1. This notice replaces Customs Notice 17-22 and provides a provision to the interim process to address a specific scenario for single shipments (back to back) destined to primary warehouses. See paragraphs 6 – 11 for details on this provision. The existing rules for the interim process have remained unchanged and will continue for the duration of the voluntary period as indicated in Customs Notice 17-15.
2. The Canada Border Services Agency (CBSA) has developed an interim process to address current security and program integrity concerns until systems enhancements for electronic house bill requirements and functionality are deployed. These system enhancements are necessary to fully support the eManifest program and to allow freight forwarders to comply with all reporting requirements.
3. As of August 14th, 2017 and for the duration of the interim period outlined in Customs Notice 17-15, the option of allowing back to back shipments using the electronic house bills to release goods from primary sufferance warehouses has been suspended. Freight forwarders must cease transmitting electronic house bills for back to back shipments destined to a primary warehouse.
4. Freight forwarders must implement the following for import or in bond consolidated shipments including back to back shipments:
- a. All electronically transmitted house bills must be destined to a CW warehouse. The release request must quote the lowest level house bill.
- b. Electronic house bills may not be transmitted for back to back shipments clearing from a primary warehouse. Release requests must be on the primary cargo control number and shipments will be released on the primary cargo control number. Pre-arrival / pre-load Advance Commercial Information (ACI) S10 supplementary reports will be required for air and marine back to back shipments.
- c. When electronic house bills are not transmitted, the freight forwarder must present paper house bills to the CBSA post arrival for validation for all house bills. The release request must quote the lowest level paper house bills destined to a CW (secondary) warehouse. Pre-arrival / pre-load ACI S10 supplementary reports will be required for air and marine consolidated house bills.
5. The following are consolidated shipment scenarios which require one or more house bills.
- a. Multi-shipment consolidations - A number of separate shipments grouped together by a consolidator or freight forwarder and shipped to a freight forwarder as one shipment under one bill of lading.
- b. Single shipments (back to back) - Shipments that involve both a freight forwarder and a primary carrier, but consist of only one shipment.
- c. Buyer’s Consolidations – Full container loads that involve multiple shipments grouped together on multiple house bills of lading being delivered to one importer/consignee.
NEW - Provisional Allowance to Interim Process
6. The CBSA has reviewed the interim process published in Customs Notice 17-22 and a decision has been made to include a provisional allowance to the interim process for electronic house bills. This addition to the interim process will allow non-consolidated single house bills to move from one primary warehouse, destined to another primary warehouse, when the house bill is moving under its own bonded freight forwarder code. House bills that are moving under a primary cargo control number (i.e. a 9000 series CCN), must continue to be destined to a CW warehouse for release.
7. The consolidated primary cargo control document must be transmitted by the carrier within the modal timeframes destined to the first point of arrival (for example port of destination is port 809) with an AW type warehouse, sub-location code (subloc) included as the sufferance warehouse. The non-consolidated electronic house bill must also be transmitted by the freight forwarder within the modal timeframes and must be destined to a primary inland warehouse (for example port of destination is port 495) with an AR type warehouse subloc included as the sufferance warehouse. When the primary Cargo Control Number (CCN) is “arrived” by either a conveyance arrival certification message (CACM) or a warehouse arrival certification message (WACM) in port 809, the liability of the goods is transferred to the freight forwarder and the cargo movement to the warehouse in port 495 is controlled by the house bill.
8. The following conditions for proceeding with this process must be adhered to:
- Back to back house bill must be non-consolidated;
- Goods must be moving on the house bill, and therefore the freight forwarder must be bonded;
- House bill cargo control number (e.g. 8000) must be arrived by the primary warehouse with a Warehouse Arrival Certification Message (WACM); and
- Goods can only exit the warehouse once a Release Notification System (RNS) release has been received.
- Freight Forwarders wishing to utilize this allowance must:
- Ensure that the primary cargo and non-consolidated house bill are transmitted electronically to the CBSA within the pre-arrival modal timeframes;
- Ensure that the house bill is non-consolidated;
- Have the agreement from the primary inland warehouse that they will transmit a WACM for the house bill CCN;
- Be approved by the CBSA to use this process flow and specify at which ports of entry and inland locations the goods will be destined to; and
- Submit a listing of all house bill CCN’s destined to primary inland warehouses at the end of each month.
- Warehouse Operators must:
- Agree to transmit a WACM on the house bill cargo control number;
- Not allow goods following this scenario to exit the warehouse until they have received the RNS release quoting the house bill CCN; and
- Request approval from the CBSA to participate.
Participants will contact the Canada Border Services Agency for approval to participate in this process by emailing the eManifest Help Desk and must include “Request to participate in the provisional allowance to the interim process” in the subject line of the email. Participants must include their bonded freight forwarder code and indicate which inland warehouses the goods will be destined to, including the sub-location codes of these warehouses.
Participating freight forwarders will be required to provide a listing of all CCN’s destined to a primary inland warehouse on the last business day of each month for monitoring purposes to the Transporter Compliance Unit. As required under section 7 of the Transportation of Imported Goods Regulations, freight forwarders and warehouse operators must maintain accurate books and records for compliance purposes.
11. Applications for participation will be accepted from the date of publication of this Customs Notice announcing the provisional allowance.
12. Timeframes for the transmission of supplementary reports are the same timeframes for air and marine cargo. For more information please reference: https://www.cbsa-asfc.gc.ca/prog/aci-manif-ipec/req-exig-eng.html#tab4 for marine requirements, and https://www.cbsa-asfc.gc.ca/prog/aci-manif-ipec/req-exig-eng.html#tab1 for air requirements. Supplementary reports may be transmitted by either the primary carrier or the freight forwarder.
13. Freight forwarders should continue to transmit electronic house bills for consolidated shipments destined to a CW warehouse.
14. Pre-arrival supplementary data reports will continue to be required for consolidated freight remaining on board (FROB) shipments in the air and marine modes.
15. The existing exemption for consolidated shipments transiting Canada as described in Customs Notice CN16-23 will remain in effect during the voluntary period.
16. These interim processes will only be in place until a functional systems solution is in place. For more information on the voluntary period, please refer to Customs Notice 17-15 - Changes to the Implementation Timeline for Electronic House Bills.
17. The CBSA urges freight forwarders to register for electronic notices, which includes the Deconsolidation Notice. Clients may refer to Chapter 11 of the ECCRD or contact the TCCU for more information. Clients may contact the TCCU by email at email@example.com or by calling 1-888-957-7224 and selecting Option 1.
18. An electronic house bill (ehouse bill) client support service is available to assist freight forwarders and facilitate their shipments into Canada. Freight forwarders can use this service to ask ehouse bill questions, resolve related operational issues, and learn about freight forwarder requirements.
19. For email support on eManifest policy and processes, contact the eManifest Help Desk at firstname.lastname@example.org.
20. For additional information regarding the pre-arrival and reporting requirements for freight forwarders, please see the revised departmental memoranda, D3-3-1, Freight Forwarder Pre-Arrival and Reporting Requirements.
21. For additional information regarding eManifest requirements clients may visit the CBSA website.
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