Guide: Goods and Conveyance Reporting in South Africa

A companion guide in support of increased compliance in the reporting of goods and conveyances (RCG) to Customs, South Africa.

Necessary information for – Air, Sea and Road carriers, vessel’s agents, NVOCCs, freight forwarders, Air and Sea terminal operators, container depot operators, transit shed operators and de-grouping depots. Also, all private software service providers to the trade.

The guide offers easy navigation through –

  • registration and electronic trading with SARS Customs
  • the various electronic messages mandated by law, covering import and export movements, across all modes of permissible international transportation
  • message types for each transaction type
  • scenarios to facilitate easier understanding across operators in the supply chain on how the various electronic reports are sequenced, ensuring that Customs formulates a comprehensive end-2-end view of a international trade transaction
  • reference webpages, official notifications, Customs rules and other pertinent information concerning cargo reporting.

All information is hyperlinked to SARS documentation, found on the official SARS website

You may download the Guide below (File size: 3MB)


Mozambique – Single Road Cargo Manifest Phase II

Mozambique flagThe Maputo Corridor Logistics Initiative (MCLI) recently published a communication informing it’s stakeholders about the Single Road Cargo Manifest as received from the Mozambican Revenue Authority (MRA).

The MRA has informed MCLI that the 2nd phase of the Single Road Cargo Manifest process will come into effect from the 16th of June 2017, when all international road carriers transporting goods to Mozambique through the Ressano Garcia border post will be required to submit the Road Cargo Manifest on the Single Electronic Window platform in compliance with national and international legislation. MRA Service Order Nr 17/AT/DGA/2017, in both Portuguese and English, is attached for your consideration.

For information and full compliance by all members of staff of this service, both (National and Foreign) International Cargo Carriers, Clearing Agents, Business Community, Intertek and other relevant stakeholders, within the framework of the ongoing measures with a view to adequate procedures related to the submission of the road cargo manifest, for goods imported through the Ressano Garcia Border Post, in strict compliance to both the national and international legislations, it is hereby announced that, the pilot process for transfer of competencies in preparation and submission of the road cargo manifest to Customs from the importer represented by his respective Clearing Agent to the Carrier is in operation since December 2016.

Indeed, the massification process will take place from 15th of April 2017 to 15th of June 2017, a period during which all international carriers (national and foreign) who use the Ressano Garcia Border, are by this means notified to register themselves for the aforementioned purposes following the procedures attached herewith to the present Service Order.

As of 16th of June 2017, the submission of the road cargo manifest into the Single Electronic Window (SEW) for the import regime, at Ressano Garcia Border, shall be compulsory and must be done by the carrier himself.

International road carriers must therefore register for a NUIT number with the Mozambican Revenue Authority between the 15th of April and the 15th of June 2017 and the necessary application form is included. Road carriers are urged to do so as soon as possible to enable the continued smooth flow of goods through the border post.

Specific details can be found here! 

Source: MCLI

SA – Hub for computerised Regional Integration?

AfricaFrom time to time it is nice to reflect on a good news story within the local customs and logistics industry. Freight & Trade Weekly’s (2015.11.06, page 4) article – “SA will be base for development of single customs platform” provides such a basis for reflection. The article reports on the recent merger of freight industry IT service providers Compu-Clearing and Core Freight and their plans to establish a robust and agile IT solution for trade on the African sub-continent.

In recent years local software development companies have facilitated most of the IT changes emerging from the Customs Modernisation Programme. Service Providers also known as computer bureaus have been in existence as far back as the early 1980’s when Customs introduced its first automated system ‘CAPE’. They have followed and influenced Customs developments that have resulted in the modern computerised and electronic communication platforms we have today. For those who do not know there are today at least 20 such service providers bringing a variety of software solutions to the market. Several of these provide a whole lot more than just customs software, offering solutions for warehousing, logistics and more. As the FTW article suggests, ongoing demands by trade customers and the ever-evolving technology space means that these software solutions will offer even greater customization, functionality, integration and ease of use for customers.

