehicle, loading methods, stops, emergency management and the driver’s conduct become elements relevant to aviation security. The truck is no longer merely a means of transport, but a functional extension of the secure chain.
The rules require that there be no unauthorised interference during transport and that the load is not left unattended. Unscheduled stops must be avoided and, if unavoidable, managed in accordance with precise procedures. Upon resuming the journey, the driver must verify the integrity of doors, locks, seals and load units. In the event of anomalies, the consignment must be considered no longer protected and immediately reported to the party responsible for security, interrupting the chain until a new decision is taken on the measures to be adopted.
Another important aspect concerns documentation. Traceability of the security status of consignments is a central element of the Avsec system. The road haulier must always be able to retain and present the documentation accompanying the load, including the identifiers of the regulated agent, the Spx, Sco or Shr status, the basis on which that status was assigned and the time references of the controls carried out. Every transfer of responsibility must be recorded, as must any interruptions or events that could affect the protection of the load.
The regulation also strengthens the link between surface transport and access to airport areas. Vehicles and drivers accessing airside areas or critical parts must be subject to specific checks, hold valid authorisations and be inspected in accordance with established procedures. Here too, road transport is treated as an integral part of the security system rather than an external activity.
A fundamental element is represented by security programmes and staff training. Operators involved in the Avsec chain must adopt programmes that describe in detail the measures applied, responsibilities and self-monitoring systems. Road hauliers operating on behalf of regulated agents must be included in such programmes or have their own programmes consistent with regulatory requirements. Training of personnel, including drivers, therefore becomes an essential prerequisite for maintaining the security status of consignments.
Overall, EU Implementing Regulation 2024/1255 consolidates a security model based on continuity and shared responsibility. Every link in the chain, including surface transport, is required to guarantee the same level of protection, failing which the security status of cargo or mail is lost.
A.I.
