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Evaluation of eManifest

Final Report

July 2024

Program Evaluation Division, Internal Audit and Program Evaluation Directorate

Table of contents

Overview of the eManifest initiative

The eManifest initiative was implemented to modernize and streamline the Canada Border Services Agency’s (CBSA or "the Agency") commercial process. It expanded on the groundwork set by the Agency’s Advance Commercial Information (ACI) initiative and completed the transition from a traditional, paper-based commercial process to an automated one.[1]

eManifest was delivered through a project that launched in 2006-07 and closed in 2018-19. It involved making program, policy, and legislative changes, in stages over time, to legally mandate Trade Chain Partners (TCP) to submit commercial information to the CBSA, electronically and prior to their arrival in Canada. The project also involved developing Information Technology (IT) system components and functionalities to enable electronic data transmission, warehousing, and retrieval for risk assessing commercial shipments in all modes of transportation.

Prior to eManifest implementation, TCPs (i.e., carriers) were able to submit electronic pre-arrival information in Marine, Air and Rail modes, but not in Highway mode.[2] eManifest implementation filled the gap in the Highway mode and, in 2021, made electronic pre-arrival commercial data submission mandatory for carriers and Freight Forwarders (FF) in all modes. A timeline of events follows. Key definitions can be found in Appendix C.

In 2018-19, the eManifest initiative transitioned from a project to a functional component of the commercial process and is now under the functional authority of the Commercial and Trade Branch (CTB). In its steady state, eManifest is expected to deliver on the following results:

  1. Improved risk assessment (as pre-arrival, electronic commercial data allows the CBSA to identify and target high-risk shipments)
  2. Faster, more efficient frontline processing for commercial trade
  3. Reduced administrative burden on businesses

These expected results align with the eManifest project’s intended benefits (refer to Appendix D for original intended benefit statements).

Summary: eManifest key events timeline

2004 & 2005
ACI Phases I & II: Electronic pre-arrival data mandated for Air and Marine modes for carriers (not FFs)

2006
First eManifest Treasury Board (TB) submission

2015
eManifest milestone: Electronic pre-arrival data mandated for Rail and Highway modes for carriers (not FFs)

2016
Second eManifest TB submission

2019
eManifest Project closure

December 2021
eManifest milestone: Electronic pre-arrival data mandated for FFs in all modes

Development of eManifest IT components, enabling electronic data exchange in highway mode [3]

2011
eManifest Portal available to end-users

2015
Commercial Threat Assessment System (CTAS) available to end-users

2019
Commercial Passage (CPSG) available to front counter (limited functionality)

2023 and ongoing
Milestone: CBSA now receives electronic pre-arrival data from all required parties across all modes

Note: Given the importance of the December 2021 milestone, the evaluation will often present the impacts of eManifest through changes observed pre and post this date, although changes were implemented over time up to that date.

eManifest capabilities and key players

eManifest supports the following capabilities of the commercial process:

Key CBSA stakeholders (eManifest – steady state)

Office of Primary Interest (OPI): CTB

End-users: Intelligence and Enforcement Branch (IEB) and Regions

Information, Science and Technology Branch (ISTB):

Evaluation scope and methods

Evaluation Scope:

Out of scope:

Expected results assessed:

  1. Improved risk assessment
  2. Faster, more efficient frontline processing for commercial trade
  3. Reduced administrative burden on businesses (limited assessment)

Lines of evidence used:

Operational and financial data, headquarters (HQ) consultations, regional questionnaire, operational scenarios, document review, and project performance metrics review. (See Appendix D for more information on the evaluation methodology and its limitations.)

Evaluation coverage:

The evaluation covers the five fiscal years from 2018-19 to 2022-23.

Evaluation considerations and limitations

General considerations:

Limitations and considerations on assessing efficiency:

Data considerations and limitations:

Overall findings

eManifest implementation is aligned with the CBSA and the Government of Canada’s digitalization and modernization efforts, and the shift to electronic data submission was necessary to undertake. While more time will be required to determine eManifest’s true impacts, the following contributions and areas for improvement were identified:

Despite some challenges, eManifest continues to be useful to the Agency as it provides the basis for ongoing development of capabilities and functionalities needed for efficient and effective commercial processing. Two recommendations are presented to fill the existing gaps and improve realization of expected results.

Recommendation 1 and associated findings

There is a fragmented understanding of eManifest and unclear roles and responsibilities for results achievement and performance tracking

Depending on Agency stakeholders’ role and interaction with eManifest, their definition of eManifest varied. This could contribute to a lack of consensus across the Agency on what aspects of eManifest are working well and what areas require improvements.

Additionally, the evaluation found that the roles and responsibilities for eManifest as a functional component of the Commercial Program have not been updated under the Agency's Functional Management Model (FMM), leading to gaps in governance and accountability for results, performance measurement and reporting. The Agency continues to use the key performance indicator (KPI) developed for the eManifest project; steady-state KPIs have not been developed.

A mechanism to monitor and report on eManifest’s ongoing results is required. eManifest KPIs for all modes are needed to determine if risk assessment and targeting efforts using eManifest data are effectively contributing to the Agency’s goals.

Recommendation 1:

In order to ensure consistent understanding of eManifest and its results, the Vice President (VP) of CTB should develop and communicate a performance measurement strategy for eManifest, either by embedding it within the existing Commercial Program Performance Measurement Framework or as a standalone framework. The strategy should include:

Recommendation 2 and associated findings

Functionality gaps within the newly developed eManifest systems exist

The implementation of eManifest addressed risk assessment gaps in the Highway and Rail modes by adding system functionality where it did not previously exist. The CBSA implemented a complex IT architecture, adding functionalities to existing legacy systems and developing new systems.

