Canadian Border Service Agency (CBSA) ACI / eMANIFEST ...A: CBSA has recently modernized the way...

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Canadian Border Service Agency (CBSA) ACI / eMANIFEST FREQUENTLY ASKED QUESTIONS (FAQs) Q: What is eManifest? A: • eManifest is part of the overall measures the Government of Canada is putting in place to enhance the safety, security and prosperity of Canadians and international trade while streamlining commercial cross-border processes.? When fully implemented, eManifest will require carriers, freight forwarders and importers, in all modes of transportation, to electronically transmit pre-arrival information to the Canada Border Service Agency (CBSA) within prescribed time frames. Q: When does eManifest filing become mandatory? A: From November 7, 2016, to January 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 January 11, 2017, to July 11, 2017, freight forwarders deemed to be noncompliant with eManifest requirements may be issued zero- rated penalties (nonmonetary) 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. Q: Does eManifest replace ACI filing for shipments to Canada? A: eManifest is the 3rd phase of the Advance Commercial Information (ACI) initiative. It introduced the electronic advance cargo and conveyance information for carriers in highway and rail modes. In addition, the electronic transmission of advance secondary data (House bill and House bill Close Message) will be required from freight forwarders. Importers and/or their brokers will eventually have the ability to electronically submit the advance importer data, and will also introduce multimodal cargo reporting in air and marine modes. Therefore, eManifest is the next phase of the overarching ACI initiative. In terms of consolidations, in Air and Marine modes, air and ocean carriers were responsible for the submission of electronic supplementary reports since 2006. Presently, freight forwarders can submit electronic house bills. As House bills become mandatory for import and in bond movements, the electronic supplementary reports will no longer be required for those movements, but freight forwarders will be required to submit supplementary reports for Freight Remaining on Board (FROB) and for In-Transit Export cargo. ACI/eManifest expands the original ACI/Supplementary reports requirement. The legacy ACI now called ACI/Supplementary reports will still be required for freight remaining on board (FROB). A 6- month exemption from filing ACI/eManifest is in effect for in-transit moves to and from the US. The filing requirement for the different movement types are as follows: Legacy ACI now ACI/Supplementary Reports? - For FROB cargo going to Canada? - In-transit Goods to and from the US (6 month ACI/eManifest exemption in effect) Enhanced ACI/eManifest: - for freight that is imported into Canada (Port to Port Import Goods) / Inland Transit In- bond Goods)

Transcript of Canadian Border Service Agency (CBSA) ACI / eMANIFEST ...A: CBSA has recently modernized the way...

Page 1: Canadian Border Service Agency (CBSA) ACI / eMANIFEST ...A: CBSA has recently modernized the way they deal with service providers. Your company does not need to test directly with

Canadian Border Service Agency (CBSA) ACI / eMANIFEST FREQUENTLY ASKED

QUESTIONS (FAQs)

Q: What is eManifest?

A: • eManifest is part of the overall measures the Government of Canada is putting in place to

enhance the safety, security and prosperity of Canadians and international trade while

streamlining commercial cross-border processes.?

• When fully implemented, eManifest will require carriers, freight forwarders and importers, in all

modes of transportation, to electronically transmit pre-arrival information to the Canada Border

Service Agency (CBSA) within prescribed time frames.

Q: When does eManifest filing become mandatory?

A: From November 7, 2016, to January 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 January 11, 2017, to July 11, 2017,

freight forwarders deemed to be noncompliant with eManifest requirements may be issued zero-

rated penalties (nonmonetary) 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.

Q: Does eManifest replace ACI filing for shipments to Canada?

A: eManifest is the 3rd phase of the Advance Commercial Information (ACI) initiative. It introduced

the electronic advance cargo and conveyance information for carriers in highway and rail modes. In

addition, the electronic transmission of advance secondary data (House bill and House bill Close

Message) will be required from freight forwarders. Importers and/or their brokers will eventually

have the ability to electronically submit the advance importer data, and will also introduce

multimodal cargo reporting in air and marine modes. Therefore, eManifest is the next phase of the

overarching ACI initiative. In terms of consolidations, in Air and Marine modes, air and ocean carriers

were responsible for the submission of electronic supplementary reports since 2006. Presently,

freight forwarders can submit electronic house bills. As House bills become mandatory for import

and in bond movements, the electronic supplementary reports will no longer be required for those

movements, but freight forwarders will be required to submit supplementary reports for Freight

Remaining on Board (FROB) and for In-Transit Export cargo.

