Direct Answer — What §135.87 Requires
14 CFR §135.87 ("Carriage of cargo including carry-on baggage") prohibits carrying cargo, including carry-on baggage, in or on any aircraft unless one of three conditions is met:
- aIt is carried in an approved cargo rack, bin, or compartment installed in or on the aircraft; (§135.87(a))
- bIt is secured by an approved means; or (§135.87(b))
- cWhen carried in a compartment occupied by passengers or crew, it meets all of the conditions in paragraph (c) — restraint, packaging, load limits, no obstruction of exits/aisle/signs, not directly above occupants, and stowed for takeoff and landing. (§135.87(c))
Two more paragraphs round out the rule: §135.87(d) requires that each passenger seat under which baggage is stowed be fitted with a means to keep that baggage from sliding under crash loads, and §135.87(e) requires cargo in compartments that a crewmember must enter to fight a fire to be loaded so the crewmember can effectively reach all parts of the compartment with a hand fire extinguisher.
Source: 14 CFR §135.87 — eCFR. Section 135.87 is an operating rule about physical restraint and placement; the documented evidence that the cabin was loaded within limits lives in the §135.63(c) load manifest and the weight-and-balance record, not in §135.87 itself.
Cargo in the cabin is one of the most routine — and most quietly mis-handled — parts of on-demand operations. A box on an empty seat, a parts shipment behind the last row, a customer's gear stacked in the aisle for a quick leg: each is a §135.87 question, and each is something an operator should be able to show was done correctly. The rule is short, but it carries six independent conditions for cabin cargo, plus two structural requirements that are easy to overlook.
This article walks the rule the way an inspector reads it: the three alternative ways to comply, each §135.87(c) condition explained with the trap that produces a finding, the §135.87(d) and (e) requirements, and — because FileFlo is a compliance document platform — exactly where §135.87 turns into a record you can produce. For the broader records picture, start with what records a Part 135 operator must keep and the weight-and-balance records requirements.
The Three Ways to Comply With §135.87
Section 135.87 opens with "No person may carry cargo, including carry-on baggage, in or on any aircraft unless—" and then offers three alternatives. Any one of them, met properly, makes the carriage lawful.
(a) An approved cargo rack, bin, or compartment
Cargo carried in an approved cargo rack, bin, or compartment installed in or on the aircraft satisfies §135.87(a). "Approved" is doing real work here: the rack, bin, pod, or compartment must be part of the aircraft's approved type design or an approved alteration. That approval traces back to airworthiness paperwork — type design data, a supplemental type certificate (STC), or an FAA Form 337 for the major alteration. If you carry cargo this way, the document that proves it is the installation approval, not a loading sheet.
(b) Secured by an approved means
Cargo "secured by an approved means" satisfies §135.87(b). This covers approved cargo nets, barriers, tie-down systems, and restraint hardware whose use is approved for the aircraft and loading. As with (a), the proof is the approval basis for the restraint system. The difference between (a)/(b) and (c) is essentially: an installed/approved system versus loose cargo that rides in an occupied compartment under the enumerated conditions.
(c) The six conditions for cargo in an occupied compartment
When cargo rides in a compartment occupied by passengers or crew without a dedicated approved bin, §135.87(c) governs — and all six of its conditions must be satisfied. This is the route most relevant to mixed passenger/cargo legs and to carry-on baggage in the cabin. It is also the route where compliance is demonstrated through loading discipline and the weight-and-balance record rather than an installed-equipment approval. The six conditions are detailed in the next section.
"Including carry-on baggage" is in the title for a reason
Section 135.87 explicitly reaches carry-on baggage, not just freight. A passenger's roller bag, a duffel on the seat next to them, a box of samples — all are "cargo, including carry-on baggage" and all must meet one of the three routes. For carry-on items the (c)(1) standard is phrased as restrained "so as to prevent its movement during air turbulence," which is why a crew enforcing stowage at boarding is operationalizing §135.87, not just tidying the cabin.
The §135.87(c) Conditions, Each Explained
For cargo in a compartment occupied by passengers or crew, §135.87(c) imposes six conditions. They are independent — meeting five of six is not compliance. Here is what each one means and the trap that turns it into a finding.
Secured by belt or tie-down (or restrained against turbulence)
§135.87(c)(1)Cargo must be properly secured by a safety belt or other tie-down having enough strength to eliminate the possibility of shifting under all normally anticipated flight and ground conditions. For carry-on baggage specifically, the standard is that it is restrained so as to prevent its movement during air turbulence. The strength standard is tied to anticipated flight and ground loads — not merely "snug."
