AMC & GM to the Articles of Commission Delegated Regulation (EU) 2025-20 — Issue 1

Acceptable Means of Compliance and Guidance Material to the Articles of Commission Delegated Regulation (EU) 2025/20

Issue 1 7 July 2025

Table of contents

AMC AND GM TO THE ARTICLES OF COMMISSION DELEGATED REGULATION (EU) 2025/20 ----------- 3

AMC AND GM TO THE ARTICLES OF COMMISSION DELEGATED REGULATION

(EU) 2025/20 GM1 Article 3 Definitions

TERMS USED IN THE ACCEPTABLE MEANS OF COMPLIANCE AND GUIDANCE MATERIAL

For the purpose of the AMC and GM to Regulation (EU) 2025/20, the following definitions apply:

Cabin baggage Baggage in the custody of a passenger or crew member that is intended for carriage in the cabin of an aircraft; equivalent terms are ‘carry-on baggage’, ‘hand baggage’ and ‘unchecked baggage’.

Checked baggage Passenger baggage that has been taken into custody by the aircraft operator, intended for carriage in the cargo compartment(s) of an aircraft, for which a baggage claim check has been issued to the passenger; this includes cabin baggage that has been taken from a passenger and loaded into the cargo compartment (e.g. due to physical size/weight restrictions or lack of cabin stowage space); equivalent terms are ‘hold baggage’, ‘hold luggage’ and ‘registered baggage’.

Company material Aircraft operator material carried on an operator’s aircraft for the operator’s own purposes.

Correction The action of eliminating a non-compliance.

Corrective action The action of eliminating or mitigating the root cause(s) and preventing the recurrence of existing detected non-compliance or of any other undesirable condition or situation. Proper determination of the root cause(s) is crucial for defining effective corrective action to prevent recurrence.

Ground handling Synonym for ‘ground handling (GH) organisation’. The two terms are service provider interchangeable. (GHSP)

Holdover time The period of time during which an anti-icing fluid provides protection against frozen contamination to the treated aircraft surfaces. It depends, among other variables, on the type and intensity of precipitation, OAT, wind, the particular fluid (or fluid type) and aircraft design and aircraft configuration during the treatment.

Mass and balance In addition to the definition in Article 3 (definition (31): documentation Since aircraft operators may use different names for the various documents containing mass and balance calculations and data, the more generic term ‘mass and balance documentation’ is used throughout Commission Delegated Regulation (EU) 2025/20. This ensures alignment with Regulation (EU) No 965/2012 regarding mass and balance calculations and related documentation.

Mishandled baggage Baggage involuntarily, or inadvertently, separated from passengers or crew.

Near miss An event in which an occurrence to be mandatorily reported in accordance with Regulation (EU) No 376/2014 was narrowly averted or avoided.

Overpack An enclosure used by a single shipper to contain one or more packages and to form one handling unit for convenience of handling and stowage.

Oversight planning The time frame within which the content of the declaration of a GH cycle organisation and the processes that are identified through a safety risk assessment should be reviewed by the competent authority by means of audits and inspections.

Oversight The detailed oversight schedule that sets out the number of audits and programme other activities – including the scope and duration of each activity and the details of product audits and locations, as appropriate – to be performed by the competent authority, with a tentative time frame for performing each activity.

Package The complete product of a packing operation, consisting of the packaging and its contents prepared for transport.

Packaging Receptacles and any other components or materials necessary for the receptacles to perform their containment function.

Preventive action The action taken to eliminate the cause of potential non-compliance or of any other undesirable potential situation.

Station An aerodrome where a GH organisation provides services.

Unaccompanied Baggage that is transported as cargo and that may or may not be carried on baggage the same aircraft as the person to whom it belongs.

