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ARTICLE · 25 JUNE 2026

TSA Authorized Representatives—Emerging Practice Of Engaging Freight Brokers And Its Practical Implications

Benesch, Friedlander, Coplan & Aronoff LLP
Benesch, Friedlander, Coplan & Aronoff LLP
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As air cargo providers face mounting supply chain pressures and capacity constraints, many are turning to property brokers to arrange regulated surface transportation—a shift that introduces complex security compliance challenges and significant enforcement risks.

United StatesTransport

Air transportation safety has long been of critical supply chain importance and geopolitical significance, and that role is growing. Supply chain constraints over this decade have driven a need for adaptation, modal diversification and cost containment. To do so, authorized air cargo providers have increasingly explored new ways to add capacity for regulated surface transportation.

The primary regulated air cargo providers in the United States are air carriers and indirect air carriers. Direct air carriers operating under 14 CFR Part 119 are certificated by the U.S. Department of Transportation, the Federal Aviation Administration, and DHS’s Transportation Security Administration. The operating rules associated with direct air carriage are found in 14 CFR Parts 121 or 135. Indirect air carriers, on the other hand, are persons or entities within the United States that do not possess an FAA air carrier operating certificate but undertake to engage indirectly in the air transportation

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