Where it trips operators up
A bag wedged behind a seat or set on an empty seat without a belt does not satisfy (c)(1). "Restrained so as to prevent movement during air turbulence" means an actual restraint — a seat belt around the item, a cargo strap, or an approved restraint — not gravity and friction.
Packaged or covered to avoid injury
§135.87(c)(2)The cargo must be packaged or covered to avoid possible injury to occupants. This addresses sharp edges, protruding hardware, and items that could injure a person even while restrained — the packaging is a separate condition from the tie-down.
Where it trips operators up
Tooling, equipment with exposed corners, or unpackaged hard goods riding in the cabin can violate (c)(2) even if they are perfectly tied down. Restraint and packaging are independent requirements.
Within seat / floor load limits
§135.87(c)(3)The cargo must not impose any load on the seats or on the floor structure that exceeds the load limitation for those components. Seat and floor structure have certificated load limits; cabin cargo cannot exceed them. This is where §135.87 connects directly to weight-and-balance and to the aircraft's type-design limits.
Where it trips operators up
Dense cargo (batteries, parts, fluids) can exceed a seat-mounted or floor load limit long before it looks "too big." The limit is structural, expressed in the aircraft data — not a judgment call made at the door.
No obstruction of exits, crew aisle, or required signs
§135.87(c)(4)The cargo must not be located in a position that obstructs the access to, or use of, any required emergency or regular exit, or the use of the aisle between the crew and the passenger compartment, or located in a position that obscures any passenger's view of the "seat belt" sign, "no smoking" sign, or any required exit sign. Exit access, the crew-to-cabin aisle, and sign visibility are all protected.
Where it trips operators up
Cargo stacked in an aisle or in front of an exit is the most visible (c)(4) violation, but blocking a passenger's view of a required sign is equally a violation. The cargo-only carve-out in (c)(7) does not apply when passengers are aboard.
Not directly above seated occupants
§135.87(c)(5)The cargo must not be carried directly above seated occupants. Even securely restrained, within-limits cargo may not be positioned directly over a person in a seat. This is a standalone positional condition.
Where it trips operators up
Overhead or shelf stowage above an occupied seat row can violate (c)(5) regardless of how well the item is secured. Position relative to occupants is its own test.
Stowed in compliance for takeoff and landing
§135.87(c)(6)The cargo must be stowed in compliance with this section for takeoff and landing. The restraint, packaging, load-limit, obstruction, and positioning conditions must all be satisfied during the highest-risk phases of flight — not only at cruise.
Where it trips operators up
Items moved or unsecured during boarding or in-flight handling must be returned to a compliant stowed state before takeoff and before landing. "Stowed for takeoff and landing" is the moment a loading discipline is tested.
The cargo-only exception — §135.87(c)(7)
There is a narrow seventh provision. Under §135.87(c)(7), for the carriage of cargo only, the obstruction condition in (c)(4) does not apply if at least one emergency or regular exit is available to provide all occupants of the aircraft a means of unobstructed exit. This is an all-cargo accommodation — it relaxes the exit/aisle obstruction condition only when the operation is carrying cargo and the single-exit availability is preserved. It does not change anything when passengers are aboard, and it does not relax the other conditions (restraint, packaging, load limits, position over occupants, stowed for takeoff and landing).
§135.87(d) — Under-seat baggage
Each passenger seat under which baggage is stowed must be fitted with a means to prevent articles of baggage stowed under it from sliding forward under crash impact loads, and from sliding sideways under the maximum widthwise load, to the extent those loads could cause injury — consistent with how the seat was type-certificated. The under-seat restraint bar or barrier is part of the certificated cabin configuration. Verifying it is an airworthiness matter for a mechanic, not a paperwork field — but its presence is part of what makes under-seat stowage lawful.
§135.87(e) — Fire-extinguisher reach
When cargo is carried in a compartment that is designed to require a crewmember to enter it to extinguish a fire, the cargo must be loaded so as to allow a crewmember to effectively reach all parts of the compartment with the contents of a hand fire extinguisher. In practice this means cabin/aft cargo cannot be packed so densely or so high that a crewmember could not get the extinguishing agent to a fire at the back of the load. It is a loading-procedure condition, not a record per se — but it is part of a defensible loading process.
What §135.87 Actually Puts In Your Records
This is the part operators most often get wrong: §135.87 is an operating rule, not a recordkeeping rule. It tells you how cargo must be restrained, packaged, and positioned. It does not, by itself, tell you to file a "cargo restraint form." But cabin cargo does not exist in isolation — its weight and position drive the aircraft's loading, and that is documented. Here is where §135.87 compliance becomes a record an inspector can pull.