What is also clear is that these companies are no longer pure software development houses. While compliance with Customs law applies to specific parties required to registered and/or licensed for Customs purposes, the terrain on which the software company plays has become vital to enable these licensees or registrants the ‘ability to comply’ within the modern digital environment. This means that Service Providers need to have more than just IT skills, most importantly a better understanding of the laws affecting their customers – the importers, exporters, Customs brokers, freight forwarders, warehouse operators, etc.

Under the new Customs Control Act, for instance, the sheer level of compliance – subject to punitive measures in the fullness of time – will compel Service Providers to have a keen understanding of both the ‘letter of the law’ as well as the ability to translate this into user-friendly solutions that will provide comfort to their customers. Comfort to the extent that Customs registrants and licensees will have confidence that their preferred software solutions not only provide the tools for trading, but also the means for compliance of the law. Then, there is also the matter of scalability of these solutions to keep pace with ongoing local, regional and global supply chain demands.

The recent Customs Modernisation Programme realised significant technological advances with associated benefits for both SARS and trade alike. For the customs and shipping industry quantification of these benefits probably lies more in ‘improved convenience’ and ‘speed’ of the customer’s interaction with SARS than cost-savings itself. My next installment on this subject will consider the question of cross-border trade and how modern customs systems can influence and lead to increased regional trade.

EU fighting Customs Fraud – JRC research leads to new legislation

ConTraffic HomepageA new regulation adopted by the European Parliament and the Council will allow customs to access information to track the origins and routes of cargo containers arriving in the EU to support the fight against customs fraud both at EU and national level. The Joint Research Centre (JRC) has been instrumental in the conception and adoption of this legislation as it provided the scientific evidence on the importance of analysing the electronic records on cargo container traffic.

The EU customs authorities have been long aware that information on the logistics and actual routes of cargo containers arriving in Europe is valuable for the fight against customs fraud. However, they had very limited ways to obtain such information and no means to systematically analyse cargo container traffic both for fraud investigations as well as for risk analysis. On the other hand, the ocean carriers that transport the cargo containers, as well as their partners and clients, have easy on-line access to the so-called Container Status Messages (CSM): electronic records which describe the logistics and the routes followed by cargo containers.

jrc-cargo-container-routes-world-mapIn collaboration with the European Anti-Fraud Office (OLAF), the JRC has worked extensively on how to exploit CSM data for customs anti-fraud purposes. The JRC proposed techniques, developed the necessary technology, and ran long-term experiments involving hundreds of EU customs officers to validate the usefulness of using CSM data. The results of this research led the Commission to bring forward a legislative proposal that would enable Member States and OLAF to systematically use CSM data for these anti-fraud purposes. It also served to convince Member States of the value of the proposed provisions.

The financial gains from the avoidance of duties, taxes, rates and quantitative limits constitute an incentive to commit fraud and allow the capacity to properly investigate in cases, such as mis-declaration of the origin of imported goods. The information extracted from the CSM data can facilitate the investigation of some types of false origin-declarations. With the new legislation an importer will no longer be able to declare – without raising suspicions – country X as dispatch/origin of goods if these were transported in a cargo container that started in country Z (as indicated by the CSM data).

jrc-csm-dataset-world-map (1)The technologies, know-how and experience in handling CSM data, developed by the JRC through its experimental ConTraffic platform, will be used by OLAF to set up the system needed to implement this new legislation applicable as from 1 September 2016. The JRC will continue to analyse large datasets of CSM records (hundreds of millions per year) as these are expected to be made available through the new legislation and will continue to support not only this new regulation but to exploit the further uses of this data notably for security and safety and real-time operations. Its focus will be on data mining, new automated analysis techniques and domain-specific visual analytics methods. Source and Images: EU Commission

Vietnam Customs to Push Ahead with New e-Customs System

Picture1The Japanese-funded e-Customs system known as “VNACCS/VCIS” (Vietnam Automated Cargo and Port Consolidated System and the Vietnam Customs Information System) is set to “go live” on April 1, 2014.

Based on the NACCS/CIS of Japan, VNACCS/VCIS is intended to handle e-Declaration, e-Manifest, e-Invoice, e-Payment, e-C/O, selectivity, risk management/criteria, corporate management, goods clearance and release, supervision and inspection.