While newly developed systems were originally intended to allow for risk assessment and targeting in all modes, the end-user risk assessment interface functionality in Air and Marine modes was deferred and is yet to be delivered. As a result, the NTC continues to rely on legacy systems for risk assessment and targeting in Marine and Air modes, using inefficient workaround solutions. Another system limitation due to project scope change is the inability to assess the effectiveness of risk assessment and targeting efforts, therefore not being able to ‘close the loop’ on commercial examination results.[5]

Similar functionality gaps were previously identified within the Agency but were not fully addressed, and there continue to be challenges for end-users of eManifest systems. CTB and ISTB noted that there are future plans to develop additional components and functionalities within newly developed systems; however, there is currently no timeline for this work to be completed.

Recommendation 2:

The VP of CTB, in collaboration with the VPs of IEB and ISTB, should develop and communicate an actionable plan with clear timelines to add end-user functionality to the eManifest systems. Consideration should be given to functionality that:

The plan should consider Agency-wide information system needs, priorities, and alternatives.

Management Response and Action Plan (MRAP)

Recommendation 1: Develop and communicate a performance measurement strategy for eManifest, including a clear definition of eManifest and clearly defined roles and responsibilities.

Management response: The VP of CTB agrees with the recommendation to develop and communicate a performance measurement strategy for eManifest. The related CTB consultations to be led by the eManifest Task Force and scheduled to be completed within 9 months of Canada Assessment and Revenue Management (CARM) Release 3 (R3) with relevant stakeholders, including the regions, ISTB and IEB will lead to: the development and adoption of a clear and detailed definition of eManifest, which will include related roles and responsibilities, as well as the development of an eManifest performance measurement strategy with KPIs. The performance measurement strategy will be developed to align to the development of eManifest performance data and reporting capability, to ensure results against KPIs can be tracked and measured.

This exercise will result in a clear governance structure for eManifest providing oversight and guidance on all aspects of the initiative, with consideration given to integration with CARM governance given schedule and systems interdependencies. These elements will be components of the actionable plan mentioned in recommendation 2.

Table 1: MRAP to Recommendation 1
Management Action Plan Completion Date Lead Support
1. Create/establish an eManifest Taskforce CTB CTB, Regions, IEB, ISTB
2. Develop governance structure for an operational, steady-state eManifest that accounts for interdependencies with CARM, and disseminate governance document outlining Terms of Reference/eManifest roles and responsibilities and obtain concurrence from CBSA Offices of Collateral Interest. CTB CTB, Regions, IEB, ISTB
3. Develop and disseminate a clear definition of eManifest, including a concise definition on eManifest itself and details on key roles and responsibilities and expected results. CTB CTB, Regions, IEB, ISTB
4. Leveraging the current efforts to develop the Agency reporting capability and the need to develop the data, establish a Performance Measurement Strategy including updated KPIs reflective of available data, as well as individual baselines and tools to measure each KPI. Nine months following CARM R3* CTB CTB, Regions, IEB, ISTB, Strategic Policy Branch (SPB), Finance and Corporate Management Branch (FCMB)

*CARM R3 is currently anticipated for October 2024, so action item completion is anticipated for .

Recommendation 2: Develop and communicate an actionable plan with clear timelines to add end-user functionality to the eManifest systems.

Management response:

Table 2: MRAP to Recommendation 2
Management Action Plan Completion Date Lead Support
1. Develop and communicate an actionable plan to add reporting and end-user functionality for the risk assessment and targeting in all modes including Air and Marine. Nine months following CARM R3 CTB CTB, Regions, IEB, ISTB, HRB

*CARM R3 is currently anticipated for October 2024, so action item completion is anticipated for .

Appendices

Appendix A: Detailed findings

Findings Overview

Relevance

  1. Fragmented understanding
    • Finding 1: There is a fragmented understanding of eManifest among Agency stakeholders which could be hindering collaboration and effectiveness.
  2. Roles and responsibilities
    • Finding 2: Roles and responsibilities for eManifest and for its results as a functional component of the Commercial Program are not clear.

Achievement of Results

  1. Improved risk assessment
    • Data availability
      • Finding 3: eManifest increased the availability of electronic pre-arrival commercial data for risk assessment, and put in place data quality controls.
    • IT functionality
      • Finding 4: The eManifest initiative added IT functionalities to enable risk assessment using pre-arrival data in the Highway and Rail modes.
    • IT functionality limitations
      • Finding 5: IT systems developed under the eManifest initiative lack end-user functionalities for risk assessment in Marine and Air modes.
  2. Faster, more efficient commercial processing
    • Finding 6: eManifest contributes to a faster, more efficient frontline commercial process in the Highway mode by reducing referrals to the front counter, and contributing to release recommendations.
  3. Reduced burden on TCPs
    • Finding 7: eManifest resulted in some benefits for TCPs, however additional time is needed for the reduced burden benefit to be fully realized.
  4. Unintended benefits
    • Finding 8: eManifest enables the Agency to recover lost revenue by formalizing the process of cargo tracing to ensure payment of overdue duties and taxes.

Detailed Findings

Relevance

FINDING 1 (fragmented understanding): There is a fragmented understanding of eManifest among Agency stakeholders which could be hindering collaboration and effectiveness.

