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CBP Form 7509: Air Cargo Manifest Rules for Carriers

Published: October 11, 2026  ·  11 min read
CBP Form 7509: Air Cargo Manifest Rules for Carriers
Photo: Jonathan Borba / Pexels

Key Points

On this page

  1. What CBP Form 7509 is
  2. At a glance
  3. Where CBP Form 7509 comes from in the regulations
  4. Who files CBP Form 7509 and when
  5. How CBP Form 7509 is transmitted in ACE
  6. What goes wrong with CBP Form 7509 and what it costs
  7. How CBP Form 7509 relates to other manifest and custody forms
  8. Frequently asked questions
  9. What importers and brokers should do
  10. Key references

CBP Form 7509, Air Cargo Manifest, is the carrier's declaration of the cargo carried aboard an aircraft arriving in the United States, listing the air waybills and the shipments they cover so CBP knows what landed and can target, hold, or release it. The aircraft commander or the carrier's authorized agent is responsible for it, and it sits at the very front of the entry lifecycle: manifest first, then entry and release, then entry summary. As of October 2026 the declaration is normally made electronically through ACE air manifest, with the paper CBP Form 7509 remaining as the fallback presentation.

The links in this article go to the primary documents: the regulations in title 19 and the official CBP pages themselves. Read the source rather than a summary of it, and confirm anything time sensitive before you act on it.

At a glance

Where CBP Form 7509 comes from in the regulations

CBP Form 7509, Air Cargo Manifest, exists because 19 CFR Part 122, the air commerce regulations, requires an arriving aircraft to account for the cargo it carries. 19 CFR 122.48 is the provision that addresses the air cargo manifest and the information the carrier must present for the cargo on board. A separate provision, 19 CFR 122.48a, addresses advance electronic information for inbound air cargo, which is the rule that moved the practical center of gravity from a document handed over at arrival to a data transmission sent before the aircraft lands.

Those two sections should be read together. The manifest obligation under 19 CFR 122.48 describes what must be declared; the advance electronic information obligation under 19 CFR 122.48a describes the requirement that cargo information reach CBP in electronic form in advance of arrival rather than only at the ramp. The exact timing, the exact data elements, and any exemptions are stated in the regulation text, and because they have been amended over time, read the current sections on eCFR rather than relying on a memory of them.

Who files CBP Form 7509 and when

CBP Form 7509, Air Cargo Manifest, is the carrier's filing, not the importer's. The aircraft commander or an agent the carrier has authorized is the responsible party, and in practice that is usually the airline's cargo system, a ground handling agent, or a service provider transmitting on the carrier's behalf. A customs broker filing entry does not file the manifest; the broker consumes it, because the bill of lading or air waybill record created by the manifest is what an entry must match to obtain release.

Timing has two layers. The advance layer is set by 19 CFR 122.48a: cargo information must be transmitted electronically in advance of the aircraft's arrival in the United States, on the schedule the regulation prescribes for the flight in question. The arrival layer is the manifest itself under 19 CFR 122.48, which accounts for the cargo actually on board when the aircraft lands. Amendments after departure, split shipments, shortages, and overages are reconciled against that manifest record.

Where CBP Form 7509 sits relative to entry

Nothing moves until the manifest exists. CBP Form 7509 creates the bill-level record; the entry filer then files against that bill, and release follows. If the broker's entry cites an air waybill number that does not match the manifested bill, the entry will not match and release will not come, no matter how clean the classification and valuation work is. That is why manifest discrepancies land on broker desks even though brokers are not the filers.

How CBP Form 7509 is transmitted in ACE

CBP Form 7509, Air Cargo Manifest, is normally transmitted as data through ACE air manifest rather than presented as a printed form. The electronic record carries the same substance the paper form carries: the flight, the air waybills, the consignees, the piece counts and weights, and the description of the goods. Paper CBP Form 7509 remains the fallback, used when electronic transmission is unavailable or when CBP directs a paper presentation at the port.

Message formats, data element names, and conditional requirements live in the ACE CATAIR air manifest chapters published by CBP. Carriers and their software providers should work from the current CATAIR rather than an internal mapping document, and should subscribe to CBP's CSMS messages so that format changes are caught before a transmission starts rejecting. Where the CATAIR and an internal specification disagree, confirm with CBP.

