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.