There are a number of CBSA stakeholders with various roles related to eManifest:

Through multiple stakeholder consultations and document review, the evaluation found discrepancies in stakeholders’ understanding of what constitutes ‘eManifest’, as well as differing perceptions of its relevance, effectiveness, and efficiency. Communication gaps among eManifest stakeholders were also noted. These factors could be hindering the progress of eManifest as an operational and functional component of the commercial process, as stakeholders cannot agree on what is working well and what requires improvement.

Depending on the stakeholder’s role and interaction with eManifest, they can see it as:

Various factors contributed to the fragmented understanding of eManifest in its steady state, including:

FINDING 2 (Roles and responsibilities): Roles and responsibilities for eManifest and for its results as a functional component of the Commercial Program are not clear.

Unclear roles and responsibilities for eManifest may date to its transition from project to steady-state:

When the eManifest project closed in 2018-19, the Agency was initiating an organizational renewal, which would lead to the adoption of the FMM in 2019. Responsibility for eManifest was transitioned shortly before major changes to the CBSA’s organizational structure, meaning that eManifest responsibilities were delegated to CBSA branches that no longer exist today.

The evaluation found no evidence that an updated governance structure for an operational, steady-state eManifest was developed following the adoption of the FMM and the creation of CTB. As such, no single stakeholder within the CBSA is currently ensuring eManifest implementation is maximized to improve the effectiveness and efficiency of the Agency’s commercial process, including tracking and reporting on performance results.

During the eManifest’s project phase, roles and responsibilities were not always clear:

Source: eManifest Post Implementation Review – Lessons Learned (Interis|BDO for the CBSA, May 2018)

Performance metrics do not capture the expected results of steady-state eManifest:

Following project closure, eManifest performance has not been monitored as a functional component of the Commercial Program. Steady-state KPIs have not been developed.

Rather, eManifest performance continues to be assessed against the outcomes and KPIs initially established for the eManifest Project (refer to Appendix C). For instance, existing metrics focus on measuring results achieved in Highway and Rail modes only, while pre-arrival commercial data is used for risk assessment across all modes.

The Agency could leverage certain indicators from its Departmental Results Framework to assess eManifest’s performance, including:

Achievement of expected result 1: Improved risk assessment

FINDING 3 (Data availability): eManifest increased the availability of electronic pre-arrival commercial data for risk assessment, and put in place data quality controls.

Increased data availability:

One of the key achievements of eManifest was the introduction of legislation mandating carriers to submit electronic pre-arrival commercial information in the Highway and Rail modes, and FFs to submit the information in all modes. As a result, the volume of pre-arrival data submitted electronically increased since eManifest's implementation. A breakdown by mode shows that by 2021-22, almost 100% of pre-arrival data was being submitted electronically in all modes:

Table 3: Breakdown by mode of pre-arrival data submitted electronically
Mode 2018-19* 2019-20 2020-21 2021-22** 2022-23
Air 99.6% 99.6% 99.8% 100.0% 100.0%
Marine 76.9% 78.2% 89.9% 99.6% 99.9%
Highway 98.9% 99.2% 99.5% 99.7% 99.8%
Rail 100.0% 100.0% 100.0% 100.0% 100.0%

*eManifest project closure

**Electronic pre-arrival data mandated for carriers and FFs in all modes

Data on the number of pre-arrival submissions from 2018-19 to 2022-23 show an increase of electronic submissions and a decrease in paper submissions each year, resulting in 99.8% of pre-arrival data being submitted electronically through the eManifest service options by 2022-23:

Table 4: Rate of pre-arrival electronic submissions by fiscal year
Fiscal Year Electronic Paper % Electronic
2018-19 17,101,637 258,244 98.5%
2019-20 15,672,114 194,480 98.8%
2020-21 16,384,618 124,456 99.2%
2021-22 19,634,169 62,237 99.7%
2022-23 20,561,693 43,802 99.8%

Data quality controls enabled by the electronic environment:

Through the digitalization of the data submission process and the standardization of requirements for TCPs, eManifest introduced quality control features like automatic field validations, data cleansing (the process of correcting errors and inconsistencies in a dataset to improve data quality), and other IT functions (i.e., automated identity and address resolution).

Additionally, eManifest introduced a legislated pre-arrival electronic reporting requirement, which enabled the CBSA to issue Administrative Monetary Penalties (AMPs) in cases when there are data quality concerns, including when pre-arrival information is submitted that is untrue, inaccurate or incomplete (AMP codes: C382, C387, C381).

In Highway mode, TCPs are only required to submit electronic pre-arrival data one hour prior to the conveyance’s arrival in Canada. The NTC highlighted this as a challenge, as it is impossible for them to analyze all of the data before the conveyance’s arrival in Canada. So, while eManifest increased pre-arrival commercial data availability, it did not in all cases increase the data utility for risk assessment.

FINDING 4 (IT functionality): The eManifest initiative added IT functionalities to enable risk assessment using pre-arrival data in the Highway and Rail modes.

According to the 2016 eManifest TB Submission, the initiative was intended to develop multiple program and information technology components to ensure 100% of commercial goods in all modes could be risk-assessed in advance of their arrival to Canada. In order to accomplish this, the CBSA implemented a complex IT architecture of more than 19 back-end systems, end-user systems, and other IT products over 20 releases since 2008. Functionalities were added to existing (legacy) CBSA systems, and new systems were developed.

Legacy systems leveraged by the eManifest initiative:

New systems developed as part of the eManifest initiative:

CTAS and CPSG are two of the new systems developed as part of eManifest, and both are now used by the NTC for pre-arrival risk assessment and targeting in Highway and Rail modes, to a limited extent. Prior to their development, risk assessment and targeting using pre-arrival electronic data in Highway and Rail modes was not being conducted by the NTC.