PROVISION OF GH SERVICES FROM AN OFF-AIRPORT LOCATION

Organisations providing GH services from a location other than an aerodrome subject to Regulation (EU) 2018/1139 and its delegated and implementing acts are not subject to Commission Delegated Regulation (EU) 2025/20. The services provided by such organisations are included in the management system of the aircraft operator as contracted activities and are regulated by Regulation (EU) No 965/2012, particularly point ORO.GEN.205 thereof. Examples of these services: (a) passenger and baggage acceptance, at off-airport locations, (b) load control (load planning and production of related documents).

PASSENGER HANDLING

The safety aspects of passenger handling covered by Commission Delegated Regulation (EU) 2025/20 are the following: (a) dangerous goods in passenger baggage or on the person upon acceptance at check-in at the aerodrome; (b) insertion of the correct information related to passenger and baggage acceptance into the departure control system, for load control purposes (i.e. mass and balance calculations, load planning); (c) ground transport between the airport terminal and the aircraft; (d) safety of passengers on the apron and around the aircraft during boarding and disembarkation; (e) passenger boarding and disembarkation using GSE, including passenger boarding bridges (PBBs). All aspects above include passengers with reduced mobility (PRMs).

GROUND SUPPORT EQUIPMENT

The following items of GSE are within the scope of Commission Delegated Regulation (EU) 2025/20, regardless of their level of automation (requiring or not requiring human intervention). The list is based on IATA Airport Handling Manual (AHM): (a) lifting and elevating equipment: (1) aircraft tail stand, (2) belt loader, with or without in-hold conveyor system, (3) catering vehicle, (4) aircraft exterior cleaning equipment, (5) de-icing/anti-icing vehicle/equipment, (6) elevating work platform or equipment, (7) forklift, (8) loader (lower deck or main deck), (9) maintenance stairs, (10) mobile passenger boarding ramps, (11) passenger stairs, (12) PBBs, (13) boarding vehicle for PRMs;

(b) servicing equipment: (1) aircraft air conditioning unit (ACU) (2) aircraft fuelling dispenser (pump), (3) aircraft fuelling truck or cart, (4) aircraft heating unit, (5) aircraft start unit (ASU) (6) ground power unit (GPU) (7) lavatory service equipment, (8) potable water service equipment; (c) towing equipment, including remote controlled vehicles: (1) tractor for baggage, cargo or aircraft equipment, (2) aircraft towing or pushback vehicle (tractor, tug, truck), (3) towbar, (4) towbarless tractor, (5) interchangeable tow bar heads; (d) transporting equipment: (1) bus (for passengers or crew), (2) car, van or pick-up truck, (3) cart or dolly (for baggage, cargo, unit load device (ULD) or aircraft equipment), (4) fuelling truck, (5) temperature-controlled cargo dolly, (6) temperature-controlled cargo truck, (7) trailer (for baggage, cargo, ULD or aircraft equipment), (8) truck (for baggage, cargo, ULD or aircraft equipment), (9) ULD transporter (to move ULD to/from high loaders); (e) other equipment used to provide GH services: (1) aircraft chocks, (2) aircraft cones, (3) retractable stanchions, passenger guiding systems and parts thereof.

ACTIVITIES UPON AIRCRAFT ARRIVAL

The following activities take place before and after an aircraft is parked at the stand: (a) prior to aircraft arrival: (1) checking the aircraft stand for any FOD; (2) checking the conditions of the surface stand for any ice, snow, etc.; (3) preparing the necessary GSE, chocks and cones outside the equipment restraint area; (4) ensuring that the necessary personnel are available for aircraft arrival activities and remain outside the aircraft manoeuvring path and within the safety zones; (b) after the aircraft has been parked: (1) securing the aircraft on the ground by putting chocks on the aircraft wheels and setting out safety cones to mark the equipment restraint area; (2) performing a walkaround upon aircraft arrival to inspect the aircraft fuselage, doors and engine cowlings/propellers for any damage; (3) giving clearance for the positioning of the necessary GSE (air conditioning unit, ground power unit, passenger stairs or boarding bridges, etc.).

