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Stay Calm. eHBL Seven Month Implementation Gives Time

ehbl-cbsaMany in the community have raised serious and valid concerns about the readiness of the CBSA and readiness of many other stakeholders for the eHBL implementation date of November 7th.   eHBL is transformational.  The biggest change is that goods will move on the eHBL 8000 cargo control number – a significant change to the current complex and multi-layered inbound paper process.  In the message below, the CBSA assures us that goods will move under the existing system of ACI supplementary filing and paper re-manifests at destination.

 

So don’t panic.  November 7th is not a line drawn in cement or even in the sand.  Keep doing exactly what you are doing until you, your warehouse, the terminals, railroads and airline warehouses you use implement the D4 Notices.  We are recommending that you manage your eHBL implementation to D4 Notices implementations and that you plan to ‘flip the switch’ only in late December or in early January when there is wide-spread uptake of the D4 Notices.

 

Still, the sooner we can get rid of paper and stop lining up wasting valuable resources getting paper stamped, the better we all will be.  The ONLY real benefit of eHBL to the practitioners in the inbound supply chain is ‘paperless movement of goods’.

 

We have written to the CBSA with regards to the last sentence of the following communication and reiterated that the freight forwarder and the importers they serve cannot and will not be held ransom to the CBSA’s staffing availability for stamping.  In many instances, freight forwarders will have no option but to delay eHBL and continue to submit ACI Supplementary data and present re-manifest paper for stamping at destination for the next few months: some policy decisions will not have been made, the warehouses won’t be ready with D4 Notices and goods will not be able to move on eHBL 8000s as planned.  Although we hope that most of the big puzzle pieces have fallen into place, the CBSA must be staffed adequately to handle any stamping requirements between January and July.

 

Between now and January there is time for the CBSA to deliver the final policy pieces of this complex puzzle and it gives time for the community to prepare.

 

– Terminals and warehouses will implement the D4 Notices and the Deconsolidation Notice

 

– Forwarders will implement the D4 Notices, test their systems, revise their operating procedures

 

– The CBSA will find solutions for (among others):

 

– ‘Release requests’ on non-bonded 8000 cargo control numbers

 

– Flying trucks

 

– Warehouse rules (and figure out just exactly how the sufferance warehouse operators are supposed to ‘arrive’ marine shipments without adding huge delays, costs and risks of damage for thousands of buyer’s consolidations)

 

– Buyer’s consolidations

 

 CBSA Message

 

Effective November 7th, freight forwarders should be transmitting electronic house bills for consolidated shipments within the prescribed modal timeframes.

 

Highway and rail:

 

 In the highway and rail modes, if an electronic House bill is not transmitted, the cargo will continue to move, and paper House bills will be accepted at destination. Beginning January 11, 2017, if pre-arrival electronic House bills have not been transmitted for consolidated shipments a zero-rated AMP may be issued to the freight forwarder; however the cargo will continue to move and paper House bills will be accepted at the destination. Beginning July 12, 2017, monetary AMPS may be issued for failing to transmit electronic House bills.

 

 Air and Marine:                                                    

 

In the air and marine modes, effective November 7, 2016 if pre-arrival electronic House bills are not transmitted for consolidated cargo, but supplementary data is transmitted for the consolidated cargo, the cargo will move and paper House bills will be accepted at destination.  Beginning January 11, 2017, zero rated AMPS may be issued if electronic House bills are not transmitted for consolidated cargo, but if supplementary data is received the cargo will move and paper House bills will be accepted at destination.  Beginning July 12, 2017, if electronic House bills are not transmitted, monetary AMPS may be issued, but if supplementary data has been received, the cargo will move and paper House bills will be accepted at destination. The CBSA will continue to accept electronic supplementary data reports for a period of time after the beginning of the monetary AMPS period. During this period, Do Not Load messages will not be issued for failing to submit pre-arrival or pre-load House bills if an electronic House bill has not been transmitted, but a valid supplementary data report has been transmitted within the prescribed timeframes.  

 

Clients in all modes may encounter processing delays after January 11, 2017 if presenting paper House bills at destination

 

This is the sentence many are taking exception to and this is the sentiment that we are working to remove from the puzzle.

 

 

 

Some tools and links:

 

Timelines and Customs Notice 16-17 http://www.cbsa-asfc.gc.ca/prog/manif/reqfrfwdrs-extransitaires-eng.html

 

CIFFA eHBL Frequently Asked Questions has dozens of detailed questions and answers, sorted by category. http://www.ciffa.com/toolbox/ehblemanifest-faqs-2/

 

The CBSA is available at:

 

eManifest-Manifeste_electronique@cbsa-asfc.gc.ca

 

CBSA-ASFC_eManifest.Comm@cra-arc.gc.ca

 

TCCU-USTCC@cbsa-asfc.gc.ca

 

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