FINDING 5 (IT functionality limitations): IT systems developed under the eManifest initiative lack end-user functionalities for risk assessment in Marine and Air modes.

The eManifest project was originally intended to enable pre-arrival commercial risk assessment and targeting in all modes. However, end-user interface functionality in the Air and Marine modes was deferred for completion and is yet to be delivered. Due to this deferral, the NTC conducts its pre-arrival commercial risk assessment in Air and Marine modes using TITAN, a legacy system. Though CTB and ISTB stakeholders noted plans to develop these functionalities in CTAS and CPSG (eManifest systems), a specific timeline for their completion has not been established. While TITAN will continue to be supported until new functionalities are fully implemented, NTC stakeholders raised concerns regarding TITAN’s reliability, which are further discussed in the next page.[6]

The table below presents the functionalities across the pre-arrival data risk assessment continuum, summarizing all current capabilities made available through the newly developed eManifest IT components. As demonstrated, eManifest succeeded in acquiring, storing, and applying automated risk assessment to pre-arrival data in all modes. However, eManifest supports the NTC’s risk assessment capacity in the Highway and Rail modes only. This capacity is currently being piloted in three Ports of Entry (POE).[7] Moreover, functionalities related to communicating referrals to the front-line and closing the loop on exam results are exclusively available for the Highway mode. The NTC also uses the internally developed Customers Referral Inspection Manager (CRIM) system, which relies on eManifest data stored within the Electronic Data Warehouse. Additional details on functionality are provided in Appendix C.

Table 5: Functionalities across the pre-arrival data risk assessment continuum
  Pre-arrival data acquisition Data Warehousing (storage) Automated Risk Functionality (creation of lookouts, etc.) NTC risk assessment of pre-arrival data User review and decisions (e.g., referrals communicated to POE) Reporting capabilities (e.g., closing the loop)
Air Functionality available Functionality available Functionality available End-user functionality not available in new systems, Agency relies on legacy option and workarounds (TITAN) End-user functionality not available; workarounds are applied Functionality not available
Marine
Highway Functionality available in new systems but still being piloted Functionality available in new systems Functionality available in new systems but still being piloted
Rail Functionality partially available in new systems Functionality not available

Inefficient risk assessment resulting from limited functionalities

In the absence of CTAS and CPSG end-user functionalities, TITAN continues to be used by the NTC to risk assess for Marine and Air modes. As it is a legacy system, TITAN was not designed to efficiently process eManifest data in the format received. Therefore, the NTC has implemented workaround solutions to conduct risk assessment and targeting activities, but noted that these workarounds are neither sustainable nor efficient. Examples of inefficiencies stakeholders provided include:

Additionally, the NTC indicated that risk assessment in the Highway mode using CTAS and CPSG functionalities are being piloted in three POEs, with some emerging challenges.[8]

Inability to assess the effectiveness of risk assessment

Reporting functionality is limited across all systems, preventing the CBSA from ‘closing the loop’ on Air, Marine and Rail exam results (i.e., to indicate whether NTC referrals for examination resulted in seizures or not). This limits the Agency’s ability to determine the effectiveness of current risk assessment and targeting efforts within the Commercial Program as a whole, including eManifest as a component of the process.

De-scoping and deferring elements without sufficient consultation

A post-implementation review of the eManifest project highlighted a lack of adequate stakeholder engagement in decisions related to the de-scoping of key capabilities from newly developed systems:

“The project was re-structured in 2014, with the Programs Branch VP identified as sponsor. This led to more clarity for decision making, however, key stakeholders in Operations Branch feel they were not adequately consulted on key decisions, e.g., to de-scope the project and defer key risk assessment functionality.

Source: eManifest Post Implementation Review – Lessons Learned (Interis|BDO for the CBSA, May 2018)

Due to deferral decisions, when the eManifest project closed in 2018-19, it delivered new systems that did not include functionality for risk assessment in Marine and Air modes.

Project funding and key decisions about scope up to project closure:

2006-07: Preliminary Project Approval received from TB for $414.8M

2007-08: Effective Project Approval (EPA) received from TB for $415.1M

2015-16: Re-baselining, de-scoping of two initial capabilities and extension of project completion to September 2017

2017-18: Frozen allotment of $72.1M (ongoing funds) released by TB until the end of the 2020-21

2018-19: eManifest project closure and release of funding allotment by TB for an additional 3-year period (until end of 2023-24)

Similar functionality gaps were previously identified within the Agency. For instance, in 2022 a list of needed eManifest deliverables was produced in response to identified gaps; however, end-user functionality gaps have yet to be fully addressed.

Stakeholder perceptions collected for this evaluation and the CTB’s substantive funding assessment highlighted the need to continue to develop functionality for risk assessment in the Air and Marine modes.

Spotlight: Positive initial risk assessment results in Highway mode

As previously mentioned, the implementation of eManifest addressed a significant gap in data acquisition and risk assessment capabilities for the Highway and Rail modes. While the development of CTAS, the system designed for NTC data risk assessment, is still underway across all modes, it is most advanced and functional for Highway mode capabilities.

The evaluation analyzed NTC data for the Highway mode over the past four years to identify any trends. However, the following factors limited the evaluation's ability to draw conclusions:

The NTC shared some business requirements that are not currently being met by CTAS in the Highway mode, for which inefficient workarounds are applied, including:

For more information see Appendix C.

Rail Targeting is a new activity under the NTC that is currently being piloted on a small scale before implementation, and there is not enough data within the evaluation’s scope to analyze the impact of eManifest implementation in this mode.