The load manifest — §135.63(c)
For multiengine aircraft, §135.63(c) requires the certificate holder to prepare a load manifest in duplicate containing: the number of passengers; the total weight of the loaded aircraft; the maximum allowable takeoff weight for that flight; the center of gravity limits; the center of gravity of the loaded aircraft (when computing CG limits is required, with an allowance for stabilizer/fuel as applicable); the registration number of the aircraft or the flight number; the origin and destination; and identification of crew members and their crew position assignments. Cargo weight and where it sits in the cabin feed directly into the total weight and the CG of the loaded aircraft. The certificate holder must keep copies of the completed load manifest for at least 30 days (§135.63(d)). This is the single most direct documentary footprint of cabin cargo.
The weight-and-balance record
The §135.87(c)(3) load-limit condition (cargo must not exceed seat or floor load limitations) and the load manifest both rest on the aircraft's weight-and-balance data — the current empty weight and CG, the equipment list, and the loading limits from the approved flight manual. A cabin load that satisfies §135.87 must also keep the aircraft within its CG envelope. For how that record set is structured and retained, see the aircraft weight-and-balance records requirements.
Approval paperwork for installed cargo equipment
If you comply via §135.87(a) or (b) — an installed cargo rack/bin or an approved restraint system — the proof is the airworthiness approval: type design data, an STC, or a Form 337 for the major alteration, which becomes part of the aircraft's permanent records. That ties cabin-cargo compliance into the broader aircraft records requirements and the ARROW airworthiness documents carried aboard.
The hazmat boundary — what you will not carry
Cabin cargo restraint under §135.87 is separate from dangerous-goods rules. An operator that is not authorized to carry hazardous materials must keep its will-not-carry documentation and crew training current — see aviation hazmat / dangerous-goods will-not-carry records. A securely restrained box still cannot contain undeclared dangerous goods. Restraint compliance and hazmat compliance are two different gates that both apply to the same cargo.
Don't confuse §135.87 with the passenger briefing
The §135.117(a) pre-flight passenger briefing list (smoking, safety belts, seat backs, exits, survival equipment, ditching, oxygen, installed equipment) does not enumerate "stow your carry-on." The carry-on stowage obligation lives in §135.87, and the briefing obligation lives in §135.117 — supplemented by printed cards under §135.117(e). Treat them as two separate requirements rather than assuming one covers the other. For the briefing side, see Part 135 passenger briefing & cabin safety records.
See whether your cargo and loading records hold together
FileFlo classifies the documents §135.87 touches — load manifests, weight-and-balance records, and the STC/Form 337 approvals behind installed cargo equipment — indexes them against the governing CFR, tracks the documents that expire, and produces an inspector-format binder on demand. It does not load your aircraft or run your operation; it proves the records are complete. See the full Aviation compliance coverage.
Compliant vs Non-Compliant Cabin Loading — Side-by-Side
The same leg — a few boxes of parts plus a passenger's carry-on in a light twin — loaded two ways. The left column satisfies §135.87(c); the right column collects findings.
Compliant Cabin Load
- Boxes secured with the aircraft's approved cargo straps to seat-track tie-downs — no possibility of shifting (c)(1)
- Carry-on belted into a seat / restrained so it cannot move in turbulence (c)(1)
- Sharp-cornered parts boxed and padded — no exposed edges toward occupants (c)(2)
- Total cargo weight checked against seat/floor load limits from the AFM (c)(3)
- Nothing in the aisle or in front of either exit; required signs visible (c)(4)
- No box positioned directly above a seated passenger (c)(5)
- Load verified stowed and within limits before taxi and confirmed again before landing (c)(6)
- Weights and positions entered on the §135.63(c) load manifest; CG within envelope
Non-Compliant — Multiple Findings
- Boxes set on empty seats with no belt or strap — relying on friction (violates (c)(1))
- Passenger carry-on loose on the floor, free to move in turbulence (violates (c)(1))
- Unpackaged tooling with exposed edges facing the cabin (violates (c)(2))
- A box stacked in the aisle between the cockpit and cabin for a "quick leg" (violates (c)(4))
- A parcel resting on the shelf directly above an occupied seat (violates (c)(5))
- Cargo weight never entered on a load manifest; CG not computed (§135.63(c) gap)
- Restraint route never decided — not (a), not (b), and (c) conditions unmet
The conditions are cumulative — and so are the findings
Because §135.87(c) conditions are independent, a single mis-loaded leg can generate several discrete findings at once. The defensible answer is a written loading procedure that walks the route decision (a, b, or c) and each (c) condition, plus a load manifest that shows the numbers worked. FileFlo can index and surface those documents; it cannot make the loading decision for you. For how a surveillance review pulls these threads together, see how to prepare for a Part 135 FAA surveillance audit.