ACI/eManifest expands the original ACI/Supplementary reports requirement. The legacy ACI now

called ACI/Supplementary reports will still be required for freight remaining on board (FROB). A 6-

month exemption from filing ACI/eManifest is in effect for in-transit moves to and from the US. The

filing requirement for the different movement types are as follows:

Legacy ACI now ACI/Supplementary Reports?

- For FROB cargo going to Canada?

- In-transit Goods to and from the US (6 month ACI/eManifest exemption in effect)

Enhanced ACI/eManifest:

- for freight that is imported into Canada (Port to Port Import Goods) / Inland Transit In-

bond Goods)

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Q: Do I have to register with the CBSA Technical Commercial Client Unit (TCCU)?

A: SmartLink can sign up your company with the CBSA. Your company has to be registered

individually with CBSA. If your company has been an ACI filer for some time, chances are that you

need to submit new paperwork to CBSA. All filers must compete a form “Electronic Data Interchange

(EDI) Application for Advanced Commercial Information (ACI)” and list SmartLink as your service

provider. SmartLink will provide this for you.

Q: Do I have to test with the TCCU?

A: CBSA has recently modernized the way they deal with service providers. Your company does not

need to test directly with the CBSA if you have a service provider like SmartLink. CBSA will onboard

and test with the service provider and then their clients can test directly with their service provider.

Q: What computer technology do I need to have to file eManifest?

A: To file eManifest through SmartLink, you are only required to have an internet connection and

access to a browser. SmartLink will provide each client with a unique User ID and Password to allow

access to the SmartLink eManifest filing environment.

Q: Does my company need to have an 8000 series carrier code?

A: Any freight forwarder may obtain an 8000 series freight forwarder code, however only freight

forwarders residing in Canada may obtain a bonded freight forwarder code. Foreign based freight

forwarders can only receive a non-bonded freight forwarder code, meaning, that they may not move

cargo in-bond to seek release inland without re-manifesting their shipment to a bonded freight

forwarder or bonded carrier. Non-bonded freight forwarders can only use the “import” shipment

option.

Q: Will FCL shipments without a house bill be exempt from eManifest?

A: Unless subject to an exception or an exemption, all commercial cargo must be reported

electronically and in advance to the CBSA. Each trade chain partner is required to provide pre-arrival

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eManifest data to the CBSA, within the mode specific timeframes. If 3 there is a freight forwarder

involved in the transportation process, the CBSA will expect the freight forwarder to provide the pre-

arrival data.

Q: How do the e-Manifest data elements differ from regular ACI?

A: The data elements differ between the ACI supplementary report and the ACI eManifest electronic

House bill.

Q: Will eManifest only apply to consolidated or LCL shipments?

A: eManifest will require all carriers, freight forwarders and importers to send advance commercial

information about their shipments electronically to the Canada Border Services Agency.

Q: What are the steps involved?

A: There isn't any particular order in which the various filing steps have to occur, as long as all of

them are eventually submitted before vessel sailing (vessel arrival for cargo originating in the US or

Puerto Rico / BBK cargo), since the steps listed involve both BL filing and BL close messages:

a. Carrier submits Primary CCN (MBL) - Can happen before or after secondary CCN is filed under it.

b. NVO submits Secondary CCN (HBL) directly under Primary CCN - Can happen before or after

primary CCN is filed above it.

c. NVO submits HBL Close Message to close Primary CCN - Can happen before or after related

primary CCN is on file.

d. If the Secondary CCN (HBL) is a consolidated HBL then the party filing under it submits their HBLs -

Can happen before or after the related consolidated HBL is filed.

e. Party filing under the consolidated HBL submits the HBL Close Message to close out the

consolidated HBL - Can happen before or after the related primary CCN is closed, but must happen

after the related consolidated HBL is on file.

Q: If my company is a master loader, and we submit all House bills on time, but the co-

loaders beneath my company do not, then how do we rectify that problem? Or does the

cargo just not load?

A: This reflects the multiple tiers of consolidation scenario. If a client is a master loader freight

forwarder and they have co-loader freight forwarder partners beneath them that also need to

submit their respective House bills, the key will be the Cargo Complete message. An indication to the

master loader (who submits a consolidated House bill) that their co-loader partners have not

completed their electronic House bills is if the master loader does not receive the Cargo Complete

notice on the consolidated House bill. This means that the CBSA has not received the House bills

within the mini consolidation. In this instance, the master loader would need to reach out to their

coloader partner to ensure they submit their part of the consolidation before the cargo is loaded

otherwise the CBSA will not have complete cargo that is required from a risk assessment perspective.

Q: This works if the master loader knows who the co-loaders are beneath them but what

happens if there are many levels underneath?

