Compliance checklist for Canadian import filing requirement

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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.

  1. Filing productivity
    1. View security filings as a subset of your shipment data. That way, most of the security filing data elements are at your fingertips. 
    2. 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.
    3. 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.
  2. Filing accuracy and completeness
    1. 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.
    2. 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).
  1. Filing visibility
    1. 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.
    2. 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.
    3. 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).
  1. Filing compliance
    1. Get familiar with filing eManifest ASAP, it’s complex.
    2. Make sure you archive your filings for the required 3 years
  1. Internal SOP Readiness – is your staff trained?
    1. Forwarders must educate their internal staff
    2. Is your company matched up with a global service provider to accommodate your needs?  Trade Tech has helped many forwarders develop SOPs.
    3. Timeliness – eManifest has defined filing cut-off times that must be clearly communicated
  1.  External SOP Readiness – have you educated your customers?
    1. Forwarders must educate their customers
    2. Consider how you will support your customers in multiple time zones and multiple languages?
    3. 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.

The Canadian Border Services Agency once again rocks the boat

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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.