private aircraft eapis memo.pdf

Law Offices

ROLLER & BAUER, PLLC

Moffett B. RollerLee A. Bauer

Washington Dulles International Airport45005 Aviation Drive; Suite 200

Dulles, VA 20166

Phone: 202-331-3300Fax: 202-331-3322

[email protected]

May 2009

MEMORANDUM - eAPIS Requirements for Private Aircraft

Basic Information;

Effective May 18, 2009, U.S. Customs and Border Protection (CBP) is requiring eAPISreports for all private, i.e., non-commercial, flights to and from the United States.Commercial flights are already required to file eAPIS reports, and there is no change tothat requirement. In this Memorandum we discuss how the new rule affects privateflights to and from Mexico, including how this requirement is similar to -- and differentfrom -- the existing requirement for commercial flights.

Mexican air taxis should enroll to make private eAPIS reports.

One result of the new rule is that eAPIS reports will be required for all flights bothcommercial and private between Mexico and the United States. Because an air taxithat normally operates commercial flights may also operate private flights occasionally,air taxis should also enroll to make eAPIS reports for private flights. If you are uncertainwhether a particular flight is commercial or private for purposes of submitting thecorrect eAPIS report, please contact us at 202-331-3300.

We recommend that you use this Memorandum as a guide as you go through thesteps (described below) to enroll, to enter crew information, and to prepare andsubmit a private flight manifest on the CBP eAPIS website: http://eapis.cdp.dhs.gov

PART I -- ENROLLMENT & VALIDATION -- EAPIS REPORTS FOR PRIVATE FLIGHTS

Step 1 - Enrolling to create a private aviation account

A Mexican air taxi cannot use the Sender ID and password that it uses forcommercial eAPIS information to make private eAPIS reports. The air taxi must enrollseparately to make private eAPIS reports.

1. Go to the eAPIS web site: https://eapis.cbp.dhs.gov

2. Click on Enroll under (even though the air taxi is alreadyO> New eAPIS Usersenrolled to make commercial eAPIS reports).


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Terms and Conditions

3. Read the End User Terms and Conditions on the next screen. To accept theseTerms and Conditions, click I agree and then click .NEXT

Enroll - Select Account Type

4. On the next screen, entitled Enroll Select Account Type, click Private Aviationto indicate that the new account will be used for private aviation transactions and thenclick .NEXT

Enroll - Private Aviation Account

5. On the next screen, entitled Enroll -- Private Aviation Account, enter information inall of the fields marked with a red asterisk ( r ).The red asterisk means that an item ofinformation is required. If a field does not have an asterisk, you do not have to provideit, but it is a good idea to provide this information if you can. (We use the word fieldsto identify the white boxes where you enter information on the eAPIS website.)

Primary Point of Contact (POC) &Alternate Point of Contact

The Primary Point of Contact (POC) is the person at your air taxi company whom CBPshould contact first about eAPIS matters. The Alternate Point of Contact is the personwhom CBP should contact about eAPIS matters if the Primary Point of Contact is notavailable.

IMPORTANT The email address for the Primary Point of Contact is the emailaddress that CBP will use to send instructions for every private flight to or fromthe United States. Someone at your company must be able to access the emailaccount during flight operations.

Create Your Password

Choose a password and enter it again in the boxes under Create Your Password.Your password must be between eight and twelve characters in length. The firstcharacter must be a number. The other characters can be numbers, capital letters,small letters, and at least one of the following special characters:

~ ! # $ % ^ & * ( ) - _ + = { } [ ] | ; : . ? /No character can be repeated consecutively more than two times. For example, yourpassword can include aa, but a password that includes aaa is NOT acceptable.


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Some examples of acceptable passwords are 123xa-abc, 1967lear60!, and11aabbcc##.

Your password is case-sensitive. For example, if you choose a password with capitalletters and with small letters, you must always enter the same capital letters and smallletters when typing your password.

You must remember your password. You cannot retrieve it from eAPIS or from CBP.

You must renew your password at least every 90 days. You can change your passwordby clicking on Reset your password on the Welcome screen.

Click .NEXT

Complete Enrollment

6. If you have entered your information correctly, the next screen will read CompleteEnrollment and state: You have completed all information necessary for enrollment.This screen will list all of the information that you have just entered. You should makesure that all of the information is correct.