A: Master loaders are responsible for their direct clients. If you are delivering consolidated freight to

the co-loader, you will need to know that they are consolidated and the cargo complete on them. If

there were 3 tiers of consolidation, that freight forwarder would be responsible for getting their

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cargo to cargo complete thereby getting the top level to cargo complete.

CBSA will not be issuing any DNLs during the initial implementation of eManifest and the most likely

reason for a DNL against a consolidated BL (carrier MBL or master loader HBL) is the inability of CBSA

to know the actual or ultimate consignee due to the 4 sub-HB/Ls not being on file.

Q: What is the House Bill Close Message?

A: 1) The freight forwarder is required to provide a Close Message to CBSA. If it is a one to one ratio

the SmartLink application will automatically send the close message when the Master or

Consolidators House Bill has been submitted. The close message is used to initiate the link between

the parent and child documents in CBSA's system.

2) If the house bill submission has a further deconsolidation (Master Loader) the Consolidation

Indicator must be set to Yes.

3) The Master Consolidator must submit a HBL to CBSA for every shipment that they have in the

container. The HBL may show the shipper and consignee as the NVOCC. A Master Loader must be

bonded in Canada in order to submit a consolidated bill.

4) The Master Loader must submit a closing message to CBSA listing the HBLs they have filed

under the carrier's primary CCN.

5) The underlying NVOCC must submit a closing message to CBSA referencing the Master Loader’s

HBL.

Q: Can a foreign freight forwarder (one that is not resident in Canada), be allowed to

convey all these House bills and the Close Message as well? Or will only Canadian

domiciled freight forwarders be allowed to do this?

A: House bills can be submitted by any freight forwarders with an 8000 carrier code or their modal

carrier code (something new CBSA added). The key is whether you are bonded or not. If you are non-

bonded, it puts a restriction on the movement of the goods on your cargo documents. Non-bonded

FFs (bonded freight forwarders must be Canadian residents) can submit House bills but they cannot

move on the house bill. It will require a paper re-manifest to move beyond the primary warehouse.

Unless the primary itself is destined to the place of release.

Q: Can the Close Message be sent at the same time as you transmit the last House bill

details?

A: The House bills listed on the House bill Close Message need to be on file and accepted by the

CBSA before the House bill Close Message can be submitted and accepted.

Q: Will the Deconsolidation notice be part of the suite of notices that will be coming out?

How will we be able to see it? Through the current EDI channel?

A: At the moment, for the House bills, a filer will only receive the Matched/Not Matched notice.

SmartLink will register filers with the TCCU in order to receive all available EDI notices and do testing

in the SmartLink testing environment. They will not be available in the CBSA Portal until end-state.

Q: Who gets the DO NOT LOAD (DNL) notice on a multi-level consolidation? Master loader

and lower level forwarder?

A: CBSA has advised that in the DNL notice will be sent to the primary notify party (party that

submitted the document against which the DNL was posted) and any related automated notify

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parties or secondary notify parties. In other words, the party that submitted the related MBL or HBL

will get the DNL, as well as any other parties listed on the document; e.g. carrier listed on NVO HBL

or NVO listed on carrier's MBL.

Q: How does the Master Loader and Co-Loader Close process work?

A: The Master Co-Loader is responsible for closing the MBL. Co-Loader must close the Master Co-

Loader's file relative to the HBL they have tendered. The party that files HBLs under the related

parent BL is responsible for closing out the related parent BL (aka "Previous CCN"). In other words,

the underlying co-loader that files the HBLs under the master loader is responsible for closing out

the master loader's BL.

Q: How does the Auto-Closing process work for FCL shipments?

A: The close message is closing out the related parent BL. For FCL the close message will close out

the Carrier's MBL. In addition, CBSA requires that in order to close out a consolidated HBL the related

consolidated HBL must be on file or the close message will be rejected. However, it is NOT necessary

for the carrier's MBL to be on file prior to sending the close message that closes out the carrier's MBL.

Q: I already did EDI testing. I find it very difficult to go back to revise data that was sent.

How do I do that?

A: You have to make sure you are using the right function. If the goods have not arrived into Canada,

you will have to use the “Change” function. If the goods have arrived into Canada (Reported) then

you will need to use the “Amend” function. SmartLink will track whether the cargo has arrived or not

arrived at the first port of arrival (FPOA) and submit any updates to the HB/L filing as a "Change" or

"Amend" accordingly.

Q: Ocean Reporting Timeline: A bonded Freight Forwarder must meet the 24 hour prior to

loading timeline...is this correct?

