CBSA EMANIFEST ANNOUNCEMENT OF POSTPONEMENT
As Trade Tech has anticipated for some time now, the Canada Border Services Agency (CBSA) has announced a postponement of the penalty period for lack of a filing or for an improper eManifest filing. The delay is caused by the CBSA's discovery of substantial issues with major supply chain partners in Canada that must be resolved for the processing of shipments. The CBSA posted CN17-15, which outlines the revised implementation timelines. Until systems are robust and tested, eHBL remains voluntary. The CBSA CN17-15 is posted below for your information.
"A new voluntary period will begin immediately and will be in place for a period of at least one year. During this period, no penalties for non-compliance will be issued regarding pre-arrival submission of house bills. Freight forwarders who are transmitting electronic house bills may receive report cards from the CBSA with respect to data quality within their transmissions."
Trade Tech customers may file with Trade Tech using either filing type and we recommend that importers become familiar with the requirements for eManifest as it will be the sole filing type allowed in the future. We note that eManifest filings may require manual workarounds in some cases.
For questions, please contact your Trade Tech representative or your local Trade Tech office.
Changes to the Implementation Timeline for Electronic House Bills
Customs Notice 17-15
Ottawa, May 23, 2017
1. This notice provides new information regarding the eManifest implementation timeline for freight forwarders to electronically transmit advance house bill data on consolidated freight to the CBSA within the prescribed mode-specific time frames. This notice replaces Customs Notice CN16-28 Updated-Mandatory Date for Electronic House Bills.
2. On May 6, 2015, regulatory amendments supporting the CBSA's eManifest initiative were published in the Canada Gazette, Part II. The publication of these regulatory amendments made eManifest requirements for freight forwarders legally binding, and an implementation timeline began on November 7, 2016.
3. To provide time for the CBSA to fully test and implement enhanced electronic house bill system functionality, the CBSA has determined that the existing timeline for mandatory eManifest house bill requirements should be modified. A new voluntary period will begin immediately and will be in place for a period of at least one year. During this period no penalties for non-compliance will be issued regarding pre- arrival submission of house bills. Freight forwarders who are transmitting electronic house bills may receive report cards from the CBSA with respect to data quality within their transmissions.
4. Once a date has been determined, the CBSA will communicate by means of an amendment to this Customs Notice and provide details on when the 6 month zero rated (non-monetary) penalty period will begin. Following the 6 month zero rated period, monetary penalties may be issued for non-compliance.
5. The requirement to transmit electronic house bill and supplementary data is the liability of the freight forwarder, as defined in the Reporting of Imported Goods Regulations: "freight forwarder" means 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 or carriers who meet this definition may transmit supplementary data or house bill data using their own carrier code. As with many CBSA processes, business to business communication is essential to ensure the appropriate information is transmitted to the CBSA.
6. An interim process, until the systems enhancements are complete will be communicated shortly. Until such time, freight forwarders should either continue to transmit electronic house bills, or revert to the legacy process (submit electronic pre-arrival supplementary data for air and marine shipments (or ensure the related air or marine carrier is transmitting the supplementary data), and present paper house bills post arrival.
7. The CBSA remains committed to supporting clients in their transition to eManifest throughout the regulatory implementation timeline through online resources and dedicated client support activities.
8. 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.
9. For email support on eManifest policy and processes, or to participate in upcoming freight forwarder implementation calls, contact the eManifest Help Desk at email@example.com
10. 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.
11. For additional information regarding eManifest requirements clients may visit the CBSA website.