TIP: If you have omitted some of the information that is not required, you will getgreen warning messages on this screen. If you do not want to provide theinformation that is not required, you can ignore the message or messages. Ifyou change your mind, click to return to the previous screen and enterBACKthe information. If you do not want to enter the information that is not required,click and then the next screen will read Complete Enrollment.NEXT

If any of the information is not correct, click to return to the prior screen toBACKcorrect the error.

If the information is correct, click COMPLETE ENROLLMENT

Part I - Step 2 - Validating the Account

7. CBP will send an email with enrollment information to the email address for thePrimary Point of Contact. This email will provide an APIS Sender ID for the carrier.The APIS Sender ID will have eight characters: APGA and then four letters or numbers,e.g., APGA123E. Do not expect to receive the enrollment email immediately, however,as CBP is taking up to seven (7) days to confirm enrollments.


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This email will also provide an activation key. You must use the activation key toactivate your account the first time you log in to use your new eAPIS account forprivate flights. You have seven days from the date of the email to activate youraccount. If you do not activate your account within this seven-day period, you will haveto start over, that is, re-enroll with eAPIS and receive another email with a newactivation code.

8. a. To activate, go to https://eapis.cbp.dhs.gov

b. Under Log In under Enrolled Users, enter the APIS Sender ID that youreceived from CBP, e.g., APGA1234.

c. Enter the password that you selected and click Log In O>

d. After you log in, you will see a screen that requests the activation code.Because the activation code is long, you may want to copy the activationcode from your email and paste it into the space for the activation code.Click Activate. If you have successfully enrolled, you will then go to ascreen entitled Private Aviation - Manifest Options where you can beginthe steps necessary to enter crew member data and to create and submitthe information for a private flight manifest.

PART II -- Using eAPIS to Submit Reports for Private Flights:

The procedure for using eAPIS to make reports for private flights is very similar butnot identical to the procedure for making reports for commercial flights. Mexican airtaxis that have been making commercial eAPIS reports should be generally familiar withthe steps that are outlined below.

Deadline for Submitting eAPIS reports for Private Flights

Inbound & Outbound Flights. eAPIS Notices of Arrival for flights inbound to the U.S.and Notices of Departure for flights outbound from the U.S. can be submitted as far inadvance as you wish, but they must be submitted no later than 60 minutes prior todeparture for both inbound and outbound flights. As explained below, you cannot takeoff until you receive an email from CBP and comply with all of the instructions in theemail.

Continuance Flights -- Not Applicable. You do not need to file an eAPIS report for aprivate flight between two points in the United States, i.e., a continuance flight.(Commercial flights by air taxis must file crew data, but not passenger data, forcontinuance flights.)


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Overflights -- Not Applicable. You do not need to file an eAPIS report for private flightthat passes through U.S. airspace but does not take off or land in the U.S., i.e., anoverflight. (Note: Commercial flights must file crew data, but not passenger data, foroverflights through U.S. airspace.)

Part II, Step 1 - Entering Crew and Pilot Information

Before you can submit eAPIS reports for private flights operated by a Mexican air taxi,you will need to log on to the eAPIS web site and enter the data for the crew memberswho will be operating the aircraft on private flights.

1. Go to https://eapis.cbp.dhs.gov

2. On the Welcome screen, enter your Sender ID, e.g., APGA1234, and passwordunder Log In. Click Log In O>

3. The next screen will be the Terms and Conditions screen. Click I agree andthen click .NEXT

4. The next screen is entitled Private Aviation - Manifest Options. Underclick Update or Create Crew and Pilot Information.

NOTE: Use to change your passport or to update information forthe account holder. You should not use because this optionrequires the preparation of a flight manifest in a special format.

5. The next screen is entitled Crew Maintenance. Click ADD CREW under AddCrew Information:

6. The next screen is entitled Add New Crew Member. Enter the information for yourfirst crew member. You should enter information in every field. You must enterinformation in fields that are marked with a red asterisk ( r ). If you do not, eAPIS willnot add the crew member to your list. Even though eAPIS will accept (with a warning)crew information that omits data in fields that do not have a red asterisk, it is notadvisable to omit any information. Some of these information fields are required whenyou make eAPIS reports even though they are not marked with a red asterisk.


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For Country of Residence & Country of Citizenship, the code for Mexico is MEX.