A: A freight forwarder must respect the pre-established ACI mode specific timelines when submitting

their House bill data. 24 hours prior to loading or arrival depending on type and origin of goods for

marine, 4 hours prior to arrival or at time of departure for air, 2 hours prior to arrival for rail and 1

hour prior to arrival for highway.

Q: Does the CCN have to be shown on the first EDI transmission when it is an LCL shipment?

Can the CCN be entered afterward?

A: The CCN is a mandatory data element and must be entered in order to transmit a Cargo document

or a House bill. The CCN cannot be entered afterwards.

Q: We are using a service provider to submit eManifest data (EDI). Shall we contact TCCU

to set up the receiving of the Deconsolidation Notice? Or shall we just make sure our

service provider has the capability of receiving the notice?

A: Recently CBSA has modernized the way we deal with service providers. The CBSA still has to sign

you up and register you as individual clients to set up a profile but now, you don’t need to test

directly with the CBSA if you have a service provider; we will onboard and test with the service

provider and then their clients can test directly with their service provider.

Q: What is a manifest forward?

A: CBSA has provided the filer the ability to forward their manifest information to a third party

(warehouse, trucker, etc.) if this party has received a client identifier (from CBSA) and has been

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designated on the filing. This is an optional field in the filing.

Q: If we can know how all ocean carriers' CCNs are structured, that will be very helpful for

us to submit eManifest within the required time frame. Let's say, if we know all ocean

carrier's CCN is formatted as 9000 # + Booking number... Otherwise, we have to rely on our

overseas branches to obtain the number within the required timeframe, it sometimes

could be very challenging.

A: Assigning a CCN to a trade document is per the discretion of the company assigning the number.

There is no set structure. As long as the number is a unique number that has not been used within

the past 3 years plus the current year and is a maximum of 25 characters, a client can choose any

number in any manner the company chooses. The onus will be on trade to ensure that they have all

the information they need before they transmit their data to the CBSA.

Q: How long do filing records have to be retained?

A: Freight forwarders are responsible for maintaining records for 3 years plus the current year to

comply with regulations. The CBSA eManifest Portal is a transmission method 6 only and is not a

database for records management. SmartLink’s eManifest solution will allow all filings to be

maintained to comply with the CBSA regulations.

Q: Will freight remaining on board (FROB) be subject to filing supplemental data for

eManifest?

A: Until house bills become mandatory on November 7, clients choosing to transmit house bills for in

transits and imports on a voluntary basis will not be required to submit supplementary reports for

shipments with a house bill on file. Supplemental reports will only be required for FROB shipments in

the air and marine modes.

Q: Does it matter if the FROB’s final destination is Canada, or elsewhere?

A: The CBSA defines FROB as follows:

a) Marine – Cargo on a vessel that is not being discharged at a Canadian seaport but remains on

board the vessel for furtherance to its ultimate destination outside of Canada

b) Air – Cargo that is not being discharged at a Canadian airport but remains on board the aircraft for

furtherance to its ultimate destination outside of Canada Supplementary Cargo Report - a document

submitted by a freight forwarder for shipments that have, or will be deconsolidated from an air or

marine cargo control document for freight remaining on board (FROB) shipments only.

Cargo that is staying on board in Canada is subject to a supplementary filing instead of an eManifest

HBL filing. A supplementary filing is what we're currently sending to CBSA for all types of goods

(Imported or Stay on board) and is basically a paired down version of the HBL filing we'll be sending

for eManifest.

An exception to the rules for Stay On Board cargo is that the freight forwarder doesn't need to file a

supplementary if the cargo stays on board in Canada and ultimately discharges in the U.S.

An eManifest filing needs to be completed for U.S. goods traveling through Canada to an overseas

location, like Asia or Europe (U.S. exports through the port of Montreal to Europe, for example). The

CBSA expects freight forwarders to provide electronic house bill data for US loaded in-transits.

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Q: Please clarify the difference between supplemental data and the required data

elements for eManifest?

A: A House bill is a Cargo Control Document submitted by a Freight Forwarder for shipments that

have, or will be, deconsolidated from another Cargo Control Document, and which will control cargo

liability. A supplementary report is a set of data elements transmitted by a carrier or freight

forwarder to complete a primary cargo report. Data elements include detailed cargo information that

is not available on the original primary cargo report. The data elements required in the House bill

and the Supplementary Cargo report are very similar. Under the new regulations, the supplementary

cargo document will be required for FROB and In-Transit shipments in air and marine modes, while

the electronic house bills (eManifest) will be required for import and in-bond shipments in air and

marine modes.

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eHBL, eManifest FAQs – Basic, Introductory

Q: Are ‘back-to-back’ shipments consolidations requiring eHBL?

