NATA is advising that starting 26 January, all air passengers travelling into the United States, including by private flights, air charter and general aviation aircraft, will be required to show proof of a negative COVID-19 test result or documentation of having recovered from COVID-19, regardless of vaccination status. All passengers must complete an attestation affirming their compliance with the Centers for Disease Control and Prevention (CDC) requirements and provide it to their aircraft operator.

The requirements in the CDC order apply to all aircraft, including airlines, air charter operators and private aircraft operators arriving in the United States.

Beginning on 26 January 2021, aircraft operators are responsible for: verifying that each passenger has completed an attestation. Attestations may be completed electronically or on paper. The aircraft operator must keep a copy of each attestation for two years; confirming each passenger has documentation of their negative test result or proof of recovery. The documentation should indicate that the passenger has taken a COVID-19 viral test no more than three calendar days before their flight departure with a negative result or that a passenger who has recovered from COVID-19 has received clearance from a public health official to travel. Aircraft operators do not need to retain copies of these documents; not permitting any passenger to board without verifying the attestation and confirming the documentation.

The following limited exemptions are provided in the CDC order: the testing and attestation requirements do not apply to children under two years of age; crew members on official duty, including those in an assigned deadhead status, are exempt from the testing requirement as long as they follow industry standard protocols for the prevention of COVID-19 as set forth in the relevant FAA-issued SAFO; operators transporting COVID-19 passengers pursuant to CDC authorisation; certain law enforcement, government and military operations; CDC recognises that certain countries may not have available testing capacity. Any operator wishing to conduct operations to the US from such locations must request and receive a waiver directly from the CDC.

The CDC documents provide specific details on the types of acceptable documentation and the actions required of both passengers and aircraft operators. Operators intending to conduct international flights should immediately review the CDC documents, establish compliance plans and implement the requirements of the order for flights on and after January 26, 2021. The CDC has a webpage including the order, attestation and FAQs.

NATA strongly advises operators to proactively reach out to international travellers to ensure they have a testing plan for their trip. Operators should also review their contracts and cancellation policies to ensure they account for any potential contingencies associated with this order, including positive test results from crew or passengers, passenger refusal to test or provide attestation or passenger failure to test in the required time window.

More recently, NATA and other industry stakeholders participated on an interagency call, including representatives from the CDC and FAA, to gain further clarity on CDC’s Order imposing COVID-19 entry testing requirements for all air travellers arriving to the United States. New guidance states that: the CDC is the lead agency for this order’s enforcement, not the CBP; and self-testing is permissible with proof of negative result as long as it is a viral test and not an antibody test.

More detailed guidance will be forthcoming for operations to locations where COVID tests are not easily obtainable.

Testing is not required for flights to or from Puerto Rico, Guam, or other US territories to the United States

For flights from the US returning to the US within 72 hours, a test taken before departing the US is valid for the return as long as it was taken within the 72-hour timeframe.