Electronic House BL Requirement for Canada
Dear Valued Customer,
Please be advised that as of November 7th, 2016 the new CBSA requirement for a new electronic House B/L (EHBL) has come into effect.
Below you can find a summary of the main elements of this new requirement.
1. What kind of shipments does the eHBL requirement apply to?
The eHBL requirements only apply to shipments that are considered to be “consolidated.” According to CBSA, a shipment is consolidated if it consists of:
A number of separate shipments grouped together by a consolidator or freight forwarder, for which the primary bill of lading shows the shipper and consignee as a freight forwarder or NVOCC or consolidator, OR
A single shipment for which the primary bill of lading shows the shipper and consignee as a freight forwarder or NVOCC or consolidator (also known as a "back to back" shipment)
The eHBL provisions DO NOT APPLY to single shipments where there is no freight forwarder involved and where the primary bill of lading shows the name of the actual shipper and consignee.
2. Under the eHBL provisions, will marine carriers submitting ACI for consolidated shipments have to make any changes to their primary cargo report?
No, marine carriers submitting ACI for consolidated shipments will continue to:
Submit the primary cargo report to CBSA (no new information is required, therefore no change to your current process)
Select “Y” to indicate that the shipment is consolidated (this is the same indicator that is currently used as the supplementary indicator)
Indicate both the Port of Destination Code and Sub Location Code(s) for the shipment (although provision of the sub-location code on the primary cargo report is not mandatory, CBSA cautions that cargo may not be released at the warehouse if the sub-location code is not available).
3. At what point in the ACI process does the eHBL requirement trigger ACI reporting changes?
The changes arising from the eHBL provisions relate to the supplementary data that is transmitted by the freight forwarder (or by the carrier in cases where the carrier is providing this service for the freight forwarder):
Currently, the freight forwarder is required to provide supplementary data for all import, in-bond, in-transit and FROB cargo.
Once eHBL comes into effect, the freight forwarder will be required to provide supplementary data for consolidated FROB only, and advance electronic house bill data for all in-bond, in-transit and import cargo
The way in which these changes are implemented in practical terms will depend on the business relationship between the freight forwarder and the marine carrier, as well as the preferences / transmission capabilities of each individual party.
The marine carrier may have no involvement whatsoever in the transmission of supplementary or electronic house bill data on the freight forwarder’s behalf (in which case, the carrier would only provide CBSA with the primary cargo report as per point 2 above).
The marine carrier may transmit supplementary data for consolidated FROB on behalf of the freight forwarder, while the freight forwarder submits electronic house bills for all other consolidated cargoes (this may require some changes to current reporting processes for marine carriers who were previously submitting supplementary reports for import and in-transit cargo as well).
The marine carrier may do all of the electronic house bill reporting on behalf of the freight forwarder by submitting supplementary reports for consolidated FROB and electronic house bills for all other consolidated cargo. In such a case, the marine carrier would use its own 9000 series carrier code to transmit the data, but would essentially be acting as the freight forwarder in CBSA’s eyes (meaning that the carrier would be liable for the timeliness and accuracy of the information provided). This would require substantial changes to the carrier’s current reporting processes.
4. What are the implementation timelines for the eHBL requirement?
As per Customs Notice 16-17, CBSA has provided the following information regarding the timeframes and manner in which the eHBL requirement will be implemented.
November 7, 2016 to January 11, 2017: This is a transitional period during which CBSA will work with freight forwarders to help bring them into compliance with the new requirements, with no penalties being issued for cases of non-compliance. CBSA has confirmed that if electronic house bills for consolidated cargo are not transmitted during this period, but supplementary data is transmitted, the cargo will move and paper house bills will be accepted at destination.
January 11, 2017 to July 12, 2017: During this period, CBSA may issue non-monetary AMPs to freight forwarders for failing to transmit electronic house bills for consolidated cargo. However, if supplementary data is received in such cases, the cargo will move and paper house bills will be accepted at destination.
As of July 12, 2017: As of this date, CBSA may issue monetary AMPs to freight forwarders for failing to transmit electronic house bills for consolidated cargo. However, if supplementary data is received in such cases, the cargo will move and paper House bills will be accepted at destination.
As indicated above, CBSA will continue to accept ACI supplementaries at least until July 2017 (and possibly beyond), as this is CBSA’s only means of ensuring that they have information against which to perform risk assessments in cases where a freight forwarder fails to comply with the eHBL requirements. Carriers may wish to keep this in mind when deciding whether to continue providing supplementary data for consolidated freight on a temporary basis once the eHBL provisions come into effect on November 7th.
5. Do marine carriers need to sign up for any new CBSA notices as a result of the new eHBL requirements?
CBSA has introduced a suite of new “disposition” notices as part of the eManifest program, which are designed to assist trade chain partners in monitoring the progress of their shipment by, for example, notifying parties on the completeness of the advance information sent to CBSA and on the arrival and status of shipments as they move through the commercial import process. Although it is not mandatory for carriers to receive these notices, they may be useful for tracking the status of a given shipment. Anyone wishing to receive the notices should contact CBSA’s Technical Commercial Client Unit (TCCU) to initiate a testing process (TCCU-USTCC@cbsa-asfc.gc.ca).
Of these new notices, one of the most important is the “deconsolidation notice,” which is the electronic message that CBSA sends to inform clients (freight forwarders, warehouse operators, terminal operators and carriers) that it has authorized the transfer of cargo control from a consolidated shipment to the related individual house bills that were submitted by the freight forwarder. As such, it serves as electronic notification to the warehouse or terminal operator to allow the freight forwarder to take control of the goods within the consolidation. Although receipt of the deconsolidation notice is optional, CBSA strongly encourages all parties to register to do so, as this will enable a smoother transition to the electronic transmission of house bills for freight forwarders and reduce the paper burden on all parties involved in the transportation and cargo control process. For more information on the deconsolidation notice, please see this Customs Notice 16-20.
You can find further information at the below link:
Please do not hesitate to contact your local Customer Service Representative who will be happy to assist.
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