Where §135.87 Fits in the Part 135 Records Picture
Cargo restraint is one operating rule among many that ultimately resolve into documents an operator must be able to produce. The cleanest way to see it: §135.87 governs the act of loading; other sections govern the records that prove the operation was conducted within limits and by qualified people.
Loading & weight-and-balance
The §135.63(c) load manifest and the weight-and-balance records are the documentary home of cabin cargo. They are also where an inspector can see whether cargo weight and position were actually accounted for, or whether the cabin was loaded "by eye."
Cabin safety, briefings & equipment
Cargo positioning interacts with the cabin-safety regime: passenger briefing & cabin safety records and emergency & survival equipment records. Cargo that obscures a required sign or blocks access to survival equipment touches both §135.87(c)(4) and the equipment-accessibility expectations elsewhere in Part 135.
The wider operating-rule and records set
Cargo loading sits alongside the rest of the Part 135 documentary world — from flight locating / flight release records to your OpSpecs, which may add cargo and loading authorizations and limits specific to your certificate. The full retention picture is in the aviation records retention schedule, and the maintenance-record half — for any installed cargo equipment — runs through §43.9 maintenance record entries and Part 135 CAMP maintenance recordkeeping.
Related Part 135 records resources
- What records must a Part 135 operator keep — the master list
- Aircraft weight-and-balance records requirements
- Part 135 passenger briefing & cabin safety records (§135.117)
- Part 135 emergency & survival equipment records
- Aviation hazmat / dangerous-goods will-not-carry records
- Part 135 IFR fuel, alternate & weather minimums
- Operations Specifications (OpSpecs) explained
- Aviation records retention schedule — how long to keep what
Frequently Asked Questions
What does 14 CFR §135.87 actually require for carrying cargo?
Section 135.87 ("Carriage of cargo including carry-on baggage") prohibits carrying cargo, including carry-on baggage, in or on any aircraft unless one of three conditions is met: it is carried in an approved cargo rack, bin, or compartment installed in or on the aircraft (paragraph (a)); it is secured by an approved means (paragraph (b)); or, when carried in a passenger or crew-occupied compartment, it satisfies all of the conditions in paragraph (c). Those paragraph (c) conditions are the ones that govern cargo riding in the cabin alongside people — restraint, packaging, load limits, no obstruction of exits or the crew aisle, not directly above occupants, and stowed for takeoff and landing. Paragraphs (d) and (e) add an under-seat baggage retention requirement and a fire-extinguisher reachability requirement for certain cargo compartments.
Can you carry cargo in the passenger compartment of a Part 135 aircraft?
Yes — but only under the specific conditions in §135.87(c). Cargo carried in a compartment occupied by passengers or crew must be (1) properly secured by a safety belt or other tie-down with enough strength to eliminate the possibility of shifting under all normally anticipated flight and ground conditions (carry-on baggage must be restrained to prevent its movement during air turbulence); (2) packaged or covered to avoid possible injury to occupants; (3) within the load limitation for the seats or floor structure it rests on; (4) not located so as to obstruct access to or use of any required emergency or regular exit, the aisle between the crew and passenger compartment, or a passenger's view of the required signs; (5) not carried directly above seated occupants; and (6) stowed in compliance with the section for takeoff and landing. Meeting these conditions is what makes cabin cargo lawful — and what an operator should be able to demonstrate.
Does §135.87 generate a record that an FAA inspector reviews?
Section 135.87 itself is an operating rule, not a recordkeeping rule — it tells you how cargo must be restrained and where it may sit, not what to file. But compliance with it shows up in records governed by other sections. For multiengine aircraft, §135.63(c) requires a load manifest in duplicate that includes the number of passengers, the total weight of the loaded aircraft, the maximum allowable takeoff weight for that flight, the center of gravity limits, the center of gravity of the loaded aircraft, the aircraft registration or flight number, the origin and destination, and identification of crew members and their crew positions. Cargo weight and its position feed directly into that weight-and-balance computation. The operator keeps a copy of the load manifest (the certificate holder must keep copies for at least 30 days under §135.63(d)). So while §135.87 is about physical restraint, the documented evidence that the cabin was loaded within limits lives in the load manifest and weight-and-balance record.