ACTIVITIES UPON AIRCRAFT DEPARTURE

These activities include, but are not limited to: (a) removing the PBB and any other external equipment and vehicles from the aircraft and the equipment restraint area (ERA); (b) verifying that aircraft doors and panels are properly closed; (c) conducting an aircraft walkaround; (d) checking for FOD; (e) ensuring the availability of towing/pushback equipment; (f) ensuring that all persons and equipment are outside the aircraft danger areas; (g) any other activity necessary in accordance with the GH organisation’s procedures and the local aerodrome operator’s procedures.

CARGO AND MAIL HANDLING IN A CARGO WAREHOUSE

(a) Cargo handling is a complex activity that involves various entities responsible for different segments of cargo preparation and transport. Not all those entities are included in the scope of Commission Delegated Regulation (EU) 2025/20. For example, the following entities are excluded from the scope of the Regulation: (1) organisations that do not perform activities listed in Article 2(2) of Commission Delegated Regulation (EU) 2025/20 at the premises of an aerodrome within the scope of Regulation (EU) 2018/1139; (2) organisations like freight forwarders or shippers; (3) organisations that only transport cargo on the ground from one location/warehouse to another before being checked for acceptance for air transport. (b) The GH activities related to cargo and mail handling usually occur in a cargo warehouse. Like the entities involved in the cargo transport chain, not all cargo warehouses are included in the scope of Commission Delegated Regulation (EU) 2025/20. (c) Only the cargo warehouses that are located at an aerodrome or adjacent to it and that are responsible for final cargo checks and acceptance before the cargo is loaded on the aircraft are included in the scope of Commission Delegated Regulation (EU) 2025/20. (d) Furthermore, only the safety-related activities occurring in a cargo warehouse that may have an impact on the safety of the flight are included in the scope of Commission Delegated Regulation (EU) 2025/20.

ORGANISATIONS OUTSIDE THE SCOPE OF COMMISSION DELEGATED REGULATION (EU) 2025/20 THAT OPERATE GSE AROUND THE AIRCRAFT

(a) Organisations that move GSE to and from the aircraft or connect GSE to the aircraft to complete their tasks but are outside the scope of Commission Delegated Regulation (EU) 2025/20 are not required to declare their activities. However, as the operation of GSE is included in the scope of the Regulation, it is subject to oversight by the competent authority responsible for the oversight of the safe provision of GH services at the aerodrome of operation. The GSE and its operation are subject to compliance with the safety and maintenance requirements of Commission Delegated Regulation (EU) 2025/20. (b) Examples of GH services that may use GSE in close proximity to the aircraft: aircraft interior cleaning and in-flight services. (c) GSE moved to and from the aircraft for aircraft maintenance purposes is covered by Regulation (EU) No 1321/2014.

MARSHALLING OF AIRCRAFT

(a) Organisations that provide aircraft marshalling services are required to comply with the requirements of Regulation (EU) No 139/2014 applicable to aircraft marshalling. (b) If such organisations also provide GH services that are included in the scope of Commission Delegated Regulation (EU) 2025/20, this Regulation is applicable to them and they are expected to declare their activities in accordance with Subpart ORGH.DEC, except for the marshalling services.

FLIGHT DISPATCH

Although the term ‘flight dispatch’ is included in the definition of ‘ground handling’ in Regulation (EU) 2018/1139, Commission Delegated Regulation (EU) 2025/20 does not regulate those activities or their providers for the following reasons. (a) The flight dispatch function is linked to the operational control system of an aircraft operator and is therefore considered a flight operations function, which is covered by Regulation (EU) No 965/2012 and the associated AMC and GM. This function may be outsourced to a third-party service provider. (b) The term ‘flight dispatcher’ is defined in Regulation (EU) No 965/2012 and ICAO Annex 6, both regarding air operations, as an individual with specific qualifications and training compliant with ICAO Annex 1 who has specific tasks in the operational control system of the aircraft operator, including to support, brief or assist the pilot-in-command in the safe conduct of the flight. The flight dispatcher function is considered a typical ‘flight operations’ function. The flight dispatcher’s tasks and responsibilities can be found in Regulation (EU) No 965/2012. (c) The term ‘dispatcher’ is also used in ground operations, but it is not defined. For ground operations, the dispatcher performs a GH function that confirms to the aircraft operator’s flight dispatcher or the flight crew that all GH activities have been completed and that, from a GH perspective, the aircraft is prepared to leave the stand. Other terms may be used to describe this function, such as ‘ramp coordinator’ or ‘ramp supervisor’. (d) Although the meaning of the term may be clear in the mind of the user, it is not always clear to others whether the user is referring to the function explained in point (b), related to the operational control system, or to the ground function explained in point (c). The confusion generated by the use of the same term to indicate two different functions may persist, as one usually associates a term only with tasks in the domain with which one is more familiar – that is, either air operations or ground operations, but rarely both. This may have safety implications due to the numerous interfaces between air operations and GH for operational procedures on the ground.

