In the Spring 2021 edition of The Transportation Brief, we advised on an upcoming change to the rules governing cargo offered for international air transportation. The new rule, effective June 30, 2021, requires all cargo to be screened or handled pursuant to an “alternative framework.” Due to delays by the Transportation Security Administration (TSA) in updating affected security programs, we have seen significant disruption in the supply chain as shippers, air forwarders, and all-cargo aircraft operators attempt to navigate new compliance obligations. Difficulties encountered by air forwarders include limits on screening capacity, unclear packaging guidance, late-arriving amendments to their security programs, and murky rules for single-entity charters and cargo that is not capable of being screened using methods currently approved by the TSA. Despite recent indications of imminent relief on these issues, we continue to advise Indirect Air Carrier and Certified Cargo Screening Facility clients to work closely with screening vendors and air carriers to stay ahead of the curve.