A: Yes. Any shipment with a HBL, even a single HBL is a consolidation and the consolidation indicator

must be triggered.

Q: Is there an eHBL 8000 where there is no house bill?

A: No. When the consignee on the carrier’s bill of lading of MAWB is the importer and there is no

actual house bill, there is no eHBL. The shipment will customs clear on the primary carrier’s MAWB

or 9000 or truck or rail cargo control number (CCN) and there will be no 8000 CCN.

Q: What are the timeframes for when eHBL data are required to be transmitted?

A: That depends on the mode. See the picture below and discussions under air and marine sections.

Q: Are “supplementary data” / “supplementary report” ACI HBL filings?

A: YES. The s10 Supplementary filing is the current ACI filing.

Q: Is “electronic house bill” the new eManifest filing?

A: YES. The eHBL is the electronic house bill and is the new eManifest filing. Sometimes also called a

‘secondary report’ or secondary filing by CBSA.

Q: What is the primary cargo control number (CCN)? How do we get the primary CCN? Do

we need it if we’re co-loading?

A: The Primary Cargo Control Number is defined by the CBSA as the original cargo control number

(CCN) used in the submission of the house bill to reference the carrier’s primary cargo document,

with the carrier code preface – for example 9000 for ocean carriers or the master airway bill for air

carriers. Truck and railroads also issue primary cargo control numbers.

The 9000 CCN is provided by the carrier but it is not always carrier 9000 code + B/L number. Each

carrier has different variations and one must insist on a carrier providing the cargo control number in

writing. Example – Hapag Lloyd B/L starts with HLCU (their SCAC code) but the HLCU part is not

included in the CCN.

Overseas agents or offices must receive the primary CCN from the carrier – usually at time of

booking.

Co-Loaders will have primary carrier CCN on hand and must provide it to each freight forwarder they

are providing space to in ocean container or airline unit. Every tier of forwarder requires the primary

carrier’s cargo control number.

Q: What is the requirement for HS Codes? 6 digit HS code or 10 digit HS code? What is the

requirement if there are multiple HS Codes in the shipment?

A: One HS Code only, to 6 digits if you have it on tour paperwork that you get from the shipper and it

is on the actual house bill issued by your office / agent from origin.

From the CBSA: “The requirement for a freight forwarder to provide an HS code / Customs Tariff item

number is conditional upon the freight forwarder having this information as part of the bill of lading,

way bill or similar transportation source document. If the HS code / Customs Tariff item number for a

specific shipment is no included in any of its source documents, there is no requirement for the

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freight forwarder to provide an HS code / Customs Tariff. Freight forwarders are only expected to

provide the HS code / Customs Tariff information that is provided to them and they are not expected

to classify the goods.

Should this information have to be transmitted: as per Chapter 8 (Advance Commercial Information

(ACI) / eManifest House Bill Portal) ECCRD it states under the cargo description that a minimum of 6

digits must be provided depending on the ECCRD data element conditions and system specifications.

At this time the (CBSA) system allows for just one HS code per house bill transmission. We would

suggest using the HS code that represents the bulk of the shipment.”

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eHBL, eManifest FAQs – Implementation

Q: What does November 7, 2016 mandatory date men? Why is January 11, 2017 significant,

particularly for marine shipments?

A: As started in Customs Notice CN 16-17, the regulations for eHBL come into force on November 7.

However, we have a 45 working day ‘implementation’ period where either eHBL or ACI may be filed,

to January 11, 2017.

For marine shipments, it is a bit confusion. The November 7th date is the ‘vessel arriving’ date at the

first Canadian port. So, technically, the eHBL data should be transmitted for all shipments arriving in

Canada on or after November 7th. Which means that to adhere to the timeframes, eHBL should be

filed before those shipments are loaded at the last origin port before heading to Canada.

The important date is January 11, 2017. Shipments arriving in Canada on or after this date must have

the eHBL data transmitted ‘within the timeframes’. This means cargo loading overseas probably in

December with a 30-40 day transit to Canada must have eHBL filed.

Q: Can a freight forwarder submit eHBL data if not all co-loaders / forwarders in that

consolidation are transmitting?

A: The TCCU understands that the inability to combine paper and electronic house bill during the

voluntary period is causing issues for those freight forwarders who are wanting to be proactive and

get an early start on electronic house bill filing. However, it was necessary to put certain systems

rules in place to respect the amendments to Reporting of Imported Good Regulations regarding

electronic house bill requirements. These rules make the combination of paper and electronic house

bill unmanageable. The CBSA is working towards a date for mandatory electronic house bill. Once the

date has been announced there will be a period of 45 business days where no penalties will be

assessed for non-compliance. After the 45 business days, a 6 month zero-rated AMPS period will

begin. Leading up to, and during the phase in of penalties the CBSA will be actively communicating

with freight forwarders regarding their understanding and compliance with the Regulations.

