The Canadian Border Services Agency’s (CBSA’s) implementation of the ACI/eManifest import filing requirement for freight forwarders has now entered the enforcement phase. Monetary penalties for non-compliance takes effect in July 2017. Here are some tips to ensure a smooth transition.
- Filing productivity
- View security filings as a subset of your shipment data. That way, most of the security filing data elements are at your fingertips.
- Look for patterns in your filings and reuse data for frequent and similar filings. Shipper, consignee, notify party, stuffing and delivery addresses are great candidates for reuse.
- Filing service providers, such as Tech Tech, takes advantage of this to simplify filings and keeps the data required to be entered to a bare minimum.
- Filing accuracy and completeness
- Ensure you validate Cargo Control Numbers (CCNs) and carrier/forwarder codes. Nothing works without them. Trade Tech ensures proper CCN’s and that other codes are validated before being transmitted to CBSA. This greatly improving accuracy.
- Code confusion is the most common cause for rejections. Understand which data elements are required and the appropriate codes to populate them. For example, Port codes, Sub location codes, Port of discharge codes, HS Codes, Dangerous Goods codes and Carrier codes).
- Filing visibility
- Although CBSA notices are not mandatory they are essential for tracking filing completeness and disposition, especially for consolidated shipments. Use them! Unfortunately, the CBSA eManifest portal doesn’t support a full set of notices until next deployment (D5). Currently, those are only supported by direct CBSA EDI feeds or through service providers, such as Trade Tech.
- Evolve procedures and tools to coordinate filings with co-loaders. CBSA requires all filing in a consolidation to be of the same type either eManifest or Supplementary Reports. Only the absence of a CBSA Cargo Complete notice, alerts master loaders that co-loader filings are incomplete or missing. Trade Tech has developed a unique process to automatically close consolidated HBLs in addition to a dashboard of security filings in progress.
- Think globally. Electronic filing can enable all supply chain participants to come together on the same page, provided by a shipping portal. Therefore, design your SOPs so filing data is entered by the folks closest to its source (usually at origin).
- Filing compliance
- Get familiar with filing eManifest ASAP, it’s complex.
- Make sure you archive your filings for the required 3 years
- Internal SOP Readiness – is your staff trained?
- Forwarders must educate their internal staff
- Is your company matched up with a global service provider to accommodate your needs? Trade Tech has helped many forwarders develop SOPs.
- Timeliness – eManifest has defined filing cut-off times that must be clearly communicated
- External SOP Readiness – have you educated your customers?
- Forwarders must educate their customers
- Consider how you will support your customers in multiple time zones and multiple languages?
- Timeliness – eManifest has defined filing cut-off times that must be adhered to – Trade Tech delivers support for a global 24/7/365 operation to keep your cargo moving.
In the recent Customs Notice 16-28, the CBSA makes further changes to the ACI/eManifest advance electronic import filing requirement.
For a limited period, CBSA will accept freight forwarders to electronically file ACI/supplementary reports (legacy ACI) instead of the new and more comprehensive ACI/eManifest. A paper HBL must be provided to CBSA at the destination to complete the filing. For consolidated shipments CBSA require forwarders to coordinate filings so they all are of the same type; either eManifest or legacy ACI. The CBSA will provide adequate notice as to when legacy ACI no longer will be accepted.
If a forwarder issues a HBL, then the liability of filing either legacy ACI or eManifest falls on the forwarder and not on the carrier. Prior to the implementation of eManifest, for a fee, forwarders could delegate this liability to carriers. If CBSA cannot perform cargo risk assessment, then the cargo cannot be loaded or if loaded it risks rejection at the first point of arrival in Canada. The non-monetary penalty phase of eManifest takes effect on January 11th, 2017. This applies to missing or incomplete filing.
Trade Tech recommends avoiding temporary work-arounds and instead file according to the new eManifest filing requirement, which is painless with modern Cloud based filing solutions.