With the launch of the VNACCS/VCIS, Vietnam Customs is trying to simplify customs clearance procedures, reduce clearance time, enhance the management capacity of customs authorities in line with the standards of modern customs, as well as to cut costs and facilitate trade. VNACCS/VCIS also purports to ensure Vietnam’s compliance with the ASEAN “single window” initiative.

VNACCS/VCIS is intended to improve on the current e-Customs system. For example, the VNACCS/VCIS provides new procedures for the management of pre-clearance, clearance and post-clearance processes, adds new customs procedures such as registration of the duty exemption list, introduces a combined procedure for both commercial and non-commercial goods, simplifies procedures for low unit value goods and offers new management procedures for temporarily exported/imported goods, etc.

After the testing phase (which took place from November 2013 until the end of February 2014), users have been raising concerns regarding the VNACCS/VCIS system’s complexity. VNACCS/VCIS provides a declaration process with 109 export and 133 import data fields, compared to the current 27 export and 38 import declaration fields. Many of them are not compatible with the actual systems of companies, and appear to require from declarers an extensive knowledge of customs-related matters.

Comment – from an outsider’s perspective, besides systems testing, it would seem to appear that insufficient time has been allocated for alignment of industry systems to Vietnam Customs’ new data requirements. This, and the fact that no ‘grace period’ (waiver of sanctions or penalties) will be considered by the customs administration does not bode well for a smooth transition.

VNACCS/VCIS employs the quantity reporting mechanism in the official Units of Measures (“UOMs”), often used in international trade statistics, yet creates significant obstacles to companies that do not have compatible manufacturing, inventory planning and control systems. Vietnam Customs has stated that it will work on improving this issue.

VNACCS/VCIS also applies the declaration of customs values at the unit level. Since unit costs and unit prices used in financial systems of companies may not always be identical to declared values, companies may fail to comply with such requirement. Sanctions may be applied from day 1 of the new systems activation.

Technical difficulties are also a matter of great concerns to business community, e.g. with asset tracking. Currently under VNACCS/VCIS, reporting is limited to 7 digits, incompatible with many companies having asset tracking systems with identification numbers of up to 20 digits. To address concerns raised by the business community about the new system, Japanese experts have agreed to support Vietnam Customs 1 year after the official implementation date of the system.

There are concerns for potential risks of non-compliance for wrong declaration due to lack of an adequate understanding of VNACCS/VCIS. Vietnam Customs has rejected a proposal for “grace period” before applying sanctions upon violations, but encourages companies to actively participate in training programs organized by customs authorities to better avoid potential non-compliance risks.

Another concern is the chance of system failure which may lead to severe interruptions and delays in clearance procedures. Vietnam Customs has ensured business community that they have a back-up contingency mechanism in place to support customs procedures in the event that VNACCS/VCIS fails to operate properly. In the meantime, a new circular detailing the implementation of VNACCS/VCIS is being drafted and should come into effect by the launch date. Various business associations are still trying to find ways to mitigate the likely disruption from the sudden transition to the new system. Source: Baker & McKenzie (Vietnam)

CBP initiation date for liquidated damages for 10+2 non-compliance

isfU.S. Customs and Border Protection (CBP) has announced that on July 9, 2013, it will begin full enforcement of Importer Security Filing (ISF or 10+2), and will start issuing liquidated damages against ISF importers and carriers for ISF non-compliance.

According to the CBP release, “in order to achieve the most compliance with the least disruption to the trade and to domestic port operations, it has been applying a “measured and commonsense approach” to Importer Security Filing (ISF or 10+2) enforcement.

The Importer Security Filing (ISF) system—also referred to as the “10+2” data elements—requires both importers and carriers to transmit certain information to CBP regarding inbound ocean cargo 24 hours prior to lading that cargo at foreign ports. These rules are intended to satisfy certain requirements under the Security Accountability for Every (SAFE) Port Act of 2006 and the Trade Act of 2002, as amended by the Maritime Transportation Security Act of 2002.

