We would like to share some information regarding recent events on the above-mentioned topic and our role in it:
Two of our pilot representatives (Oliver Eichorst and Nick Collett) recently joined the IFALPA Dangerous Goods (DG) Committee, attending its yearly committee meeting at BALPA HQ at Heathrow.
The IFALPA DG Committee promotes the safe transport of DG by air and represents IFALPA at major international forums such as the October’s ICAO Assembly in Montreal.
The meeting in London ran over three days, spanning a wide variety of topics, the most relevant to us at Cargolux being the issue of CAO freight:
As we all know, passage aboard Cargolux aircraft carrying CAO DGR’s for leisure travel has been prohibited for some years due to restrictions imposed by ICAO Annex 18. Attempts by ALPL and Cargolux management to resolve this by means of DAC exemption have thus far been without success.
According to ICAO Annex 18 Definition – a ‘passenger aircraft’ is an aircraft that carries any person other than:
– A crew member,
– An operator’s employee in an official capacity,
– An authorized representative of an appropriate national authority,
– A person accompanying a consignment or other cargo
This constitutes the list of people who may be carried aboard a cargo aircraft, according to ICAO Annex 18.
Few states honor this to the letter – most have added other categories of persons who can travel on cargo aircraft carrying CAO. For example – horse grooms returning without horses are not foreseen by the ICAO definition of a cargo aircraft. This provision is provided by a DAC exemption.
IFALPA has, through the ICAO Dangerous Goods Panel, been working for several years to resolve this, to permit additional people to travel on CAO-laden aircraft. Various workarounds have been looked at, but proposals thus far have had mixed reception at ICAO level.
One early proposal was to change the definition of a cargo aircraft to broaden the scope of who could travel on board. This faced opposition as it was seen as attempting ‘regulation through definition’.
The most recent proposal, tabled at the (ICAO Convention) in Montreal in October 2025, was to delete the definitions of passenger and cargo aircraft from Annex 18, and to add new wording that would permit additional persons on board a CAO flight when authorized by the operator and the State of the Operator.
Unfortunately, this latest proposal was also rejected, due to opposition from several ICAO DG Panel members who fear unintended consequences of deletion of the definitions, and that a thorough impact assessment would need to be done.
Despite this setback, IFALPA, through the ICAO DG panel, will continue work to resolve the issue. Confidence was expressed at the meeting in London that this would be eventually successful.
The timing, however, is uncertain, especially due to the slow pace of proceedings at ICAO level. It is unlikely that Annex 18 changes which would lead to a relief in our situation would come into effect before 1st January 2029.
Despite these setbacks, Oli and Nick reported that there was optimism that the ICAO text would eventually be changed for the better. They made valuable connections and were pleased to witness first hand that there is a dedicated, knowledgeable team working towards rectifying not only these issues, but a wide range of DG related safety topics.
Also worth mentioning is the fact that Cargolux is by far not the only operator with a very restrictive aviation authority limiting our well-deserved staff travel benefits. The prominent examples where the authorities have currently allowed additional people on board are the exception.
For us, these dragged developments mean that we are launching a prepared initiative to try to mitigate the restrictions internally by other means.
We will keep you updated as soon as possible and hope to have contributed to a better understanding of the underlying restrictions.
