Category Archives: Director’s Blog

Former CIFFA President provides input on Montreal infrastructure development

CIFFA has been actively participating in an ongoing discussion about the Ville St. Pierre Interchange, a 10-year plus road/highway infrastructure project at its early consultation/fact-finding stage.

Logistics cluster CargoM recently hosted a discussion on the future need of the Ville St. Pierre Interchange, an event hosted February 4 by the Port of Montreal, and attended by CIFFA Director Karl-Heinz Legler, and various municipal and government officials who offered their expertise and guidance on the topic.

 Legler presented his position on the project in the following CIFFA Director’s blog:

I am a frequent user over many decades of the interchange and many of its access/exit arteries in the Ville St. Pierre – Montreal West/Lachine and LaSalle area are in constant and great need of fluidity options to circumvent never-ending traffic bottlenecks.

The numerous critical points identified by participants at the meeting have made it abundantly clear that future infrastructure improvements to aid all the different traffic flows in and around the Ville St. Pierre Interchange present a complex challenge.

The most serious challenge for seeking improvements is not necessarily the Highway 138/20  flow but the interconnectivity amongst the various local sectors touching on the interchange area, i.e. the North- South and East-West arteries between Ville St. Pierre-Montreal West /Lachine and LaSalle, particularly:

  • St. Joseph/Rue Notre Dame connections with Ave. Dollard -Rue St. Pierre / Rue St. Jaques
  • Highway 20 service roads North and South to and from St. Jaques to 1st Avenue Lachine
  • Lafleur/ Rue Clement/Ave. Dollard

Highway 20 between Boul. Agrignon and La Salle and 55th Ave., Lachine serves a large number of industrial clients.

Truck traffic from and to the CN and CP Intermodal Container Terminals in Lachine bringing goods to manufacturing plants, warehouses and distribution centres located in the immediate area is expected to increase over the years.

Trucks carrying domestic, import and export cargoes from and to the Port of Montreal, rail container terminals and Dorval airport all travel through the Ville St. Pierre Interchange.

Infrastructure planning must take into consideration the impact of the changing character of the entire area.

For example:

  • The impact of existing industrial neighbours on local traffic – problem identification and solutions
  • Increasing commercial traffic
  • The ongoing conversion of industrial land into residential development projects
  • Increasing residential traffic
  • Accessibility to parks and recreation facilities

Planning and implementation of efficient long-term road infrastructure solutions require out of the box thinking, deep pockets and cooperation amongst municipal, provincial and federal government authorities in consultation with the public.

I am thankful for having had the opportunity to express some opinions and suggestions on behalf of CIFFA at the February 4 meeting and hope to have been able to contribute to some extent positively towards identifying existing and future infrastructure issues for the Ville St. Pierre Interchange.

Kind regards,

Kar-Heinz Legler

The Port of Montreal takes action on congestion- But will carriers step up to the plate?

By Julia Kuzeljevich

CIFFA applauds the Montreal Port Authority’s announcement this week that it will be posting monthly, gateway-level scorecards on its website.

In an earlier blog dated February 12, CIFFA’s Executive Director Ruth Snowden highlighted the spate of liner congestion surcharges emerging after a difficult winter, and the overall lack of schedule integrity among some liner players, partly due to weather in the North Atlantic and winter in Canada.

Lack of schedule integrity causes a lot of problems. And defaulting to a reactive model of handling ships “when they arrive”, with the congestion charges falling on the cargo, is simply not sustainable.

MPA reports it has experienced a 17 % compounded increase in container volumes in the last two years, with a 12 % increase in January of this year alone.

While increased business and higher volumes are good news for the port and for Canada’s economy, the mounting congestion issues reported by CIFFA members to the association over the last several months have been concerning.

So the news that MPA will offer metrics online, and that stakeholders will be able to source scorecards directly from the website in both languages, is more than welcome.

Since the last quarter of 2018, MPA said it has taken the following measures to deal with the increased business:

Beginning in November, the port has moved to increase its labor force by 20 %,  and the hiring process continues, with 60% of new hires in place. Understandably the training process takes time.

The terminals have extended the gate hours from 6:00 am to 11:00 pm, Monday through Friday. Currently the use of extended gate hours is about 20% and MPA said it would like to get more users to take advantage of the after-hours gates. MPA also reported that average truck processing time for January was 54 minutes.

MPA also plans to release information on rail dwell. The average dwell for the months of September through December was between 4 and 4.5 days, with January a particularly bad month, 6 days, caused in part by terminal closure during the Christmas and New Year holidays, and the recent ice issues where approximately 4 days were lost until ice breakers arrived to clear up the navigation channel.

While these measures are not expected to completely eradicate bottlenecks and delays emerging from time to time in the system, there is the promise of greater transparency, via tools that can challenge myth from fact, and hold up kpi’s.

From CIFFA’s perspective, ideally, the next step in the process might be to identify those players whose on-time performance is far below acceptable levels. The rest of the stakeholders in the supply chain should not be forced to sink to a level of reactivity.

Put another way, should paltry performance be penalized? And can on-time performance be incentivized?

What could such measures realistically achieve? It is less about pointing fingers and blame-shifting, and more about holding to a set of standards and metrics, more about moving away from a siloed operations environment, more about forecasting, communication, and transparency in the supply chain.