The data from 2019-20 to 2022-23 shows that the resultant rate has improved over time in the Highway mode. However, given the limitations to data analysis mentioned on the previous page, it is too early to conclude this increase is due to the increased availability of electronic pre-arrival data.

The NTC's ability to conduct risk assessment and targeting in the Highway mode since the implementation of eManifest is a benefit for the Agency. However, due to previously highlighted factors, further time is required to fully evaluate the scale of this success.

Moreover, it will be important to compare NTC results from different modes to understand how the availability of IT functionality in newly-developed systems affects the Agency's enforcement capabilities.

The NTC’s resultant rate in the Highway mode, compared to volumes of electronic pre-arrival data over time.[9]

Figure 1: NTC’s Resultant Rate, Compared to Volumes of Electronic Pre-arrival Data Over Time

Figure 01
Image description

Achievement of expected result 2: Faster, more efficient commercial processing

FINDING 6: eManifest contributes to a faster, more efficient frontline commercial process in the Highway mode by reducing referrals to the front counter, and contributing to release recommendations.

Fewer referrals to front counter in Highway mode

Prior to the eManifest initiative: Commercial cargo arriving at the border underwent processing at the Primary Inspection Line (PIL) with a portion of shipments redirected to the front counter to complete their primary processing. This was typically due to certain POEs being limited to scan only five Pre-Arrival Review System (PARS) codes at the PIL, resulting in referrals made to the front counter once that limit was reached.

Following the implementation of eManifest: Front-line staff process the majority of commercial shipments directly at the PIL, with an average 9% of shipments referred to the front counter. The table below shows a decrease over time of Highway conveyances referred from the PIL to the front counter. This results in gained process efficiency for the Agency as fewer trucks need to wait in line for processing at the front counter.

Table 6: Percentage of total Highway conveyances referred to the front counter from the PIL* by fiscal year
Fiscal year Percentage of total Highway conveyances referred to the front counter from the PIL*
2018-19 13%
2019-20 10%
2020-21 8%
2021-22 7%
2022-23 8%

* Counts for service options SO976

Regional respondents generally felt eManifest implementation contributed to process efficiencies. Many respondents highlighted its role in streamlining cargo clearance, reducing border wait times, and enhancing customs procedure management via better tracking.

However, a few respondents also highlighted some challenges to fully realizing the intended efficiencies. For example, regional respondents indicated eManifest resulted in increased TCP data entry errors, requiring more time from the front-line to manually fix them. They also felt that continued reliance on the legacy ACROSS system is inefficient.

Contributing to release recommendations

Between 2018-19 and 2022-23, when an importer submitted a release request electronically at least one hour before arrival at the POE, a release recommendation was available upon arrival in 99.4% of cases. This is another way in which eManifest has streamlined commercial processing in the Highway mode. eManifest provides electronic pre-arrival data that can be analyzed and used to make release recommendations, before a shipment arrives in Canada.[10]

The evaluation looked at four scenarios to assess the potential impact of eManifest on the time and number of steps needed to process commercial goods in the highway mode. The scenarios presented in the table below estimate the total time and number of steps required to process commercial goods with eManifest and prior to eManifest implementation (the counterfactual). The estimates in each scenario are based on the real experiences of Southern Ontario Region’s (SOR) frontline staff who worked on commercial processing before and after eManifest implementation.[11]

As illustrated in the table below, in the three scenarios in which a recommended release is on file when the conveyances arrive at the border, eManifest facilitates the release of goods into Canada by reducing the number of steps and time needed for processing. In the fourth scenario, in which a recommended release was not on file, eManifest had no impact on the number of steps or time needed for processing.

Table 7: Time savings post-eManifest by Highway mode commercial shipment scenario
Highway mode commercial shipment scenarios Pre-eManifest (Counterfactual) Post eManifest Time savings post-eManifest
# of steps *Time # of steps *Time
1. A recommended release is on file for nine non-consolidated shipments 18 11 min 3 1 min 10.15 min
2. Six shipments are submitted within the same cargo, five of which have a recommended release on file and one which does not 16 20 min 2 2 min 17.45 min
3. A consolidated cargo in which one shipment is released at the point of arrival (recommended release was on file) and another is released later at an inland destination 6 173.30 min 2 1 min 172.30 min
(2.9 hours)
4. A shipment arrives in Canada without a recommended release on file and is referred to primary examination (front counter) 3 44 min 3 44 min None

*Times were provided by SOR’s frontline staff based on operational experience and vetted by the Transporter and Cargo Control Programs Unit, CTB.

Achievement of expected result 3: Reduced administrative burden on TCPs

FINDING 7: eManifest resulted in some benefits for TCPs, however additional time is needed for the reduced burden benefit to be fully realized.

Data harmonization with international requirements

In 2019, the eManifest initiative successfully harmonized the CBSA’s data requirements with World Customs Organization (WCO) and the United States (US) Customs and Border Protection requirements. Data harmonization reduces the administrative burden for TCPs by allowing them to utilize electronic processes and systems already implemented to comply with US requirements.

The benefit of reduced administrative burden on businesses was driven by the value proposition to “Harmonize data reporting requirements and minimize costs for external clients who have invested in systems that comply with the US ACE project.” By eManifest project closure (Benefit Realization Report, Gate 7, 2019) this value was deemed fully realized.

Counterfactual: Had data harmonization not happened, TCPs would likely need to provide one set of data for commercial shipments to the US and a second set of data for shipments to Canada.

Increased communication with TCPs

Communication has increased due to eManifest functionality which enables the Agency to proactively provide electronic updates and feedback to TCPs at various stages of the commercial process, in all modes.