The Canada Border Services Agency (CBSA) has announced a last-minute change in the eManifest security filing requirement for freight forwarders (FFs). We are nearing the end of the transition period, the first of three implementation phases for eManifest. The non-monetary enforcement phase begins in January 2017. On December 6, 2016, CBSA issued Customs Notice 16-29. This is a significant announcement and change by CBSA. Prior to this announcement, only Canadian-based FFs could be bonded and only those bonded FFs could move cargo that was required to be moved in bond in Canada and only those could file advance consolidated HBLs. Now, the opportunity is open to FFs from any domicile around the world to become bonded and simplify Canadian imports.
Companies across the globe have expressed concerns about eManifest readiness in general. We have been advised that there are some large co-loaders who are not yet ready for eManifest. We have clients who are unable to begin eManifest filing because their co-loaders are not ready. There are also some Canadian ports that are not ready to receive the Deployment 4 (D4) notices from CBSA. Because of this, those ports have created paper-based process workarounds for now.
Trade Tech is ready. Our services have been tested extensively by the CBSA and we are officially registered with the CBSA as a service provider. We have many customers that have started filing eManifest with us. However, many companies have not yet registered for eManifest. Trade Tech is ready to assist and to get all freight forwarders signed up and trained for eManifest. Our global presence allows us to train compliance teams in local country and language.
Trade Tech has worked with our partners to provide a complete solution, a one stop shop – we can assist you to apply for a Bond. Once received, we can manage the CBSA application to apply to CBSA to become bonded. We can also handle the acquisition of a CBSA 8000-series forwarder code (bonded or not) on your behalf.
We encourage you to start the sign-up process today. This will help ensure ample time for processing as well as time to review and implement your internal SOP and educating your customers. There is still time to practice eManifest filing before any CBSA letters of non-compliance will begin to be issued in January of 2017. Actual monetary penalties will take effect in July of 2017.
We are in the middle of a digital revolution that dwarfs the industrial revolution, you’ve heard many times. But how far along is the logistics industry really? Three concepts, unfortunately used interchangeably, define this digital journey. One concept builds upon the other, in this sequence:
Digitization → Digitalization → Digital Transformation.
We are already done with digitization, that was act of converting the analog world into digital computers. Today, I think my kids’ lives are more digital than real-world, analog. All businesses are digital in some form. Some industry icons slipped into the abyss of irrelevance like Eastman Kodak and Blockbuster as a result of digitization.
Digitalization, currently in full swing, is the process of getting the data back out of the computers, mobile phones and intelligent things into the Cloud. Uber and Airbnb are examples of companies mining this data and creating tons of value. Similarly, cloud native transportation management systems can unleash significantly efficiency gains by automating information-, cargo- and cash-flows, end-to-end, from origin to destination. Digitalization 2.0 lets our friends at Google, Facebook and NSA apply machine learning, at scale, to analyze and predict every move in our digital lives. That part I’m less enthusiastic about. However, machine learning will also help expedite flows of information, cargo and cash in global supply chains.
Digital Transformation, is the mega disruptor, the storm on the horizon the effect that will shake up things. Ocean carriers are scrambling to prepare for this phase. Manufacturers are already re-saddling to become service providers owning the equipment that calls home when it’s time for replacement or repair. Through consolidation at global scale, Amazon has the potential to dramatically increase global transportation efficiency, becoming the one place where all supply- and demand chains are run and managed. Transformation is more about business than technology. Disruptors will benefit and incumbents will need to seek new opportunities.
For thirteen years, the IT community has debated Nicholas Carr’s provocative claim that IT doesn’t matter. In a Harvard Business Review article, he argued that IT, like electricity, is everywhere and therefore doesn’t provide any strategic business advantage.
He got one thing right. As it turned out, cloud computing platforms did indeed commoditize data storage, processing and communication. However, he didn’t anticipate that cloud computing would fuel innovation that enable completely new business models. Nimble, cloud native innovators created services that made available to everyone, business process automation tools that were previously reserved only for enterprises with hefty IT budgets. Global by design and deployed in days rather than years, these services instantly created strategic advantages for its users. So, IT mattered a great deal after all. What do you think?