(e) To avoid the confusion described above, it is recommended that GH organisations avoid using the terms ‘flight dispatch’ or ‘(flight) dispatcher’ when describing typical GH tasks to prepare an aircraft for departure.

LOAD PLANNING, LOAD CONTROL MESSAGES AND COMMUNICATIONS, AND ISSUANCE OF LOAD CONTROL DOCUMENTS

(a) The scope of Commission Delegated Regulation (EU) 2025/20 does not cover the provision of load planning services, mass and balance calculations or load control messaging and communications, or the issuance of related documents. These activities are included in the scope of Regulation (EU) No 965/2012. When outsourced to a third-party provider, the responsibility for the safety of these services is covered by point ORO.GEN.205 of Regulation (EU) No 965/2012. (b) The load control function is specific to the operator’s fleet and operational context. It may be performed by an organisation at an aerodrome or outside an aerodrome or by the personnel of the aircraft operator itself. (c) The load control process is classified into two distinct phases: (1) Phase 1: mass and balance (M&B) calculations, load planning, load control communications and messaging, and issuance of load control documents (load sheet, loading instructions/report (LIR) or notification to captain (NOTOC) when necessary). These activities may be executed from an aerodrome or a remote location. (2) Phase 2: load control communication — that is, verification of load against the loading instructions and communication of any last-minute changes to the mass and balance documentation. These activities take place at an aerodrome, as part of the preparation of the aircraft for departure. (d) The aircraft operator is responsible for ensuring the compliance of activities included in phase 1 — that is, mass and balance calculations, load planning, load control communications and messaging, and issuance of load control documents — with the relevant requirements of Regulation (EU) No 965/2012. This applies at all times, regardless of whether these tasks are performed by the aircraft operator itself or outsourced as a contracted activity. These activities are overseen by the competent authority of the aircraft operator. (e) The GH organisation is responsible for the activities included in phase 2, which take place on an aircraft, at the aerodrome. These activities are overseen by the competent authority for GH of the aerodrome where they are performed.

GROUND SUPERVISION

(a) Ground supervision may be contracted by an operator as an individual service. It is usually associated with ground administration services provided by a GH organisation on behalf of the operator. (b) This service includes the supervision and/or coordination of one or more GH activities on behalf of an operator, which may be performed by one or more providers of GH services. (c) Organisations that provide ground supervision are required to comply with the relevant requirements of Regulation (EU) No 965/2012. (d) If such organisations also provide other GH services that are included in the scope of Commission Delegated Regulation (EU) 2025/20, the Regulation is applicable to them. They are expected to declare their activities in accordance with Subpart ORGH.DEC, except for the ground supervision services and any other GH services listed in Article 2(3) of the Regulation. (e) Ground supervision comprises activities such as: (1) providing official representation for the contracting aircraft operator in relation to the aerodrome authorities or other organisations operating at that aerodrome, issuing disbursements on behalf of the aircraft operator, and ensuring the provision of office space for representatives of the operator; (2) setting key performance indicators for operational performance; (3) organising workflows and conducting operational planning; (4) reporting incidents, accidents and near misses; (5) activating and coordinating emergency responses, in accordance with the operator’s procedures; (6) communicating with the aircraft operator; (7) handling, storing and administering ULDs; (8) supervising operational functions in the areas of: (i) passenger and baggage handling, (ii) ramp handling, (iii) load control; (9) any other administrative services requested by the aircraft operator. (f) Ground supervision does not include a GH organisation’s management of its own activities. (g) Ground supervision does not imply that the individual performing this function will replace, when necessary, an individual performing a GH operation. (h) A person responsible for ground supervision may act on behalf of more than one aircraft operator to ensure the safe delivery of the services by GH organisations.

