Archives For Cargo Manifest

SARS-RCG

Enter SARS RCG Webpage here!

This Friday, 20 April 2018, SARS Customs will implement its new Cargo, Conveyance and Goods Accounting solution – otherwise known as the Cargo Processing System (CPS). In recent years SARS has introduced several e-initiatives to bolster cargo reporting in support  its electronic Customs Clearance Processing System (iCBS), introduced in August 2013.

Followers of SARS’ New Customs Acts Programme (NCAP) will recognise that the CPS forms part of one of the three core pillars of the new legislative programme, better known as Reporting of Conveyances and Goods (RCG). The other two pillars are, Registration, Licensing and Accreditation (RLA) and Declaration Processing (DPR). More about these in future articles.  In order to expedite the implementation of the new Acts, SARS deemed it necessary to introduce elements of the new functionality via a transitional manner under the current Customs and Excise (1964) Act.

Proper revenue accounting and goods statistical reporting, can only be adequately achieved if Customs knows what goods ‘actually’ arrive, transit and exit it’s borders. Many countries, since the era of heightened security (post 9/11), have invested heavily in the re-engineering of policies and systems to address the threat of terrorism. This lead to a re-focus of resources and energies to develop risk management systems based on ‘advanced information’. SARS has invested significantly in automated systems in the last decade. Shortly, SARS it will also introduce a new automated risk engine with enhanced capabilities to include post clearance audit activities.

It should also not come as a surprise to anyone conversant with Customs practice, that international Customs standards such as the WCO’s SAFE Framework of Standards, the RKC and the Data Model are prevalent in the new Customs legal dispensation and its operational business systems.

South Africa will now follow several of its trading partners with the introduction of ‘advance reporting of containerised cargo’ destined for South African sea ports. This reporting requires carriers and forwarders to submit ‘advance loading notices’ to SARS Customs at both master and house bill of lading levels, 24 hours prior to vessel departure.

The implementation of CPS is significant in terms of its scope. It comprises some 30 odd electronic cargo notices and reports across the sea, air, rail and road modalities. These reports form the ‘pipeline’ of information deemed necessary to ensure that the ‘chain of custody’ is visible and secure from point of departure to final destination. For the first time, South Africa will also require cargo reporting in the export domain.

SARS_RCG_ Message_Schema 2018

Download a high resolution map of SARS Cargo Report Messages here!

It is no understatement that the CPS initiative is a challenge in particular to new supply chain entities who have not been required in the past to submit electronic reports. In order to meet these reporting requirements, a significant investment in systems development and training is required on the part of SARS and external trade participants. To this end, SARS intends to focus on ramping up compliance amongst all cargo reporters across all transport modalities. The first modality will be road, which is the most significantly developed and supported modality by trade since the inception of manifest reporting under the Customs Modernisation Programme. The remaining transport modalities will receive attention once road is stabilised. 

 

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ACE_image_csonLast week, the National Customs Brokers & Forwarders Association of America, Inc. (NCBFAA) hosted a conference in Baltimore, MD targeting software developers interested in obtaining more information about US Customs and Border Protection’s (CBP’s) Automated Commercial Environment (ACE) and upcoming technical changes related to the PGA Message Set, Entry Summary Edits, Automated Corrections/Cancellations and AES Re-Engineering/Manifest Baseline development. During the conference, CBP made two important announcements which were heard and noted first hand from an Integration Point representative. These two announcements included:

  • CBP announced that it plans to mandate the use of manifest and cargo release in ACE by December 31, 2015 and mandate the use of ACE by December 31, 2016. CBP also provided a tentative release schedule for seven deployments that will lead up to this mandate.  Each deployment will consist of one or two increments, and each increment will span over a period of twelve to thirteen weeks. On this road map, CBP announced some exciting functionalities to be released in the near future such as automated cancellation and/or correction of entries, integration of simplified entry with other modes of transport and certifying simplified entry through summary. In addition to the enhanced simplified entry process, CBP also gradually plans to include the validations that were not initially included in ACE entry summaries.
  • CBP is also working on the reengineering of AES and pilot programs of entry data collection for various Participating Government Agencies such as the US Environmental Protection Agency (EPA) and US Food Safety and Inspection Service (FSIS) and CBP plans to deploy this later on in 2013 and early in 2014.

Now there is relevance in all of this. It reinforces the growing importance of Customs’ focus on “cargo management”.  Far too much emphasis is placed on the goods declaration alone. This is not only short-sighted but demonstrates an ignorance of the global supply chain. Without the ‘cargo report’ (manifest) the goods declaration is little more than a testament of what is purported to have been imported and exported.

confidentialAn interesting and pertinent issue has been raised in the social media area on the ‘confidentiality’ of carrier information submitted to Customs. In this particular regard it relates to the practice of the US Customs and Border Protection Agency. One blogger commented “It’s kind of ironic in the U.S. for example that importers/consignees are required to submit a request to customs to opt-in to keep manifest information confidential.”

CustomsNow, a direct filing solution for US traders relates “As a common practice, importers and consignees may submit a request to US Customs, pursuant to 19 CFR 103.31, to keep manifest information confidential.  Our previous blog post on this topic  includes several tips to ensure these requests result in the broadest degree of confidentiality.”

Recently, importers and consignees who have submitted confidentiality requests have complained to CBP that confidential shipping data — party/shipper/consignee name and address — for ocean freight have nevertheless been disclosed to the public.  After reviewing the matter, Customs has determined that “improper data entry” was the cause.  To avoid this, CBP advises in a recent CSMS publication, when filing e-Manifests in ACE, “the commercial party name fields must ONLY contain commercial party name data.”  Otherwise, “…the name of the party stored in the ACE database is corrupted because it includes address data. This inaccurate party name data fails the confidentiality edits resulting in confidential business information being shared publicly. This inadvertent disclosure is tied directly to the way in which data is transmitted by users.” Additional information can be found in CBP’s CSMS #13-000064.

In South Africa, and I’m sure a great many other countries too, one just has to accept that the Customs authorities will secure such information, because they say its safe. Read the link below – cause for concern.

MV Rena off New Zealand Coast of TaurangaIn this age of heightened security it remains remarkable how carriers still willfully take custody and/or load ‘goods’ for which the contents thereof are unclear. True, carriers and intermediaries (fowarders/brokers) will correctly point at the ‘shipper’ (exporter) for not disclosing the details correctly. It also needs be mentioned that the cargo handler (packer of the container) is really key in all of this. It is this entity who has knowledge of what is being stuffed into the container. There is much debate on this matter, and a whole lot more work to be done in ultimately pinning down the responsible party. Given this state of affairs, most Customs administrations are happy to lay the responsibility and liability for lawful clearance on the party responsible for cargo reporting, i.e. the entity which ‘cuts’ the manifest. I dare say that the terms of sale (incoterms) also have an influence in terms of risk and liability here which adds some complexity to decision-making in time of misfortune. Take for instance the recent grounding of the M/V Rena off New Zealand earlier this month, where it has recently come to light that the wreck contains at least 21 containers which were not properly recorded on the ship’s manifest. Read articles below.