January 8, 2015
Canada Border Services Agency
171 Slater St, 8th Floor
Ottawa, ON K1A 0L8
Attention: Alec Attfield, Director
By eMail: Alec.Attfield@cbsa-asfc.gc.ca
Subject: Comments on D20-1-1 Exporter Reporting
On behalf of the members of the Canadian International Freight Forwarders Association (CIFFA) we are pleased to submit the following comments on the revised D20-1-1. We will not repeat details on several comments that were noted at the BCCC Sub- Committee meeting on December 15, 2015, such as finalizing the flow chart, ensuring that definitions are clear and updating certain language.
At the outset we would like to express our regret that this revision of the DMemo, which was started in 2012, does not address the need for mandatory electronic export reporting and the elimination of the paper B13A. We understand that the legislative and systems changes have not occurred which would permit and facilitate the move to the 21st century world of paperless transactions for Canada’s export reporting. The reasons for mandatory, electronic export reporting outlined in our letter of September 16, 2009 to the Honourable Mr. Van Loan and others are even more compelling today.
15. and 16. We agree with your comments that paragraphs 15 and 16 are challenging as the CBSA has no authority over email or electronic exports. This is a Canada Border Services Agency Departmental Memo and has no responsibility to deal with Other Government Department requirements (such as those of DFATD or CFIA etc.) and there is no need for it to contain these paragraphs.
30. Not for this revision of the DMemos, but for our future thinking about exports, do we want all shipments, regardless of commercial value or personal effects reported electronically for risking? Risk assessment is risk assessment, regardless of the value or nature of the shipment. One must consider the risk attached to a printer cartridge that under our current regulations would not be reported on export. Our association has begun to think about this subject and looks forward to future discussions.
46. It is the exporter’s responsibility to provide the carrier with their export declaration proof of report number. Proof of report will be in accordance with the reporting method, as follows:
a) In the case of a CAED, the proof of report is 23 digits in length and includes:
i. the licence number, which is composed of two numeric, one alphabetic and three numeric digits, e.g. 12X543;
We have been advised by a CIFFA member that the CAED proof of report has changed and can now be either as noted here or three numeric and three alpha. This should be reviewed with Stats Can before finalization of the DMemo. If the numbering change is permanent and the DMemo is updated, there will have to be extensive communication to carriers, forwarders and exporters so that systems can be updated.
56. We look forward to seeing the re- wording of this paragraph to clearly state that it is not an individual officer that must be satisfied, it is the CBSA that must be satisfied. At every holiday period such as Christmas the association receives two or three examples of export containers called for exam, then the officer goes on vacation and the container sits for two or three weeks until that officer comes back. Changing the wording, communicating the change, and having CBSA Operations revise standard operating procedures will be helpful.
H. Ruth Snowden Paul Hughes
Executive Director Customs Committee Chair
C: CIFFA Members at www.ciffa.com