Q: Are primary airline warehouses / ocean & rail carriers’ terminals ready to handle

paperless cargo under the freight forwarders’ 8000 Cargo Control Number – with the

Deconsolidation Notice?

A: No. And this is a big problem. The Deconsolidation Notice is voluntary. The CBSA understands the

need and has a plan to send letters to all warehouse operators. They will also work with CIFFA to

identify which terminals / warehouse need to implement D4 Notices, especially the Deconsolidation

Notice which is needed right now. Furthermore, as published in the July 5th eBulletin, the CBSA

announced that they are now in production with the House Bill Close ‘Document Not on File’ and

“the Deconsolidation Message”.

Q: Will the CBSA publish a list of sufferance warehouses that are ready for Deconsolidation

Notices?

A: No. According to the TCCU, there are 22 warehouse and 13 freight forwarders on Deconsolidation

Notices production as of Thursday June 30.

The CBSA cannot provide that information due to their interpretation of the privacy regulations in

Canada. They will provide updates on a regular basis as to how many are implementing.

Q: If we file eHBL do we still need to file ACI Supplementary?

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A: NO. In paragraph 5 of the Customs Notice it states that “On November 7, 2016 electronic house

bill will become mandatory. In the interim, clients choosing to transmit house bill for in transits and

imports on a voluntary basis will not be required to submit supplementary reports for shipments

with a house bill on file.”

Q: Does this mean that if we file eManifest HBLs, we no longer as of June 29th, 2016 need

to file ACI?

A: Correct. According to the CBSA, paragraph 5 ‘In the Interim’ means from the date of CN 16-17

(June 29, 2016). So, as of now, if there is an eHBL on file, there is no need for an ACI Supplementary.

It means there is only a need to submit once, within the time frames. This is great news as freight

forwarders who implement eHBL transmissions will not need to transmit twice.

Q: What is the best way to contact CBSA for live freight issues? We have already

experienced several ‘live freight’ problems – mostly with getting cargo out of warehouses,

having knowledgeable CBSA local officers ready to help etc. delays with ‘live shipments’

mean screaming customers, storage charges, anxiety and frustration.

A: The best thing is to go to the Longroom counter and ask to speak to a CBSA eHBL ‘specialist’. It has

been confusing and Border Services Officers (BSOs) at the counter don’t always know the way to fix

the problem, BUT, you can ask them to contact the specialist units in Ottawa and they are generally

helpful and willing to talk to someone to find the solution.

Q: My agent is continuing to submit the ACI and we are submitting the eHBL. Is this OK

and can we use different cargo control numbers?

A: There is no problem with transmitting a supplementary report and a house bill for the same

shipment. And there is no problem with the carrier code for the supplementary being different from

the carrier code on the house bill.

There are rules that will not allow the same cargo control number (CCN) to be used. So you could not

file a supplementary report with the exact same CCN as the house bill.

And, there is a rule that requires all of the house bill within a house bill close message to have the

same carrier code.

eHBL, eManifest FAQs – Marine

Q: What are the timing requirements to submit the data (eHBL) to the CBSA for ocean

import shipments?

A: The 8000 eHBL must be submitted with all elements at least 24 hours prior to loading of the

vessel at the last port of loading before heading to Canada. So, this is the last port of departure, not

the first port of departure. Realistically, the eHBL data must be provided at least 4 or 5 days prior to

loading and in many cases eHBL data can be transmitted two, three or four weeks prior to loading of

the container onto the vessel. eHBL should be submitted as early in the process as possible,

especially in co-load situation.

Q: What is the requirement for Port of Discharge sub-location code on out eHBL?

A: Currently, the policy is that the port of discharge and subloc are conditional, the condition being

“if different from the port of destination”. The ECCRD reflects this policy. However, the CBSA

Transporter Cargo and Control Programs Unit (TCCPU) has reviewed the requirement for port of

discharge and sub-location code on the house bill transmission, and will make the appropriate

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changes to the ECCRD to state that the condition on the port of discharge and corresponding sub-

location code data elements is conditional “If available”.

Q: What happen when a co-loader above you has not switched to eHBL and is still doing

paper re-manifests?

