customs brokerage, freight forwarding and truck transportation

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Customs Preload Import Risk Assessment: How To Help Assure A Positive Outcome 2018-05-07

Customs agencies around the World have been collecting preload information on import shipments for some time, even predating 9/11.
 
Freight forwarders and carriers provide that information to CBSA in electronic form at the preload stage for marine and air import shipments.
 
They collect shipment level detail and together with other data and specialized tools assess the risk of any particular shipment well before it departs from origin.
 
That detail generally includes: 
  • Shipper name and address
  • Consignee name and address
  • Delivery name and address (if different from the Consignee)
  • Cargo description, packaging type and quantity
  • Gross weight of shipment
In Canada, Canada Border Services Agency (CBSA) is responsible for performing risk assessment on all inbound cargo that is either destined for Canada or transits through Canada on its way to another destination country. The CBSA program that applies in this area is called Advanced Commercial Information (ACI for short). A newer iteration of that program called eManifest allows Customs Officers and others in the intelligence and law enforcement and compliance communities to peer even more deeply into the circumstances of a shipment; CBSA and their peers are provided with additional data elements that have the potential to enhance visibility and follow the actual path of a cargo shipment info Canada. Much if not most of the validation done by the Agency’s computer systems (so terms have to be understood by machines and cross referencing lists has to be easy enough for a computer to recognize quickly).
 
The quality of the data that we transmit to CBSA depends heavily on the information that is provided by both shipper and consignee before the time of lading on or in conjunction with the shipper’s letter of instruction for issuance of the bill of lading or B/L for a shipment; the areas that pose the greatest difficulty for the freight forwarder include:
  • Inaccurate consignee name and address:
As examples incorrect or incomplete civic number, street name, city name or postal code.
Addresses should correspond to the way that the consignee is currently known to CBSA and other Canadian Government departments (for CRA, the way that a company is registered and following the manner in which an address appears in Canada Post’s database is a good idea).
  • Incorrect or missing delivery name and address (if different from the Consignee):
As examples incorrect civic number, street name, city name or postal code or including consignee c/o a third party logistics (3PL) provider’s warehouse.
If s ship-to address is known prior to lading, it can and probably should be included by itself. If the carriage of contract ends at a place that is geographically distant from the consignee, a local ship-to address (adjacent to the place at which the contract is concluded) can and should be reported on the B/L that is the basis for the ACI and or eManifest transmittal.

A non-resident importer (NRI) can and should be indicated as the consignee for a shipment (using their overseas address) if they are registered as an importer in Canada. By default a Canadian ship-to address is mandatory. The ship-to can be a 3PL warehouse, the warehouse of the ultimate consignee or the final sufferance location in Canada from which the goods will be sold, etc.
  • Vague or wordy cargo description, unclear packaging type(s) and or and quantity:
Wordy or vague description is difficult; what might be perfectly understandable to the transport parties but that cannot be understood by a machine or even an outsider unfamiliar with specific trade terms such as a Customs Officer. Clients can follow CBSA’s own guidance on commodity descriptions on the Agency’s own website.
 
If the data and formatting of our preload reporting (the basis for which we receive from the shipper) is correct and our preload ACI or eManifest passes initial risking activity by an automated system, the chances are that the goods will be cleared to load on time and then discharge and be brought to final destination without interruption.
 
If the data and formatting of our data is incorrect, that might result in either of the following: 
  • Request for info (RFI) from a Customs officer
  • Potential ACI/eManifest hold and subsequent do not load (DNL) order from CBSA
  • CBSA hold at the first Canadian port of arrival (FPOA) and container exam (that cost on average $1800.00/ea.)
  • Delays that come together with CBSA’s intervention at any point in the shipment lifecycle 
The shipper’s instructions (including those that relate to the bill of lading and the information that we as forwarders transmit to CBSA through ACI/eManifest) can have consequences on the outcome of a shipment. Canadian buyers should be engaged with their overseas vendors to assure that accurate directions are provided to Milgram’s overseas offices and agents.
 
For any information on ACI and eManifest and how to improve your chances of success with the ACI/eManifest process, please contact Ted Chazin, Milgram’s Compliance and Risk Management consultant.
 

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