Under Document Information, for Document 1 enter the passport information for thecrew member. Again, for Mexican citizens the code for Country of Issuance will beMEX. Although eAPIS does not require that you enter information for Document 2,"you should enter the Pilots License information for Document 2 for every crewmember who is a pilot. Later, when you create a flight manifest, eAPIS does requirepilot license information for the crew member who is listed as the pilot for the flight.

7. After you enter all of the information for a crewmember, click .ADD CREW

8. You will then return to the screen where you will see, under theheading Crew List: the name and date of birth (DOB) of the crew member that youhave just entered.

Updates or Corrections: To the right of the name and DOB of the crew member is a red caret( v ) under the heading Update Information. If you need to change any of the information fora crew member, click on the red caret and you will go to a screen entitled Update CrewMember that contains the information that you previously entered for this crew member.Update or correct this information as necessary.

9. Add additional crew members until your Crew List is complete. If you do not need tofile an eAPIS manifest for a private flight at this time, click Log out [X] at the top of thescreen. The information for the crew members will be automatically saved in the eAPISwebsite for use in a future eAPIS manifest.

If you do need to file an eAPIS manifest for a private flight, click MANIFEST OPTIONSto return to the initial screen, where you can thensubmit a Notice of Departure or a Notice of Arrival for a private flight.

Part II, Step 2 - Submitting an eAPIS Report for Private Flights

Take the following steps to create an eAPIS report for a private flight that is arriving in,or departing from, the United States,:

1. Go to https://eapis.cbp.dhs.gov At the Log In screen, enter your Sender ID andPassword that you created pursuant to the steps in Part I above.

2. Click I agree to accept the Terms and Conditions and then click .NEXT

3. The next screen is entitled Private Aviation - Manifest Options.


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IMPORTANT NOTE: The second paragraph on this screen contains an emailaddress in bold print. This is the email address of the Primary Point of Contact.CBP will use this email address to send instructions regarding a manifest thatyou have submitted. Someone must be able to access the email from CBP. It isagainst CBP regulations to take off before you receive this email.

4. Under Click Submit Notice of Departure for a flight departing the United States for a pointoutside of the United States, or Click Submit Notice of Departure for a flight arriving in the United States from apoint outside of the United States.

The remaining steps summarize the procedure for submitting a Notice of Arrival. Thesteps for submitting a Notice of Departure are similar.

5. The next screen is entitled Notice of Arrival for _________, where your Sender IDappears in the blank space, e.g., Notice of Arrival for APGA1234."

Aircraft Information

Under Aircraft Information, enter the tail number for the aircraft. Use only letters andnumbers. Do not use a dash. For example, XA123 would be acceptable, but XA-123would not be acceptable.

Foreign Departure Information

Under Foreign Departure Information, first enter the four-letter ICAO code for theairport of departure, the name of the airport, and the state where the airport is located.

On the next line enter the date and estimated time of departure (ETD) in local time atthe foreign airport of departure. Use a 24-hour (or military) format, e.g., 1334, not1:34 p.m.

In the next five fields, enter the four-letter ICAO code for any airport where the aircrafthas landed during the 24 hours prior to the time of departure. If the aircraft has notlanded at any airport during the 24 hours prior to departure, leave all five fields blank.

If an airport at which the aircraft has landed during the 24 hours prior to departure doesnot have an ICAO airport code, enter a name or other information that would identifythe airport. You can enter up to 10 characters to identify each such airport.


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Next enter the Estimated time and location of crossing U.S. Border or Coastline.Use 24-hour format for the local time at the point of crossing and use the nearest U.S.city or town for the location of crossing.

U.S. Arrival Information

Enter the four-letter ICAO code for the U.S. airport at which you will be landing. If theU.S. airport at which you will be landing does not have an ICAO code, enter the ICAOcode for the nearest U.S. airport that does have an ICAO code.

Enter the date of your arrival and your estimated time of arrival (ETA) in local time atthe U.S. airport of arrival. Again, use 24-hour format for entering the time.

Enter the U.S. city for the airport of arrival. In the next field enter the two letter codefor the U.S. state. For a list of the two letter states codes, click on the arrow in the circlenext to the field.

If your airport of arrival has an ICAO code, you do not need to enter anything into theArrival Location Description.