A: The rule to reject an electronic house bill when the previous house bill is not on file was put into

place during the voluntary period to address scenarios where not all freight forwarders involved in

the consolidation were transmitting electronically. Due to the unpredictable nature of paper and

electronic house bill, a decision was made that during the voluntary period all house bills in all tiers

must be electronic, or the existing paper process would have to be used. This rule will be turned off

when house bill become mandatory, at which time the system will accept the tier 2 house bill even if

the previous is not yet on file. A ‘not matched’ response will be sent to the sender of the tier 2 house

bill.

Q: How do we get the primary cargo control number in time to file the eHBL before the

vessel departs? (Normally we only get it when the carrier issues the arrival notice after

cargo arrives in Montreal.)

A: Talk to your co-loader / carrier. The master co-loader must provide the primary cargo control

number (CCN) at least several days before goods can be loaded overseas. Each co-loader in the

consolidation must provide that primary CCN to the co-load customer below. Normally, the co-loader

will provide the primary CCN at the same time as it providers its 8000 CCN (which could then

become the Previous CCN)

Q: What is the Primary CCN that we use in a multi-tiered co-load consolidation? Does it

need to be the 9000 series CCN from the ocean carrier for every party involve in this

consolidated container?

Scenario consolidation: what happens when there is a co-loader within a co-load, meaning that

multiple level of forwarder.

For example:

- Our Chinese agent book with ABC Forwarder for space in a container

- ABC Forwarder books with master co-loader XYZ Forwarder line for the space on the

container

- XYZ Forwarder books with COSCO for the space on the vessel.

- We, the end receiving forwarder may have 1 or 2 or 3 House bill in this consol.

Right now, we get an ABC Forwarder Manifest that is using XYZ Forwarder Master

Co-Loader’s CCN as ‘previous CCN’. We use ABC Forwarder’s CCN as previous CCN

to de-consol our shipment (When we have several house bill involved) under our

carrier code and we than issue customs clearance 8000 CCN for each shipment

A: Yes, the primary cargo control number is the carrier’s primary CCN (COSCO) that you will have to

get from ABC Forwarder and ABC Forwarder will have to get from XYZ Forwarder, the master co-

loader.

Q: Do all levels in the co-load user the same primary CCN? For Example: ABC Forwarder,

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XYZ Master Co-Loader and us, the last in the line would file under the COSCO CCN and

closed message for each e-manifest using the same primary CCN?

A: You close up to the co-loader’s 8000 above you. You reference the primary CCN on your eHBL, but

you close up to the PREVIOUS CCN. Don’t confuse the PRIMARY with the PREVIOUS CCN and

remember you will need both the Primary CCN and the Previous CCN to file the eHBL in a co-load.

Q: Will we always need to clear the cargo under our cargo control number? Or can we

clear under the co-loader or carrier cargo control number as we do now?

A: That depends on the arrangement with the co-loader. If you provide the HBL data to the co-loader

and the co-loader files the eHBL under its 8000, then the release request and clearance would be

under their 8000. If you file the eHBL under your 8000, then the release request and clearance would

be under your 8000. It all depends on which organization files the eHBL data. With eManifest, the

eHBL CCN is the same CCN as the release request / clearance.

Q: Do we know if there has been any testing with the big NVOCC co-loaders? These are the

freight forwarders who have multiple layers of freight forwarders in their containers – so

Forwarder 1 must file an 8000 eHBL and send it to Forwarder 2 who will file his multiple

eHBLs, one of which is another co-loader 8000 and he sends it to Forwarder 3 and so on

down the line. Thousands of co-loaded shipments will be in these cascading eHBLs and

there are concerns that no testing has happened to demonstrate how that will actually

work in real life?

A: In discussing this issue with CBSA client testing and system testing team, it is confirmed that co-

load tests were conducted in the system testing phase (pre-production), however they are not part

of the CBS client testing (production) package at this time.

Q: Regarding Freight Remaining On Board cargo, when a freight forwarder has a house bill

shipment for Montreal and the carrier vessel calls Halifax first, then discharges the

Montreal cargo in New York for the primary carrier arranged transport into Canada, what

is the freight forwarder responsible for filing?

A: Under current regulations, a supplementary report is required for each consolidated shipment

within the FROB movement, so the shipment will require a FROB declaration.

When the shipment returns to Canada as an import movement, an electronic house bill transmission

(eHBL) will be required for each shipment. That eHBL 8000 will be ‘attahced’ to a truck or rail primary

cargo control number.

It is important to note that the CCN used for the electronic supplementary transmission cannot be

used for the electronic House bill transmission. The CBSA is working on a systems enhancement that

will allow for the recognition of the movement type with respect to the CCN number which would

allow the same number to be used for different movement types, however, this functionality is not

yet available.