A company’s most valuable assets are the business processes that guide planning and execution of innovation, operations and relationships with customers and partners. You are your “process” was the mantra of one of my old bosses at SAP. Of course coming from SAP, that may seem a bit self-serving. Nevertheless, in logistics, process is king and timeliness is queen. Logistics clockwork is completely dependent on processes, making the mantra spot on. Now, not all processes are equal. Processes exist in a spectrum from ad-hoc to fully automated. While not ad-hoc, many logistics processes still rely on spreadsheets, emails and phone calls and are therefore manual in nature, requiring many “touches”. In few cases is the process documented and governed by policy but rarely is it automated. In global logistics these internal processes exist in an overarching flow between carriers, terminals, truckers, forwarders and shippers each with their own data silos. Orchestrating that flow has traditionally been very challenging.
The maturity and the ubiquity of Cloud technology is changing this situation rapidly; never before has it been possible to unify all the people, information and processes involved in global supply chain networks. An evolution, called digitalization, is under way to fully automate global flows, connecting all supply chain participants and systems in real-time via the Cloud. If you are a service company, like a freight forwarder, this is a key opportunity to rethink strategy and focus on innovation to gain competitive advantage. Consider, for example, providing your consignee with complete visibility into in-transit inventory and PO management.
Global supply chain flows can be broken down further into interconnected flows of INFORMATION, CARGO and CASH. Trade Tech specializes in simplifying and automating these flows with cloud technology (captured in our neat visual above). Shipping documents and compliance filings are artifacts of these flows. A shipping document is a snapshot of the flow at a specific time from a specific perspective. In other words, a shipping document is merely a view of the flow. Taking a flow centric, versus a document centric approach is important. The flow carriers the necessary information to complete a given document. There is absolutely no need to re-enter the data for the next hand-off in the chain. This seems to be an industry obsession and the source of most inaccuracies, lost visibility, costs and delays. However, only by standardizing core reference data (master data), which is non-trivial, can true automation take place. A Cloud based system that is always on and always connected can automatically synchronize such data. Think sailing schedule, GL account codes, SKUs, carriers codes, port codes, cargo types, hazard codes or stakeholder profiles etc. Workflow rules can now take action based on standardized qualitative data and automation can take place. With repeatable outcomes you are now in pole position for taking your business global. The perspectives of this digitalization are quite exciting:
Trade Tech, a leader in cloud-based solutions for the global shipping and logistics industry, announces its cloud-based solution, Syrinx™ e-Shipping Portal (Syrinx), is equipped for freight forwarders to submit ACI/eManifest security filings. Effective Nov. 7, 2016, the Canada Border Services Agency (CBSA) requires advance secondary data to be transmitted by freight forwarders for cargo imported into, or moving in-transit through Canada.
With the implementation of ACI/eManifest, freight forwarders are required to transmit advance house bill data electronically to the CBSA. The data must be validated and accepted by the CBSA 24 hours prior to the cargo being loaded aboard the vessel at the port of origin. Freight forwarders are also required to transmit a house bill ‘close’ message once all house bills within a consolidated shipment have been submitted. This expanded requirement replaces the existing ACI/supplementary reports, that now, instead is required for freight remaining on board (FROB) in Canadian ports.
Trade Tech co-founder and CEO Bryn Heimbeck says, “The eManifest requirement is quickly approaching and we’ve found that freight forwarders are making preparations for eManifest and having Trade Tech register them with the CBSA. Affected freight forwarders must realize that they not only have to register with the CBSA Technical Commercial Client Unit (TCCU), but that there is also a lengthy testing period before they can begin filing. Trade Tech can register and test on our clients’ behalf so we’re removing that burden from them and our solution ensures that they’re compliant, avoiding cargo delays and penalties.”
Timeframe for eManifest Requirement:
• From Nov. 7, 2016, to Jan. 10, 2017, the CBSA will provide freight forwarders with a period of transition during which penalties for non-compliance will not be issued and the CBSA will work closely with freight forwarders on corrective measures.
• From Jan. 11, 2017, to July 11, 2017, freight forwarders deemed to be non-compliant with eManifest requirements may be issued zero-rated penalties (non-monetary) under the CBSA’s Administrative Monetary Penalty System (AMPS).
• Beginning July 12, 2017, freight forwarders deemed to be non-compliant with eManifest requirements may be issued monetary AMPS penalties.
Trade Tech is offering weekly educational webinars on ACI/eManifest filings. Freight forwarders can click here to register for the next webinar.