Under the ISF, the following 10 data elements are required from the importer:

  1. Manufacturer (or supplier) name and address
  2. Seller (or owner) name and address
  3. Buyer (or owner) name and address
  4. Ship-to name and address
  5. Container stuffing location
  6. Consolidator (stuffer) name and address
  7. Importer of record number/foreign trade zone applicant identification number
  8. Consignee number(s)
  9. Country of origin
  10. Commodity Harmonized Tariff Schedule number

From the carrier, 2 data elements are required:

  1. Vessel stow plan
  2. Container status messages


EAC authorities share cargo data online

East African tax authorities have launched an online system to share customs cargo information in the region. The system, RADDEx 2.0 (Revenue Authorities Digital Data Exchange), will enable the tax authorities to instantly know what is in transit in the region. Uganda Revenue Authority says RADDEx 2.0 is web-based, has more “functionality and better performance” and will be used by clearing agents. If cargo destined to Uganda poses any risk, notifications  will be sent via e-mail so that authorities can plan action prior to arrival of the cargo. All data on cargo will be sent to a central server at the East African Community headquarters in Arusha, Tanzania. Any East Africa partner state that needs data about expected cargo will interrogate the system, which will automatically provide feedback. The system was developed by IT and customs expert staff from Uganda, Kenya, Tanzania, Rwanda and Burundi and sponsored by USAID/COMPETE (Competitiveness and Trade Expansion Programme). Source: The New Vision, Uganda

Advancing the argument for sealing cargo and tracking conveyances

South African Customs law provides for a seal integrity regime. This consists in provisions for the sealing of containerised sea cargo as well as sealable vehicles and trailers. These requirements have, however, not been formally introduced into operation due to the non-availability (until recently) of internal systems and cross-functional procedures that would link seal integrity to known entities. To explain this in more layman’s terms, it is little use implementing an onerous cargo sealing program without systems to perform risk assessment, validation of trader profiles and information exchange. It’s  like implementing non-intrusive inspection (X-ray scanning) equipment without backward integration into the Customs Risk Management  and Inspection environment and systems. It has often been stated that a customs or border security programme is a layered approach based on risk mitigation. None of the individual elements will necessarily address risk, and automation alone will likewise not accomplish the objective for safe and secure supply chains. Moreover, neither will measures adopted by Customs or the Border Agency succeed without due and necessary compliance on the part of entities operating the supply chain. It therefore requires a holistic strategy of people, policy, process and technology.

In the African context, it is surmised that the business rationale will be best accomplished with a dual approach on IT connectivity and information exchange. Under the political speak there are active attempts within SACU, SADC, COMESA and the EAC to establish electronic networks to facilitate and safeguard transit goods. Several African states are landlocked and are not readily accessible, some requiring multiple transit trips through countries from international discharge in the continent to place of final destination. National laws of each individual country in most instances provide obstacles to carriers achieving cost effective means in delivering cargoes. Over and above the laws, there exists (regrettably) the need to ‘grease palms’ without which safe passage in some instances  will not be granted. Notwithstanding the existence of customs unions and free trade areas, internal borders remain the biggest obstacle to facilitation.

Several African logistics operators already implement track and trace technology in the vehicle and long-haul fleets. This has the dual purpose of safeguarding their assets as well as the cargoes of their clients which they convey. Since 9/11, a few customs administrations have formally adopted ISO PAS 17712 within their legislation to regulate the use of high security seals amongst cargo handlers and carriers. In most cases this mandates the use of high security ‘mechanical’ bolt seals. However, evidence suggests there is a growing trend to adopt electronic seals. Taiwan Customs for one has gone a significant way in this regard. Through technological advances and increased commercial adoption of Radio Frequency Identification (RFID) technology the costs are reducing significantly to warrant serious consideration as both a viable and cost-effective customs ‘control’ measure.

Supply chain custody using RFID as an identifier and physical security audit component – as provided for in ISO 17712 – is characterized by the following:

  • it uniquely identifies seals and associates them with the trader.
  • the seal’s unique identity and memory space can be used to write a digital signature, unique to a trader on the seal, and associating that seal with a customs declaration.
  • using customs trader registration/licensing information, together with infrastructure to read seal information at specified intervals along a route to create a ‘bread-crumb’ audit trail of the integrity of the cargo and conveyance.
  • using existing fleet management units installed in trucks to monitor seal integrity along the high risk legs of a cargo’s transit.
  • record the seal’s destruction at point of destination.