OIL HANDLING

(a) Aircraft oil handling means replenishing the aircraft’s oil. Like any other activity related to aircraft maintenance, it is subject to Regulation (EU) No 1321/2014, on continuing airworthiness, as a maintenance task, and therefore exempted from compliance with Commission Delegated Regulation (EU) 2025/20. Oil handling is performed by personnel of a maintenance organisation approved under Regulation (EU) No 1321/2014 or compliant with ICAO Annex 8 Maintenance of Aircraft, when it is performed on third-country registered aircraft by organisations that are not subject to Regulation (EU) No 1321/2014. This task may also be performed by the flight crew for those aircraft for which oil handling is mentioned in the aircraft flight manual, as part of the pre-flight inspection as indicated in AMC M.A.301(a), paragraphs 2 and 3, to the abovementioned Regulation. (b) Aircraft may be replenished with oil either by aircraft operator personnel or by a contracted third-party provider that holds approval in accordance with the requirements mentioned above.

GROUND HANDLING ORGANISATION

(a) GH services may be provided by different types of organisations. When the terms ‘organisation providing GH services’, ‘ground handling service provider’ (GHSP) or ‘GH organisation’ are used in Commission Delegated Regulation (EU) 2025/20 and the associated AMC and GM, they are understood to cover all organisations identified in Article 2(1) unless it is clearly specified otherwise in the Regulation. (b) A provider of GH services that is contracted by another GH organisation to provide any GH service listed in Article 2(2) is considered a GH organisation and therefore subject to Commission Delegated Regulation (EU) 2025/20. (c) A freight forwarder is not considered a GHSP. Freight forwarding is not included in the definition of GH services in Regulation (EU) 2018/1139. If a freight forwarder provides a GH service listed in Article 2(2) of Commission Delegated Regulation (EU) 2025/20, the requirements for contracted activities will apply, either under Regulation (EU) No 965/2012 (point ORO.GEN.205), when its services are contracted directly by an aircraft operator, or under Commission Delegated Regulation (EU) 2025/20 (point ORGH.MGM.205), when its services are contracted directly by a GH organisation.

GM1 Article 3(1b) Definitions

AERODROME OPERATOR PROVIDING FACILITIES AND INFRASTRUCTURE OUTSIDE THE SCOPE OF COMMISSION DELEGATED REGULATION (EU) 2025/20

(a) An aerodrome operator may provide certain centralised infrastructure or equipment for the provision of GH services, such as centralised baggage sorting infrastructure, de-icing facilities and PBBs.

(b) When the aerodrome operator provides such equipment or facilities but its personnel are not involved in their operation, that aerodrome operator does not fall within the scope of Commission Delegated Regulation (EU) 2025/20. The aerodrome operator providing training on the operation of the facilities and infrastructure provided to the GH organisations is not considered a GH organisation and is not required to declare itself as such in accordance with the Regulation. (c) When the aerodrome operator’s own personnel are also involved in the operation of the facilities or infrastructure, that operator is considered a GH organisation and shall comply with Commission Delegated Regulation (EU) 2025/20.

GM1 Article 3(1c) Definitions

AIRCRAFT OPERATOR PROVIDING GH SERVICES

(a) The term ‘aircraft operator’, when used in relation to self-handling, should be understood as an aircraft operator that may or may not be part of a single air carrier business grouping unless specified otherwise. (b) A self-handling aircraft operator providing GH services to other aircraft operators that are not part of the same single air carrier business grouping is considered to be a GH organisation as identified in paragraph 1(a) of Article 2 of Commission Delegated Regulation (EU) 2025/20. In such a case, the Regulation is fully applicable to such an organisation.