By increasing proactive communication with TCPs, eManifest implementation reduces the number of times TCPs must reach out to the CBSA to request status updates, thus further reducing the time required for TCPs to track their shipments through the CBSA’s commercial process.

Analysis on the number of electronic notices issued to TCPs over time shows that they are increasingly receiving proactive notices from the CBSA: [12]

Figure 2: Number of EDI Applications and Notices Over Time

Figure 02
Image description

Impacts on TCPs during the transition period:

The shift from a paper-based commercial process to an electronic one, and the introduction of new mandatory pre-arrival commercial reporting requirements, created an initial administrative demand on TCPs adapting to the new process. In 2021, when new requirements came into effect, the number of calls by TCPs to the CBSA’s centralized 24 hour helpline increased by 200% (see table).[13]

During this transition period, the CBSA implemented temporary measures to lessen the burden on TCPs, including increasing outreach and education efforts. Post-2021, the number of calls to the CBSA helpline decreased, suggesting that TCPs required less assistance after the initial transition.

However, it is important to note that there is not enough helpline data available at this time to show a continued trend, and data does not include calls by TCPs directly to the Regions.

Table 8: Number of helpline tickets by Calendar Year
Calendar Year Number of helpline tickets (TCPs contacting CBSA’s support)
2020* 6,313
2021 18,960
2022 13,708
2023** 11,420

*Estimated based on 4,735 calls received from April to December 2020

**Projected based on 5,710 calls received from January to July 2023

Limitation: The evaluation did not survey TCPs to collect their perspectives regarding the impact of eManifest implementation on their processes.

Achievement of expected result 4: Unintended benefits

FINDING 8: eManifest enables the Agency to recover lost revenue by formalizing the process of cargo tracing to ensure payment of overdue duties and taxes.

Cargo tracing” refers to the process of tracking and verifying the movement of shipments to ensure that all goods entering the country are accounted for. Cargo tracing allows for the identification of duties and taxes owed on goods being released.

Lost revenue” refers to unpaid duties and taxes on goods that have not been traced.

An unintended benefit of eManifest implementation is a reduction in lost revenue on commercial shipments due to incomplete tracing. Prior to eManifest implementation, cargo was verified at its port of entry through reviewing samples of the paper cargo control documents received. Samples represented: 10% of large airport shipments, 50% of small airport shipments, and 20% for other cargo.

The introduction of eManifest transformed the process, as the availability of electronic pre-arrival commercial data allowed for:

From August 2020 to December 2023, the CBSA traced an average of 2,122 monthly outstanding overdue releases to ensure payments were made. Stakeholders stated that eManifest played a critical role in recovering lost revenue from these accounts.

Note: The evaluation did not have the data to quantify the value of the revenue recovered during this time period.

CONCLUSION – eManifest continues to be relevant and useful to the Agency

What did the evaluation find?

The findings of this evaluation highlight the importance of the eManifest initiative to the CBSA’s commercial process. Through the eManifest initiative, the Agency conducted legislative and process changes required to digitalize the commercial process. The initiative also resulted in the development of a complex IT architecture, including upgrades to back-end systems, development of new end-user systems, and production of other IT products which have enabled risk assessment using electronic pre-arrival commercial data. These changes are showing some positive initial results.

eManifest implementation filled a risk assessment functionality gap in the Highway mode; however, additional efforts are necessary to continue developing functionality for Air and Marine modes. Similar gaps were identified previously but have not been fully addressed. While the intention to implement these functionalities as part of eManifest stabilisation was raised during the evaluation, there is currently no set date for these upgrades. Without a commitment to timelines in which to address these gaps, there is a risk the upgrades continue to be delayed.

Continuing to rely on aging, legacy systems like ACROSS and TITAN, is no longer a sustainable option for the Agency due to their inefficiency when processing high volumes of electronic commercial information. At present, there are no other active initiatives aimed at addressing these gaps. Therefore, eManifest stands as the path forward to enhance the Agency's risk assessment capacity in all modes and to advance Canadian security priorities.

What needs to change?

The findings support the need for continued strategic investment in eManifest to address existing IT functionality gaps.

Performance measurement and clear accountabilities are also needed to ensure positive results in all modes.