When the U.S. airport of arrival does not have an ICAO airport code, however, enter theICAO code of the nearest airport that does have an ICAO code into the Airport field onthe first line of this section and then enter the name of the actual U.S. airport of arrivalin this Arrival Location Description field.

24 Hour Emergency Contact Information

Enter the last and first name and telephone number of an individual who is not on theaircraft to be an emergency contact. You may also enter an email address, butproviding an email address is not mandatory.

Traveler Counts

Enter the number of crew members and the number of passengers on the flight.

Click to go to the next screen.NEXT


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6. The next screen is entitled Aircraft Information, and the first section on this screenis also entitled Aircraft Information.

Aircraft Information

The tail number of the aircraft is already entered using the tail number that you havealready provided.

Enter the type of aircraft in the Type of Aircraft field, e.g., Gulfstream G-V. Enter itscolor or colors in the Color field, e.g., white with blue stripes.

If you have a call sign that you will use for this flight, enter it under Call Sign.

If you have a CBP decal, enter the number of the decal under CBP Decal Number.

Aircraft Operator Information

The Aircraft Operator can be either an individual or a company. If the Aircraft Operatoris a Mexican air taxi, enter the name of the air taxi company in the Company Namefield, e.g., Aerotransportes Poinsettia, S.A. de C.V.

Enter the Street Address, Apartment or Suite Number (if applicable), City,State/Province, Zip/Postal code, Country, Telephone Number, Fax Number(optional), and Email Address for the Aircraft Operator.

Below is a list of the two letter codes that eAPIS uses for the Mexican states:

AGUASCALIENTES AGBAJA CALIFORNIA NORTE BABAJA CALIFORNIA SUR BJCAMPECHE CECHIAPAS CICHIHUAHUA CHCOAHUILA CUCOLIMA CLDISTRITO FEDERAL DFDURANGO DOGUANAJUATO GU

GUERRERO GRHIDALGO HLJALISCO JLMEXICO MXMICHOACAN MCMORELOS MRNAYARIT NANUEVO LEON NLOAXACA OAPUEBLA PBQUERETARO QU

QUINTANA ROO QRSAN LUIS POTOSI SLSINALOA SISONORA SOTABASCO TBTAMAULIPAS TATLAXCALA TLVERACRUZ VCYUCATAN YUZACATECAS ZA


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Aircraft Owner/Lessee Information

The Aircraft Owner/Lessee can be either an individual or a company.

If the Aircraft Owner is a company and the Aircraft Lessee is a different company,you can enter the name of either company in this field. If the MexIcan air taxi that isoperating the aircraft is leasing the aircraft from another person or company, theMexican air taxi will be the Aircraft Lessee.

Enter the Street Address, Apartment or Suite Number (if applicable), City,State/Province, Zip/Postal code, Country, Telephone Number, Fax Number(optional), and Email Address for the Aircraft Owner or the Aircraft Lessee.

Click to go to the next screen.NEXT

7. In the Select Crew row, the first field is labeled Crew and has the words SelectCrew Member. Click the down arrow to the right of Select Crew Member. A drop-down list will appear that lists the names of the crew members that have already beenentered into eAPIS. If the drop-down list has the names of any of the crew membersfor the flight, click on the name of a crew member and then click SHOW DETAILS inthe adjacent box. The information for that crew member will populate the data fieldsunder Crew Details. (If you have made an error and selected the wrong crewmember, click CLEAR DETAILS and start over by selecting a different crew memberand clicking SHOW DETAILS for that crew member.)

Check the information to make sure that it is correct. Except for the name of the crewmember, you can change any of the information for this crew member for purposes ofthis flight, but making changes for this flight will not permanently change the informationthat you have previously entered for this crew member in eAPIS. To update theinformation permanently, you must separately go to the Crew Maintenance section asdescribed above and make any changes there.

Next please notice the Crew Member Status. It will be either Pilot or Crew, but thecrew manifest for a private flight can only list one pilot. If you have previously listedeach of two crew members for a private flight as Pilot under Crew Member Status,you will need to decide which one will be the Pilot for this flight. You will then need tochange the Crew Member Status for the other crew member to Crew.

Next enter the Street Address, City, State, and ZIP Code for this crew memberwhile in the United States. This can be a hotel, if applicable, but the address mustbegin with a number, e.g. 123 Main Street. If you do not have an address for the crew


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member, e.g., the flight is turning around and leaving the U.S. the same date that itarrives, you can enter the address of a fixed-base operator at your Arrival Airport.

