Advocacy Update

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CBSA Border Commercial Consultative Committee meetings outline 21st Century Strategy

By Kim Biggar

The Border Commercial Consultative Committee met in Ottawa from November 6 to 8 to provide an update on CBSA strategy, policy and projects.

In a session called “CBSA Strategy for the 21st Century,” Fred Gaspar, Director General of CBSA, noted the following priorities for the agency:

  • Working better with industry;
  • Developing a business expertise strategy;
  • Reviewing current KPIs;
  • Modernizing the Customs Act and legislation; and
  • Strengthening risk-based compliance.

Operational pressures and challenges include:

  • Emerging threats to health and safety (e.g., African swine fever);
  • Implementation of bilateral and multilateral trade agreements;
  • Implementation of an increasing number of measures stemming from trade disputes and remedies;
  • Increasing threat sophistication;
  • Increasing trade volumes and complexity of trade networks;
  • Pressure to modernize processes and employ newer technologies; and
  • Limited human and financial resources.

A review of current projects and initiatives looked at the following.

Cargo Preclearance

Work is being done to identify hubs in the U.S. through which significant volumes flow to Canada to enable customs inspections by CBSA officers in the U.S. Replicating Canadian border operations within a foreign jurisdiction is unprecedented and presents a complex undertaking; in preparation, the CBSA is internally assessing legal, policy, and operational dependencies.

The CBSA remains very interested in how the cargo preclearance vision can be leveraged to support parallel work within stakeholder business models. Current legislation needs to expand to include cargo.

The CBSA is also seeking out industry interest on participating in cargo preclearance pilots in the U.S.

The aim is to employ a small footprint in key locations and/or along strategic trade corridors to incrementally test operating procedures, infrastructure and logistics, while also assessing the impacts and benefits to stakeholders and the CBSA in a real-world context.

The Agency will continue to progress preliminary work on multimodal and courier pilot concepts, develop new pilot proposals and requirements, determine key issues and develop mitigation strategies.

Canadian Export Reporting System (CERS)

The CBSA is finalizing the testing of CERS, a web-based self-service portal replacing the Canadian Automated Export Declaration (CAED) system. The system was expected to be in production early in December.

Letters have been sent to all exporters and customs service providers who report using CAED or the Summary Reporting Program providing information on what to expect during the CERS onboarding phase.

Schedule:

  • January: Selected industry stakeholders will participate in the CERS pilot phase.
  • February: On-boarding communication will be distributed.
  • February: First wave of CAED users and all Summary Reporting Program (SRP) clients can begin using CERS.
  • March: Paper B13A reporters can begin registering for CERS.
  • April: Remaining CAED users can begin using CERS.
  • June: Mandatory electronic reporting for exporters. CAED to be decommissioned.

Single Window Initiative

CBSA is finalizing system changes to optimize the use of SWI for all participating programs, continue stakeholder engagement and employ a phased decommissioning approach to minimize impact on operations and industry. The current system will be decommissioned on April 1, 2020.

Culpability Framework

The culpability framework is the policy cornerstone that will guide operational efforts to nudge, direct or enforce compliance based on the relative risk that importers and their transactions represent. The framework enables the CBSA to proactively target compliance outreach to support voluntary compliance.

Changes are being planned to strengthen compliance. Higher AMPs and other measures are expected to effectively incent voluntary compliance. Predictability and national consistency are goals.

Assessment and Revenue Management (CARM) Project

Phase 1 will be deployed in fall 2020.

Electronic House Bills

A date has been confirmed for R856 (House Bill R2): June 6, 2020.

Once the system is in place, a new date for the beginning of a six-month informed compliance period (there will be no AMPS penalties for non-compliance during this period) will be necessary before making e-house bills mandatory.

Information sessions have started and will continue over the coming months. Detailed walkthroughs will be scheduled for all client types.

Trusted Trader Program

The Trusted Trader Renewal Working Group is working to modernize the Trusted Trader program to continue to expedite trade for low-risk, trusted partners.

The next steps will be to develop mutual recognition arrangements and to review minimum security requirements.

Secure Corridor Concept Pilots

The CBSA is leveraging technology to automate the electronic capture of passage data to achieve low-touch, remote processing of participating trusted traders.

Enhanced Detection Technologies and Tools

CBSA is increasing its capacity to detect guns, opioids and unreported pork products to stem the flow of illegal firearms, drugs, and foods and animal products that could spread African swine fever.

Infrastructure Planning – Land Border Projects

The CBSA is planning 24 upgrades between now and 2025 in coordination with the U.S. More than 100 land clearance sites are in scope.

Working Group Updates

  • Maritime: Examinations have been increased based on risk assessment. Service standards for the movement of containers at ports are to be established.
  • Highway ACI / AMPS: CBSA is looking for opportunities to improve highway carrier compliance. The Interim Highway Turnaround Policy has been extended through June 30, 2020.
  • Air Cargo: CBSA is implementing national protocols for aircraft searches and reviewing processes for the handling of HV, LVS and CLVS.
  • Manual Operations: A pilot is underway in Montreal involving the use of email and an electronic CBSA stamp for the processing of deconsolidation requests from freight forwarders. It provides efficiencies for both the CBSA and clients compared with the legacy paper-in-person process, particularly for clients without a physical presence near the longroom. The turn-around time is 30 minutes compared with 24 hours for the legacy process.

Upcoming projects and initiatives include development of an e-commerce strategy, blockchain, postal modernization, and large-scale imaging (LSI).