Appendix B: Endnotes

  1. The eManifest initiative continued from the ACI and is sometimes referred to by some Agency stakeholders as ACI Phase III. The eManifest initiative leveraged the work completed by the ACI initiative and formalized the reporting requirement in all modes.
  2. Prior to eManifest, Highway processing was in paper format, but rail was done through an old standard of EDI. eManifest harmonized and standardized the data elements among modes.
  3. Internal government document.
  4. Costing and Analytical Model (CAM) tool used by FCMB to code expenditures to programs. In 2022-23, FCMB added dedicated eManifest CAM functions to determine if retaining these functions would not result in significant discrepancies between expected and actual spending. Since this data is limited and experimental, and the evaluation opted to not use it for analysis. Due to the limited and experimental nature of this data, the evaluation chose not to use it for analysis.
  5. 'Closing the loop' means being able to indicate the exam results - resultant or non-resultant.
  6. While TITAN will continue to be supported, NTC stakeholders shared their continued concern with IT functionality to support risk assessment, including:
    • System capacity to view House Bills in TITAN beyond 2012.
    • No updates to the system risk indicators in TITAN (the NTC ceased updates to risk indicators while working on the eManifest project).
    • User review and decision functionality, which is only partially available in new systems for Rail.
    • User review and decisions for highway, which is available but only currently being piloted to 3 POEs.
    • Limited reporting capabilities.
  7. Even though user review and decision functionality is partially available in new eManifest systems for the Rail mode, this has not yet been operationalized. A small scale Rail pilot began on . Users are able to view ACI and make referral decisions through CTAS, but communicating the decisions for referral or negation to CPSG and closing the loop cannot be made.
  8. For example, according to the NTC, CTAS in the Highway mode lacks the ability for coding specific risk indicators and the ability to complete comprehensive reporting.
  9. Commercial volumes in this analysis refer to the total electronic eManifest service options data.
  10. Not all releases are submitted prior to arrival. Stakeholders (CTB and NTC) indicated that approximately between 20% to 50% of release requests are submitted before arrival depending on the mode. Release requests are submitted by importers and are not mandated pre-arrival by law like reporting requirements (submitted by carriers and FFs).
  11. Scenarios show situations in the Highway in SOR only. Therefore, they do not represent eManifest-related commercial processing in all scenarios, locations, modes, or regions. For example, if there is a keying error on any submission, it will hold up the release of the cargo. As a result, the time for some scenarios could vary from several minutes to hours, to days. This depends on knowledge of the carrier and type of access on third party portal. Often times, carriers submit new ACI or cargo document causing the originals to end up on a Primary worklist or overdue cargo list, causing additional resources to trace it. This can involve multiple Border Services Officers (BSO) and did not occur pre-eManifest.
  12. Electronic notices sent to TCPs now include: Arrive Notices; Authorized To Deliver Notices; CBSA-Hold Notice; Completeness Notices; Deconsolidation Notices; Document Not on File Notices; Release Notices; and Reported Notices.
  13. This data may include helpline tickets for other applications like the Single Window Initiative (SWI) and are not exclusively about eManifest-related issues.

Appendix C: Supplementary eManifest Information

Key definitions and information:

Carriers were mandated to provide ACI to the CBSA as follows:

Table 9: Carriers’ Advanced Commercial Information
Mode Marine Air Highway Rail
Date mandated April 2004 December 2005 April/May 2015
Timeframes for submitting advance information to the CBSA 24 to 96 hours prior to arrival or loading depending on type and origin of goods 4 hours prior to arrival if the flight is less than 4 hours long 1 hour prior to arrival 2 hours prior to arrival

Freight Forwarder: A person who, on behalf of one or more owners, importers, shippers or consignees of goods, causes specified goods to be transported by one or more carriers. Freight Forwarders submit house bills.

FFs were mandated to provide ACI to the CBSA as follows:

Table 10: Freight Forwarders’ Advanced Commercial Information
Mode Marine Air Highway Rail
Date mandated December 2021
Requirement 24 hours prior to loading or arrival depending on type and origin of goods 4 hours prior to arrival or at time of departure if the flight is less than 4 hours long 1 hour prior to arrival 2 hours prior to arrival
Table 11: Delivered, partially delivered, and future enhancements of eManifest systems functionalities by mode
Mode/ Capability Pre-arrival data acquisition Data warehousing Automated Risk Functionality Risk assessment at the NTC User review and decisions (including referrals) Reporting capabilities Intended future releases
Highway Functionality available in all modes. Carriers, FFs, and Importers submit pre-arrival and release data through EDI and the Portal.

Most of data acquisition (e.g., validation) is done in ACROSS and is not part of eManifest scope.
Functionality available. Storage in the Enterprise Data Warehouse (EDW) which includes data analytics capabilities leveraged by the NTC for workarounds (e.g., CRIM).

EDW is currently populated by data from eManifest operational data sources CDEM, ARD and Master Data Management (MDM), ACROSS and TITAN
are not eManifest applications.
Data cleansing and standardization, creation of lookouts, creation of risk rules, eliminate low risk (ELR), and the maintenance of risk metadata are available for all four modes. Functionality available through CTAS (currently being piloted in three POEs). Functionality available through CTAS and CPSG. Functionality to close the loop by adding exam results (resultant/ non-resultant) is available through CPSG. The Release (R2154) will include CTAS, RAPM, and CPSG enhancements for the Highway mode. National rollout of referral and exam pilot expected after R2154.
The Release R2154 will also introduce a Commercial Data Acquisition Digitalization (CDAD) functionality of two new suites of eManifest Notices for all modes.
Functionality in scope for upcoming release CX-02 includes:
  • re-targeting/re-lookouting
  • activate hold/disassemble rules
  • paper capture for CPSG,
  • modify secondary referral
  • add Notes
  • Secondary (SEC) BSO work split shipments.
Air Functionality not available through CTAS; NTC still uses TITAN (legacy system). Functionality not available through CTAS or CPSG;
NTC workarounds implemented.
Functionality not available through CTAS or CPSG, but potential enhancements identified for the future – functions such as: record result, view trip, data analytics results, etc.
Marine Functionality not available through CTAS; NTC still uses TITAN. Functionality not available through CTAS or CPSG;
NTC workarounds implemented.
Functionality not available through CTAS or CPSG, but potential enhancements identified for the future – functions such as: record result, view trip, data analytics results, etc.
Rail Functionality available through CTAS Functionality available through CTAS and CPSG.
No decisions available in rail currently.
Functionality not available through CTAS or CPSG, but potential enhancements identified for the future – functions such as: record result, view trip, data analytics results, etc.

The NTC’s Highway Targeting Unit’s perspective shared with the evaluation on current CTAS limitations in the Highway mode

Inability to adequately conduct searches using the available parameters: Search criteria is limited and often times out, preventing Targeting Officers (TO) from being able to identify shipments of risk based on search preferences and combination of data elements. This prevents TOs from being able to perform adequate analysis of incoming shipments. TOs have a minimum of 1 hour to conduct assessment of commercial highway cargo prior to its arrival, and any delays in searching data impede our abilities to perform comprehensive reviews pre-arrival.