What goes wrong with CBP Form 7509 and what it costs

Most CBP Form 7509 problems are data problems, not legal problems. The recurring ones are worth naming:

Consequences range from cargo holds and delayed release through manifest discrepancy write ups to penalty exposure under the Part 122 framework. The specific penalty amounts and the mitigation posture are not fixed figures you should assume; confirm the applicable provision and current guidelines with CBP for the port and the fact pattern.

How CBP Form 7509 relates to other manifest and custody forms

CBP Form 7509, Air Cargo Manifest, is the air mode member of a family of arrival manifests. The ocean equivalent is CBP Form 1302, Inward Cargo Declaration, the vessel cargo manifest the master files on arrival listing every bill of lading, filed electronically through ACE ocean manifest with the form as the paper fallback. The land border equivalent is CBP Form 7533, Inward Cargo Manifest for Vessel Under Five Tons, Ferry, Train, Car, Vehicle, etc. the arrival manifest for cargo arriving by truck, rail or small vessel; see our note on CBP Form 7533 at the land border. All three answer the same question in different modes: what arrived, on what conveyance, under what bill.

Around the manifest sit the operational permits and custody records. CBP Form 3171, Application-Permit-Special License Unlading-Lading-Overtime Services, is the carrier or agent request for permission to unlade or lade and for CBP services outside regular hours, with the reimbursable overtime it triggers; it is a permission to work the aircraft, not a cargo declaration. Once freight moves off the ramp into a bonded facility, CBP Form 6043, Delivery Ticket, records delivery of merchandise into a bonded warehouse or container freight station under CBP supervision and becomes the proprietor's custody record. If the goods are then opened, weighed, repacked, or sampled while still under CBP custody, the handling permit is CBP Form 3499, Application and Approval to Manipulate, Examine, Sample or Transfer Goods, covered in our entry on the permit to manipulate, examine, or sample. The bonded warehouse proprietor's annual inventory reconciliation submission is CBP Form 300, Bonded Warehouse Proprietor's Submission, discussed in our CBP Form 300 article.

Several other forms in this family touch the same freight later but are not manifest documents at all. CBP Form 3495, Application for Exportation of Articles Under Special Bond, is the notice an importer files before exporting goods admitted under a temporary importation bond so CBP can supervise or waive supervision of the export and the bond can be cancelled. CBP Form 3173, Application for Extension of Bond for Temporary Importation, is the request to extend the one-year TIB period, in one-year increments up to three years total, filed before the current period expires. CBP Form 368, Collection Receipt, is CBP's receipt for a payment made at a port, whether duties, fees, penalties, or bonds, and is the proof of payment kept for a protest, refund request, or audit. CBP Form 4457, Certificate of Registration for Personal Effects Taken Abroad, is the pre-departure registration of serial-numbered personal items such as laptops and cameras so they re-enter duty-free as previously exported personal effects, which is a traveler document rather than anything that appears on an air cargo manifest.

Frequently asked questions

Is CBP Form 7509 the same as the general declaration?

No. CBP Form 7509, Air Cargo Manifest, declares the cargo aboard the aircraft. The general declaration, CBP Form 7507, covers the aircraft, its journey, and persons on board. An arriving flight can require both, and they are not interchangeable.

Does a customs broker file CBP Form 7509?

No. CBP Form 7509 is the responsibility of the aircraft commander or the carrier's authorized agent. Brokers work downstream of it, filing entry against the air waybill record the manifest created, and chasing the carrier when the manifest and the entry do not match.

Is paper CBP Form 7509 still used?

Paper CBP Form 7509 remains the fallback. The normal channel as of October 2026 is electronic transmission through ACE air manifest, but a paper manifest may still be presented where electronic filing is unavailable or where CBP directs it at the port. Confirm the current expectation with the port and with CBP guidance before planning to present paper.

What is the difference between the manifest and advance electronic information?

CBP Form 7509 is the cargo manifest obligation addressed at 19 CFR 122.48. Advance electronic information for inbound air cargo is a separate requirement at 19 CFR 122.48a. Meeting one does not automatically satisfy the other; read both sections in the current regulation.

What importers and brokers should do

Key references


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About the Author

Franz Brotzen, CustomsGenius CEO & Founder. Franz is a published researcher on U.S. trade policy. He has worked at think tanks in Washington DC and Tokyo, where his academic publications focussed on tariffs and legal compliance. Franz received his JD from Harvard Law School.

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