Q: If a freight forwarder has a shipment that is to be released / acquitted at FPOA, is a

warehouse name and address / sub-loc required?

A: The Warehouse sub-location code field is Mandatory on the House Bill regardless of whether the

shipment is to be released / acquitted at FPOA. Please note the name / address is not mandatory –

only 4-digit sub-loc is required.

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Q: What if we don’t have the Port of Discharge Code or the Subloc Code? (For example,

our shipment is moving to Toronto 0495, subloc xxxx and will be arrived at the final

destination. The carrier may not provide us the Port of Discharge Subloc Code.

A: The Port of discharge and the Port of Discharge Subloc Code have been made conditional.

The condition is ‘when available’ and attached to either / both of the data fields.

• If the Port of Discharge Subloc Code is available it must be presented and then obviously the Port

of Discharge Code must be presented.

• If the Port of Discharge Subloc Code is not available, it need not be provided and then the Port of

Discharge Code should not be provided.

• If the Port of Discharge Code is provided then the Port of Discharge Subloc Code must be provided.

Q: Can I file eHBL if the forwarder above me in a co-load tier files paper?

A: No. Remember, if everyone above you in a tiered co-load files eHBL, you can file eHBL. If someone

above you in the co-load file paper, you must file paper. It doesn’t matter if somebody below you in

the tier file paper. That will not affect your eHBL.

Q: Primary warehouse are telling me I can’t release a single / back-to-back on the 8000

CCN. What is the regulations?

A: As per paragraphs 115 and 116 of the updated Freight Forwarder Pre-arrival and Reporting

Requirements Memorandum D3-3-1, single shipments that are destined to the same warehouse as

the primary cargo, and are in good standing, will be arrived by the conveyance arrival certification

message (CACM) and released. Single shipments that are destined to the same warehouse as the

primary cargo, but do not have a release on file in good standing, or require examination must be

arrived by the primary warehouse using the WACM.

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eHBL, eManifest FAQs – Notices

Q: If the freight forwarder submits their eHBL and the Primary CCN is not on file, who

receives this message? The carrier or the freight forwarder or both?

A: The Document Not on File notice does not go to the Prime Carrier if a freight forwarder submit

their HBL. The Doc Not On File would only go to the Primary Carrier when the freight forwarder

submits the House Bill Close Message.

Q: When ‘document not on file’ is issued, will it reference whether it was generated based

on a previous message being cancelled / rejected as opposed to never actually being on

file?

A: Since the Document Not on File Notice is delivered only to the client whose quoted document is

not on file, they should know themselves whether they ever actually submitted the document or not.

The Document Not on File Notice will be delivered to carriers when either a House Bill Close

Message or Pre-Arrival Release document quotes a CCN with that carrier’s carrier code. When the

client receives this notice, they should be able to verify in their own internal systems whether that

CCN has ever been filed or not, and / or whether that CCN is cancelled or rejected.

Q: Are these only sent to the party that filed the bill that is being presented?

A: Reported Notices will be sent out upon Conveyance arrival at the border to the carrier that

submitted the cargo document and to the warehouse operator quoted in the sub-loc field of that

cargo document.

Q: If the eHBL is issued by a non-bonded freight forwarder and the marine carrier handles

the in transit movement either to a warehouse or border crossing, who gets the notice?

A: The freight forwarder owner of the eHBL will receive an Arrived Notice for the eHBL and a

Deconsolidation Notice for the House Bill Close. The Warehouse Operator quoted on the House Bill

Sub-location code will receive a copy of HBL Arrived Notice. The Marine Carrier quoted on the

Primary Cargo who delivered the in-transit cargo to its destination will receive an Arrived Notice for

the Primary Cargo and also a Deconsolidation Notice.

Q: What if the marine terminal, airline warehouse operator etc. is not set to receive

electronic notices?

A: “There are 3 paper options available if the warehouse is not set up to receive the Deconsolidation

notice:

Freight forwarder may present a hard copy of the raw data EDI Decon notice. If the freight forwarder

is set up to receive the Deconsolidation notice, they will be able to print the row EDI message and

present it to the warehouse operator in order to retrieve their goods from the warehouse.”

The other two paper options are a Customs’ stamped Close Message printed out from the portal or a

primary manifest with the 8000 numbers written on the back, stamped by Customs. This is a disaster

waiting to happen.

Q: Released / Held / Authorized to deliver will only be sent upon “arrival” of the cargo or

house bill. Does this mean vessel arrival or a successful filing with CBSA?

A: This means arrival of the cargo or HBL at its quoted destination warehouse sub-location for in-

bond movements, or at vessel arrival for import cargo or HBLs seeking frontier release at the border.