Note: Although this Memorandum is describing the procedure to submit a Notice of Arrival,please note that eAPIS also asks for a U.S. address for each crew member on a Notice ofDeparture. For Notices of Departure we recommend that you enter the address where the crewmember stayed while in the U.S., and if there is no such address, to use the address for a fixed-base operator at your U.S. Departure Airport.

When the information for the first crew member is complete, click SAVE TO MANIFEST

NOTE AGAIN If you have changed any information for a crew member for thisflight, the changed information is only valid for this flight. Any changes are notpermanent until you make the changes in the Crew Maintenance Section

After you click SAVE TO MANIFEST, you will see that crew members Crew Status andName at the bottom of the screen under Manifest Crew List.

To the right of the crew members name is a column with the heading ViewInformation and in this column is a red caret ( v ). If you click on the redcaret, you then reopen the screen with the data for this crew member. Anychanges that you make for this crew member will only apply to this flight.

In the next column to the right is a column entitled Remove from Submissionwith a red dash ( ) to the right of the red caret. If you click on this dash, youwill go to a screen that lists the Name, Date of Birth, and Document Type for theCrew Member and asks, Do you want to remove this Crew Member from theManifest? To proceed with the removal, please select Next. If you do not wantto remove the crew member, select Back to return to where you were in eAPIS.Whether you select Next or Back, you will then return to the Crew Informationscreen.

Continue to add crew members by following this process until you have added all of thecrew members. When you have completed adding crew members, click NEXT STEP.

8. The next screen is entitled Passenger Information.

This screen provides the fields to enter the passenger data for up to five passengers.The data that is required is similar to the data that is required for crew members. Again,please note that a red asterisk ( r ) marks every field that is mandatory.


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NOTE: If your flight has more than five passengers, enter the data for the first five passengerson this screen and then click ADD PASSENGERS at the bottom of this screen. You will then goto another screen that will have space to enter the data for five more passengers.

You should enter each passengers Address While in the United States such as ahotel or private residence if you know this information. It you do not have a U.S.address for a passenger, you can use the address of the fixed base operator at yourairport of arrival. This is the same procedure as when no U.S. address is available forcrew members.

Under Document 1" select Passport under Document Type and then enter thepassport number under Document Number. Next, be certain to enter the Countryof Issuance and Expiration Date for the passport. Even though these two fieldsdo not have red asterisks, the Country of Issuance and Expiration Date aremandatory for persons who are not U.S. citizens.

It is not necessary to enter information under Document 2, but if you have theinformation for any of the other types of documents for a particular passenger, you mayenter it here.

When you are through entering the information for all of your passengers, click.REVIEW MANIFEST

9. You will next go to a screen entitled List of Travelers. This screen lists the namesof all of the persons on the aircraft -- i.e., one pilot, any other crew members, and allpassengers. By clicking on the red caret ( ) next to each traveler, you can view theinformation that you have entered for that person. By clicking on the red minus sign ordash ( ) in the row for each person, you can delete that person from the list.

On this screen you can also click to go back to the first screen,EDIT FLIGHT INFO, where you can review and change the information

that you have previously entered regarding the details of the flight for example,departure and arrival points, aircraft information, dates, times, etc. When you arethrough on that screen, you will then navigate through the screens where you havepreviously entered Aircraft Information, Crew Information, and PassengerInformation to return to the screen entitled List of Travelers.

If everything is complete, click . If you have entered information into all of theDONErequired fields and the information that you have entered is in the correct format, thenext screen will read--


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10.

You have completed all of the necessary information for submitting a manifestthrough eAPIS.

Please review your eAPIS manifest before submitting to CBP.Select Next to review your manifest.

NOTE: The eAPIS program does not check whether the information that youhave submitted is correct. eAPIS can only determine whether you havecompleted all of the mandatory fields and whether the information is in thecorrect format. You are responsible for the accuracy of the information. If youenter an incorrect passport number for a passenger or you fail to enter aCountry of Issuance for a passport, CBP could impose a penalty if a CBPinspector becomes aware of incorrect or omitted information.

If there is an error, the next screen will notify you of the error and require you to correctthe error before you can submit the manifest.

If there is a warning, eAPIS will advise you. You should try to fix the entry that causedthe warning, but you can choose to ignore the warning. You will still be able to submityour manifest.