“To mitigate this, the NTC relies heavily on automated products produced by our Targeting Data Analytics (TDA) team to provide us with a “Highway Summary,” an Excel-based document populated every 15 minutes that provides eManifest ACI and release information relating to every un-arrived commercial highway shipment submitted to the CBSA with an Estimated Date and Time of Arrival (EDTA) of -24 / + 5 hours to current time. This Excel document can be filtered and sorted based on specific data points, risk indicators and TO preference to identify shipments of risk for assessment and referral.”

Reporting features: Are very basic and lack the necessary information to complete reporting suites for unit performance and statistics. Supervisor functions are also limited to run reports for TO performance including performance management agreement reviews. We have been told on multiple occasions that NTC had been consulted in the past regarding reporting requirements and CTAS supervisor functions were built to accommodate those previous requests and were “built as intended.” While this is true, our needs for reporting have changed significantly from the time that we were initially consulted and our requests for enhanced reporting features continue to be met with resistance. Requirements for reporting suites to accurately reflect unit performance and efficacy should include the following (based on current manual reporting procedures):

Inability to refer on Integrated Import Declaration (IID): CTAS referral functionality will only allow referrals on the Cargo Control Number (CCN) or Conveyance Reference Number (CRN) entities.

Distribution (workload management) tool does not meet business needs/requirements:

eManifest / IT support: Although we were advised that support is 24/7, support for technical issues or outages is not always immediate. Additionally, changes/enhancements may be requested but development and implementation require coding, testing and production releases which take considerable time. If an issue is identified, targeting operations requires timely resolution for efficiency within the unit. As commercial risk evolves, high risk indicators change and we require a way to adapt and refine coded risk indicators to identify high risk shipments in real time. From our understanding, CTAS will not be able to do this.

Benefit Realization Plan KPIs

The Benefit Realization Plan (BRP) lists the following KPIs for the eManifest initiative:

KPIs for which the Agency continues to report on:

KPIs deemed “met” - reporting ceased:

Appendix D: Evaluation Methodology and Limitations

Lines of evidence, data, and limitations

Lines of evidence (methods)

The evaluation used multiple lines of evidence, including:

Limitations

The intended results of eManifest assessed by the evaluation and the BRP’s benefits

The BRP for the eManifest initiative identified three intended benefits of eManifest at project closure (2018-19). Rather than develop a logic model (which is typically done for evaluating programs), the evaluation modified the original benefit statements to align with eManifest’s current role as a functional component of the Commercial Program. The alignment between the evaluation’s benefit statements and those included in the eManifest BRP is as follows:

Table 12: eManifest BRP
Evaluation results wording Faster, more efficient frontline processing for commercial trade Improved risk assessment Reduced administrative burden on businesses
Original benefit wording at project closure (BRP) Integrates border services that further national security priorities, while facilitating the free flow of low –risk travellers and goods. Provides access for the CBSA to historical patterns and supply chain trends. This information improves the overall effectiveness of the risk assessment program and addresses border health, safety and national security threats. eManifest is consistent with the direction other countries are taking to use compatible electronic processes based on pre-arrival electronic commercial information. The data required under eManifest is harmonized to the greatest extent possible with the WCO and the United States Customs and Border Protection (US CBP) Automated Commercial Environment (ACE) program (equivalent of eManifest) to reduce the administrative burden on businesses.

Appendix E: Acronyms

ACE
Automated Commercial Environment
ACI
Advance Commercial Information
ACROSS
Accelerated Commercial Release Operations Support System
AMPs
Administrative Monetary Penalties
ARD
Automated Risk Determination
BRP
Benefit Realization Plan
BSO
Border Services Officer
CAM
Costing and Analytical Model
CBSA
Canada Border Services Agency
CCN
Cargo Control Number
CDEM
Commercial Document Entity Management
CECP
Customs Electronic Commerce Platform
CPD
Commercial Program Directorate
CPSG
Commercial Passage
CRD
Commercial Risk Development
CRIM
Customs Referral Inspection Manager
CRN
Conveyance Reference Number
CTAS
Commercial Threat Assessment System
CTB
Commercial and Trade Branch
EDI
Electronic Data Interchange
EDTA
Estimated Date and Time of Arrival
eHB
Electronic House Bill
EPA
Effective Project Approval
ExCC
External Client Communications
FCMB
Financial and Corporate Management Branch
FF
Freight Forwarder
FPOA
First Port of Arrival
HQ
Headquarters
IID
Integrated Import Declaration
ISTB
Information, Science and Technology Branch
KPI
Key Performance Indicator
LTL
Less than Load
NTC
National Targeting Centre
OPI
Office of Primary Interest
PIL
Primary Inspection Line
POE
Port of Entry
QDV
Query and Data Viewing Utility
RAPM
Risk Assessment Program Maintenance
RCNP
Residual Compliance Notification Process
RDC
Rogue Data Corporation
SOR
Southern Ontario Region
SWI
Single Window Initiative
TB
Treasury Board
TDA
Targeting Data Analytics
TCI
Targeting Commercial Intelligence
TCP
Trade Chain Partner
TITAN
Tactical Information Targeting Analysis and Notification System
TO
Targeting officer
TPA
Trading Partner Administrator
TPPD
Transformation, Planning and Projects Directorate
US CBP
U.S. Customs and Border Protection
WCO
World Customs Organization

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