Does cargo in the cabin have to be kept clear of the exits and the crew aisle?
Yes. Under §135.87(c)(4), cargo may not be located in a position that obstructs the access to, or use of, any required emergency or regular exit, or the use of the aisle between the crew and the passenger compartment, or located in a position that obscures any passenger's view of the "seat belt" sign, "no smoking" sign, or any required exit sign. There is a narrow exception in §135.87(c)(7): for operations carrying cargo only, the (c)(4) obstruction condition does not apply if at least one emergency or regular exit is available to provide all occupants a means of unobstructed exit. That exception is for all-cargo operations — it does not loosen the exit-access rule when passengers are aboard.
Can cargo be stacked directly above seated passengers?
No. Section 135.87(c)(5) states that cargo carried in an occupied compartment may not be carried directly above seated occupants. This is a distinct condition from the restraint requirement in (c)(1) and the load-limit requirement in (c)(3): even cargo that is securely tied down and within structural limits may not be positioned directly over a person in a seat. In practice this constrains how cabin cargo is arranged in a converted passenger-to-cargo layout and is one of the conditions a loading procedure should explicitly address.
What is the difference between an "approved" cargo bin and meeting the §135.87(c) conditions?
Section 135.87 offers alternative ways to comply. Paragraph (a) is satisfied when cargo rides in an approved cargo rack, bin, or compartment installed in or on the aircraft — "approved" means the installation is part of the aircraft's approved type design or an approved alteration (for example, a cargo pod, a certificated cargo net and barrier, or a fixed cargo compartment). Paragraph (b) is satisfied when the cargo is secured by an approved means. Paragraph (c) is the route for cargo that rides loose in an occupied compartment without a dedicated approved bin — and it carries the seven enumerated conditions. The documentation difference matters: an approved bin or restraint system traces back to airworthiness paperwork (type design data, a supplemental type certificate, or a Form 337 for the alteration), while the (c) route is demonstrated through loading procedures and the weight-and-balance record rather than an installed-equipment approval.
Does §135.87 require anything about baggage stowed under seats?
Yes. Section 135.87(d) requires that each passenger seat under which baggage is stowed be fitted with a means to prevent articles of baggage stowed under it from sliding forward under the crash impact loads for which the seat was certificated, and from sliding sideways under the maximum widthwise load expected in a crash, to the extent those loads could cause injury. This is why a restraint bar or barrier under the seat is part of the cabin configuration. It is a structural/configuration requirement tied to how the seat was type-certificated — verifying it is an airworthiness question for a mechanic, not a documentation question — but the existence of compliant under-seat stowage is part of what makes the cabin a lawful place to carry baggage.
How does §135.87 relate to the passenger briefing requirements?
They are related but separate. Section 135.87 governs how cargo and carry-on baggage must be restrained and positioned; the passenger briefing rule, §135.117, lists the topics the pilot in command must ensure each passenger is briefed on before flight. Notably, the §135.117(a) briefing list focuses on items such as smoking, use of safety belts, placement of seat backs, location and means of opening exits, survival equipment, ditching procedures, supplemental oxygen, and normal and emergency use of any installed equipment — and that oral briefing must be supplemented by printed cards under §135.117(e). The practical link is that a crew enforcing carry-on stowage at boarding is operationalizing §135.87(c), while the briefing is its own enumerated requirement. Do not assume the briefing rule lists carry-on stowage; treat them as two distinct obligations.
Related Aviation Compliance Reading
Part 135 Single-Pilot Operator Records
The thinnest-staffed operations still owe the full records set
Part 135 Flight Locating & Flight Release Records
Operational-control documents that ride with each flight
Part 91 Aircraft Records Requirements
The aircraft-records baseline beneath Part 135
FAA Form 337 — Major Repair & Alteration Records
The approval behind an installed cargo bin or restraint
ARROW Airworthiness Documents Carried Aboard
What must physically be in the aircraft
How to Prepare for a Part 135 FAA Surveillance Audit
How an inspector pulls loading and records together
Prove your loading and cargo records before an inspector asks
FileFlo is a compliance document intelligence platform. For aviation cargo, it classifies and indexes the records §135.87 touches — load manifests (§135.63(c)), weight-and-balance data, and the STC / Form 337 approvals behind installed cargo equipment — tracks the documents that expire, and generates an inspector-format audit binder on demand. It is the proof layer: it does not load your aircraft, run your operation, or replace your loading procedures. Starter $89/month · Professional $299/month · 5-day free trial, no credit card required.