Looking forward to the future, it is not implausible for customs and border authorities to consider the use of RFID:

  • as a common token between autonomous customs systems.
  • to verify and audit that non-intrusion inspections have taken place en-route, and write that occurrence to the seal’s memory with the use of an updated digital signature issued to the customs inspection facility.
  • to create a date and time stamp of the cargo’s transit for compliance and profile classification – to confirm that transit goods have actually left the country as well as confirm arrival at destination (to prevent round tripping).
  • Lastly to archive a history of carrier’s activities for forensic and/or trend analysis.
This is a topic which certainly deserves more exposure in line with current regional developments on IT-connectivity and information exchange. A special word of thanks to Andy Brown for his contribution and insight to this post.
Related articles

Korea to implement Advance Manifest System

The Korea Customs Service (KCS) will introduce an Advance Manifest System in accordance with WCO standards as well as fulfill its own responsibilities as a governmental agency of duties for collection and border protection. This follows other major trading partners such as the U.S., Canada, EU and China who have already already adopted the Advance Manifest reporting. Known as KAMS, the new system will be implemented by KCS from 1st December, 2011. For more information click the hyperlink to download Korea Customs Advance Manifest System guideline.

Empty container depots adding to industry’s costs?

FTW published an article recently in regard to ‘empty container depots’ and their apparent negative impact on cost and response to industry needs. It was duly noted that while so much focus was accorded to Port delays, little is said about the additional costs caused by empty container depots. Many of these in fact hold, clean and distribute empty containers on behalf of shipping lines some of whom are not equipped to service the industry due to ill-equipped facilities.

Shipping lines complain about the turnaround of their vessels at the port, but take little interest in ensuring a quick turnaround of vehicles at their appointed container depots. The report continues: “Transporters are delayed for hours at major depots while waiting for containers to be turned in, cleaned and then released for export cargo. Most of these depots do not work 24 hours in line with the port and transporters, which further limits the ability of transporters and industry to perform”. I think this deserves some further thought and consideration, and for this I’ll provide a customs-slanted view.

Firstly, in other parts of the world, the same mentality prevails whenever a port or customs system is replaced or upgraded – an avalanche of vitriolic sentiment, followed by line operators threatening to institute port delay surcharges and the like. To place matters into true perspective – yes, the port and customs services are there for the benefit and support of the supply chain, and should run and be maintained to offer efficient operation even in the event of catastrophe or a burgeoning logistics market demanding increased capacity and responsiveness. 9/11 provided a catalyst for Customs Inc. to initiate an unheard of demand on trade to increase its internal security mechanisms and even provide information in advance of the lading of a vessel at a foreign port. The US lines were the first to climb on the band wagon in support of heightened security and quickly acted to ensure that their regional offices were able to assist foreign shippers in supplying the required ‘advanced information’ at a nominal charge – varying between $25 and $60 per bill of lading. Sure, this was the cost necessary to ensure lines met their new stringent reporting requirements to the US Homeland Security to obviate possible penalties of $5,000 and up. Nonetheless, the same lines, when asked to provide the local authorities the same courtesy, recoil and look for all sorts of excuses to avoid the subject. Sure, it is understood that only the US has the right to make such demands, not any anyone else. I have followed most other advance cargo reporting requirements with similar amusement.

You see, lines were prepared to make suitable arrangements for US-bound containers such as pre-booking empty containers. Now when the requirement is extended to other parts of the world there is an immediate issue. Simply, and as the article correctly deduces, supply chain security implies that everyone changes – even the empty container depots.

As the local port authorities and your customs service are spending millions in upgrades to meet the demands of the future, so too is the same required of trade. Unlike commercial entities, your customs service remains one of the few who in the world that has not instituted a customs service fee. Certain traders and intermediaries in the industry might complain that recent developments at SARS have seen their costs increase due to new transactional requirements, for example the electronic supporting document issue. This I will discuss on its own in a separate post. The bottom line is that the FTW article is an important cue for those container depots concerned to get their act together. The heat will undoubtedly be turned up on them once SARS introduces its new export clearance and cargo reporting requirements. South Africa needs smaller to medium enterprises offering dedicated services. Perhaps it’s time for the lines (those who operate such facilities) to consider outsourcing these activities to more dedicated enterprises. Read the FTW article here!