SINGLE AIR CARRIER BUSINESS GROUPING

(c) A single air carrier business grouping refers to two or more air operator certificate (AOC) holders whose PPoB is in a territory to which the EU Treaties apply. Those AOC holders may or may not facilitate the harmonisation of their management systems and operations for the purpose of applying the requirements for self-handling in a harmonised way. The management systems and operations include policies, processes and procedures for GH, training of personnel performing GH activities, ground operations procedures, and the maintenance programme for GSE. (d) This concept is used in Commission Delegated Regulation (EU) 2025/20 for situations where an aircraft operator provides GH services not only to itself through self-handling but also to other aircraft operators that are part of the same business grouping. The application of this concept serves several purposes: (1) to avoid the duplication of GH requirements; (2) to enable AOC holders performing self-handling, including providing GH services to aircraft operators that are part of the same business grouping, to identify the competent authority to which they should submit a declaration; and (3) to enable effective and efficient oversight, including cooperative oversight.

SINGLE GROUND HANDLING ORGANISATION BUSINESS GROUPING

The concept of single GH organisation business groupings is used in Commission Delegated Regulation (EU) 2025/20 for situations where a GH organisation has several branches that are registered in more than one Member State but belong to the same parent company. In such cases, it is necessary to establish that such organisations should be regarded as part of a single business grouping and should have a single PPoB — the one where the parent company is located. The application of this concept serves several purposes: (a) to avoid the duplication of GH requirements for the same organisation; (b) to avoid multiple oversight audits and inspections with the same scope – the organisation’s management system – and to enable effective and efficient cooperative oversight; and (c) to enable GH organisations to identify to which competent authority they should submit a declaration.

AIRCRAFT GROUND DE-ICING AND ANTI-ICING

ICAO Doc 9640 provides the following definitions for the terms ‘anti-icing’, ‘de-icing’ and ‘de-icing/antiicing’. (a) ‘Anti-icing’ is a precautionary procedure by which clean aircraft surfaces are protected against the formation of ice and frost and the accumulation of snow and slush for a limited period. (b) ‘De-icing’ is the process that removes ice, snow, slush or frost from aircraft surfaces. (c) ‘De-icing/anti-icing’ is a procedure combining both the de-icing process and the anti-icing process and that can be performed in one or two steps. (1) ‘One-step de-icing/anti-icing’. Heated anti-icing fluid is used to de-ice the aircraft and remains on the surfaces to which it is applied to provide anti-icing capability. (2) ‘Two-step de-icing/anti-icing’. This procedure contains two distinct steps: the first step, de-icing, is followed by the second step, anti-icing, as a separate fluid application.

AIRCRAFT TOWING

(a) Towing can be done using a towbar or a towbarless tractor. The GSE may be attached to the main landing gear. Depending on the type of towing vehicle, the operation may involve direct steering from the flight crew compartment by authorised personnel who are in the flight crew compartment at the time of taxiing. (b) Aircraft towing may have different purposes:

(1) Aircraft maintenance. This operation is performed with no passengers or cargo and with minimum fuel on board the aircraft. This falls outside the scope of Commission Delegated Regulation (EU) 2025/20, as stated in Article 2(3)(g). (2) Operational/dispatch. This is towing of an aircraft to/from the terminal gate or parking area to/from a remote parking area, with or without passengers, cargo or fuel on board.

AIRCRAFT PUSHBACK

(a) Nose-gear-controlled pushback includes either the towbar method, where the rearward movement and steering of the aircraft are controlled by a vehicle and towbar attached to the nose gear, or the towbarless method, where a vehicle is attached directly to the nose gear. (b) Main-gear-controlled pushback involves using a vehicle that grasps the aircraft’s main-gear tyres to provide rearward movement, while directional control is provided from the flight deck using the nose-wheel steering system.