Update on third country operator (TCO) exemptions for cargo transportation in passenger compartments

Following the global logistic disruption caused by COVID-19, some TCO authorisation holders were granted exemptions, issued by their competent authorities, that allow for the transportation of cargo in the passenger cabin of large aeroplanes. Based on the issued exemptions and a review of the related documentation, the European Union Aviation Safety Agency (EASA) did not object to this kind of operation to support the transportation of medical supplies and other important goods into, within, or out of EU territories as efficiently as possible. 

After reviewing the operational context for transport of cargo in passenger cabins, EASA concluded that the logistical challenges that arose in 2020 due to the COVID-19 crisis, no longer exist to the same extent. Therefore, with the increasing traffic, cargo capacity in the holds of passenger aircraft is expected to increase by summer 2022, thus reducing the pressure on the logistic chain.

Under the current circumstances, EASA decided that the non-objections granted for cargo transportation in the passenger cabin will only be valid until July 31, 2022.
EASA will continue to issue non-objections to transport cargo in cabin operations until July 31, 2022, if operators are able to confirm that airworthiness aspects had been considered as part of the exemption process.

The following is considered as proper supporting evidence:

• Original Equipment Manufacturer (OEM) changes;
• Supplemental Type Certificate (STC);
• Airworthiness approval issued by State of Registry according to ICAO Annex 6;
• Evidence from the competent authority (e.g., circular, letter, guidance document) confirming that airworthiness aspects were taken into consideration;
• The Operator’s approved operations manual covering airworthiness aspects linked to the exemption; or
• A risk assessment made by the operator confirming that airworthiness aspects have been taken into consideration.

The following limitations remain in force:

• Carriage of dangerous goods in the passenger cabin is not authorised, with the exception of vaccines cooled by ice;
• Carriage of mix passengers and cargo in the cabin at the same time in not authorised (except if the aircraft is certified as “combi” aircraft);
• Cargo shall only be transported by operators holding valid cargo transport approvals.

After July 31, 2022, as a matter of demonstrated urgency for the transportation of medical supplies only, TCO holders may exceptionally apply for a new or an extended EASA non-objection. In addition to the ‘standard supporting evidence’ as described above, the operator will need to demonstrate the ‘urgent need’ of such a request. Finally, the EASA non-objection will be limited to ‘medical supply’. During SAFA/RAMP inspections, TCO holders may be requested to provide proper justification of the nature of the cargo being ‘medical supply’, as well as of the urgent need. 

Please note that in addition, the above-listed limitations will remain in force.

Additional information and guidance may be found in:

Should you need further clarifications, please contact TCO [at] easa.europa.eu.
EASA Air Operators Oversight Section