New Zealand Time Release Study 2010

NZ Time Release Study 2010Besides rugby, the Kiwis also do Customs pretty well. It is clear that Customs administrations outside of a revenue authority model can place more time and emphasis on the things that are meaningful. Perhaps South Africa will soon attain this level of performance reporting. Before this however, the ability of the impacted parties to report both spontaneously and reliably is a given.

The trading community are directly impacted by the response times. Not only does it affect whether or not storage and demurrage might occur, it also (more importantly) affects their local and international reputation as suppliers of choice. One of the methods used for the review of clearance procedures is to measure the average time taken between the arrival of the goods and their release. This facilitates Customs to identify both the problem areas and potential corrective actions to increase their efficiency. The use of automation and other sophisticated selectivity methods  allow Customs to improve compliance and at the same time improve facilitation for the majority of low risk goods.

The time required to release goods is also increasingly becoming the measure by which the international trading community assesses the effectiveness of a Customs administration. The WCO Time Release Study provides guidance for a Customs administration on the best way to apply this method of internal review.

Penalties for non-compliant Cargo Reporters

Recently SARS issued a communication signalling its intention to penalise non-conforming cargo reporters as of 1 July 2011, if they fail to report their cargo manifests electronically to SARS. Following international practice, all parties who engage in the contract of carriage of goods internationally are obliged to report the details of such cargoes. While customs has traditionally placed more emphasis on the correctness of the goods declaration alone – due to it being the sole means of duty and tax assessment and collection of revenue, the introduction of measures to safeguard the supply chain and combat other forms of nefarious activities, implies that all supply chain operators are ‘known’ and share in the responsibility for their actions and activities.

Perhaps seen in this guise, the whole matter of supply chain security encompassing the universal adoption of the Authorised Economic Operator (AEO) concept seems less appealing than it did a few years ago. Yes, Customs wants to know more and more about your business and who you do business with. Freight forwarders / Clearing Brokers have borne much of the brunt from customs over the years, it’s now time for parties involved in the conveyance of cargoes to come forward and be counted.

Because international shipping by its very nature transcends borders, it has always been difficult for national authorities to apply effective controls over information and parties who in all honesty are representatives/agents for those supplying the ‘original’ shipping documents. What the law now says is that those acting on behalf of foreign principles, liable for the import leg of imported goods are obligated to submit the ‘manifest information’ of those goods (electronically) to SARS.

For those customs brokers who operate as freight forwarders, this is in essence a further requirement which SARS places on your organisation. In essence a freight forwarder has a dual requirement with SARS – declaring the manifested contents of a consignment, as well as making due clearance for regulatory compliance and payment of duties. Another party with a similar dilemma are certain ‘ground handlers’, specifically those who are contractually responsible for the inbound operations of foreign air carriers, as well as the deconsolidation of aircargo upon arrival in their transit shed. They too must report the aircargo manifests electronically to SARS, and secondly to report the outturn of such goods, once unpacked for temporary storage and customs clearance and release.

The NVOCC or Vessel’s Agent must also report all cargo – for which they are contractually responsible – for the inbound leg into the Republic. These parties represent the foreign carrier and must consequentially report the carrier’s manifest (electronically) to SARS.

SARS is for now focussing principally on the reporting of master and house (sea and air)cargo manifests in this phase. Other reports are to follow.

Details for the registration for reporting electronically to SARS’ Automated Cargo Management (ACM) system have been widely distributed, and for sake of convenience are available for download here.

Consequences for non-compliance post 1 July 2011

SARS has put into place mechanisms to identify non-reporters. In such instances customs officers will call for administrative penalties to the extent of R1000,00 for each ‘manifest’ not reported. Moreover, should SARS take measures to ensure that these penalties are not ‘passed on’ to the importer – this would surely defeat the object of SARS’ intentions? Shortly, we’ll discuss the future matching of electronic cargo reports and goods declarations, but first lets endeavour to accomplish the first milestone.