If your screen displays No Errors or Warnings, click .NEXT

11. The title of the next screen is Final Review. Carefully review all of the informationthat you have entered for this flight. If you need to change any item of information, clickUpdate Info > at the end of each section of information to go to the eAPIS screen whereyou can change information in that section.

If all of the information is correct, you are finally ready to submit your eAPIS manifest toCBP. Before you submit, we recommend that you print a copy of the information onthis screen. Then click to submit the manifest.SUBMIT


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Part II, Step 3 Receiving CBP Approval for Departure

1. The next screen after you click is Submission Details. There are threeSUBMITimportant pieces of information on this screen. First is advice that the eAPISsubmission does not fulfill notice of departure requirements and that you will receivean email with departure instructions. Second is advice that you can print a copy of yourmanifest for your records and receive additional instructions by clicking HERE. Thethird important item of information is your eAPIS Submission Number that appears onthis screen. We recommend that you copy your eAPIS Submission Number and clickthe word HERE.

Print Manifest

2. You will then see a screen with a complete Manifest Information, including yourSubmission Number. Click the Printer ICON to print all of the Manifest Information.CBP recommends that the pilot carry a copy of the Manifest and the SubmissionNumber in the aircraft during the flight.

IMPORTANT: The Department of Homeland Security (DHS) will send an email to theemail address used during the enrollment process. See the IMPORTANT NOTE onpage 6 of this Memorandum.

3. eMail for Flights Arriving Into the United StatesThe email will state that Notices of arrival and/landing rights must be coordinateddirectly with the CBP destination port. In other words, you must call CBP at the U.S.destination airport and provide your usual arrival notice.

IMPORTANT: The flight should not take-off from the foreign departure airport until afterreceipt of the email and after notice has been provided to CBP at the U.S. port ofarrival. Prior to takeoff, follow all instructions given by the CBP port at the U.S.destination airport.

4. eMail for Flights Departing From the United States Follow the instructions in theemail.

If there are no problems the email will state Based on the information submitted, youare cleared for departure. The aircraft may then depart from the U.S. airport.

If DHS has any objections to the aircraft departing the United States, the email willprovide specific instructions, such as to call DHS. DHS will provide the telephonenumber.

IMPORTANT: Do not take off until fully complying with DHS instructions.


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PART III -- CHANGES TO MANIFEST & OBTAINING ANSWERS TO QUESTIONS

Changes to a Submitted Manifest

It is not possible to use eAPIS to withdraw a manifest for a flight that has beencanceled. You should notify CBP of the flight cancellation by telephone.

Changes to ETA, ETD, or the arrival or departure locations can be made either bysubmitting a new manifest or by telephone or radio, but CBP prefers that you make anew eAPIS submission to make these changes whenever possible.

Although the regulations do not specify how much your ETA or ETD must change foryou to make a new submission, we recommend that you submit a change to your ETAwhenever it changes from the original ETA by more than two hours or moves to anotherday. If the change in your ETA is more than 15 minutes, however (but less than twohours) we recommend that you advise CBP by telephone or radio as a courtesy in orderto minimize any inconvenience to CBP officials.

For a change in ETD, treat your CBP approval as valid for a departure time on thesame day as the original ETD. If your ETD is delayed to the next day, we recommendthat you submit a new manifest to update the ETD.

After you submit an amended manifest, any clearance based on an earlier manifest isinvalid, and you must wait for your new approval before you depart on a flight to theU.S. or from the U.S.

Note: CBP states that it will accept manifest information by telephone when unforeseencircumstances preclude submission of the information via eAPIS. CBP does not defineunforeseen circumstances, but you should only attempt to submit manifest information bytelephone when no internet is available or in emergency situations.

Additional eAPIS Questions & Assistance. Please let us know if you have anyquestions about submitting private eAPIS manifests.

We are also available to provide additional assistance with respect to eAPIS matters.For example, we can enroll your air taxi/company in Private Aircraft eAPIS. We canalso activate your eAPIS account on your behalf. Finally, we can provide instructions topersons in your company on the use of eAPIS.

You can contact us at 202-331-3300 or [email protected].

We hope this Memorandum will be useful to you. Please let us know if you have anysuggestions to improve this Memorandum.

private aircraft eapis memo.pdf

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