The Perils of Congestion: New Surcharges Add to Port of Montreal Woes

Closely following an announcement February 5 that Maersk will introduce a Congestion Fee Destination (CFD) for all cargo discharging at Montreal, CA, effective February 8 for non-regulated countries and March 6 for regulated countries, CIFFA received a February 8th notice originating from OOCL that as of February 15, 2019, a Port Congestion Surcharge (PCS) will apply for all westbound containers (Dry & Reefer) destined to or via the port of Montreal.

This “in view of the ongoing disruption to maritime traffic in the St Lawrence River resulting in congestion at the port of Montreal and incremental schedule delays over and above the seasonal norm”, the notice said.

Our first, instinctive response was to draft an eBulletin, haranguing the carriers and crying shame that carriers ‘automatically’ pass their problems onto the cargo.  However, after some sober second thought and a lengthy conversation with a senior marine carrier executive, we have tempered our response somewhat.

That said, the congestion surcharges, and the manner in which they were communicated, do raise several points of concern.

Reasonable Notice

Whatever happened to reasonable notice? How can forwarders (or other cargo interests) make routing decisions/carrier selection based on three days’ notice… or even seven days’ notice of a surcharge?  And what is the effective date? In the OOCL notice, there was no indication of ‘where’ the PCS becomes effective. In the Maersk notice at least, the effective place/ date is ‘cargo receipt’…. So, three days’ notice from February 5th to February 8th. In all likelihood, the cargo has been quoted and booked days or weeks before the surcharge was announced and in many cases the cargo will be en route to the port of origin/ place of receipt. It is unconscionable that carriers give such little notice of a surcharge – to non-regulated countries.


And, as usual, there is no transparency in how carriers arrived at these surcharges. What was the trigger for the surcharge? Why now and why these amounts? The notices have no explanatory notes or contextual information and so one automatically jumps to the conclusion that carriers are simply taking advantage of an opportunity to add to the woes and costs of the cargo interest – by arbitrarily implementing a surcharge.

Of course, on reflection, one should naturally come to the conclusion that no carrier would want to introduce a congestion surcharge – because there isn’t a customer in the world who would want to pay it.  We have been assured that at least one carrier has conducted in-depth analysis of its additional costs and took the only step available to it to recover some of those costs., issuing the surcharge, even knowing that customers would be upset.

How hard would it have been for the carriers to share these rationalizations with their customers, to explain the costs of lying at anchor in the Saint Lawrence waiting to dock, of additional fuel spend on fast steaming to try and catch up to schedules, costs of lost opportunity and all of the other costs that are associated with congestion delays?

And, just as we don’t know how the surcharges were triggered, we don’t know what will trigger the removal of the surcharges.

Carriers Contribute to Congestion

All of that aside, it is imperative that steps be taken to reduce the congestion and get the Port of Montreal back to its historic, high levels of service.

Lack of schedule integrity among some liner players, partly due to weather in the North Atlantic and winter in Canada, is one big contributor. (What a surprise). As the Port of Montreal’s Vice President, Growth and Development, Tony Boemi, pointed out so succinctly at this year’s Cargo Logistics Show in Vancouver February 7, the issue is not the size of the ships, it’s the infrastructure needed to handle them. Lack of schedule integrity causes a lot of problems. To a large extent, he pointed out, things have evolved to a model of ships “arriving at the port when they arrive”, with the expectation that when they arrive at the port, everyone will be ready to handle them.

At the end of the day, carriers arrive on schedule or they don’t. If they don’t arrive on schedule, the terminal operators – who are hired by and paid by the carriers – may not be able to work a vessel because labour is working a vessel that did arrive on schedule. If four liner services are scheduled to call at the port and three have good schedule integrity and even one has poor on time performance, all of the carriers suffer. Perhaps the Port of Montreal should begin to penalize those carriers who fail to adhere to their agreed schedule – by not working those vessels until resources are available or by assessing penalty costs to those carriers.

In 2018 the Port of Montreal saw its 5th year of record growth on the container side, with volumes up over 9% year over year. Boemi said the port is taking a technology and innovation focus, working toward the use of more predictive analytics, and a truck app sending alerts to truckers on wait times. But, Boemi stressed, “I can have the most efficient port in the world, but if I can’t get my cargo in or out I’m no further ahead.”

Putting everything together – increased volume at the port, vessels fully loaded, lack of carrier schedule integrity, winter weather, labour issues, it is galling that carriers feel compelled to introduce a surcharge that penalizes the cargo interests …. when that cargo interest is already paying dearly for delays and congestion.   Insult added to injury as the saying goes.

Strike Mandate at Port of Montreal Not Unexpected: What Does it Mean?


As announced in the national press on January 2, 2019, longshoremen at the Port of Montreal have voted overwhelmingly in favour of giving union leadership a strike mandate. This should not come as a surprise to anyone familiar with the situation – and it does not mean that there will be a strike – or at least not in the immediate future. The negotiation process between the Maritime Employers’ Association (MEA) and the Longshoremen’s Union, CUPE Local 375 started on September 18, 2018. The MEA and Longshoremen’s Union are presently in mediation and dates have been scheduled in January.

On November 5, 2018, CIFFA wrote to the President, Canada Industrial Relations Board (CIRB) in support of the MEA’s request to have Port of Montreal operations declared an ‘essential service.’ CIFFA has learned from the MEA that hearing dates have been scheduled in February 2019. Until the decision of the CIRB, which will be after the hearings are completed, the parties do not have the right to strike or lock out. So – take a breath.

Also, in the eBulletin of December 6, 2018, under the title “Port of Montreal, Ports Modernization and the Canada Marine Act,” we talked about ongoing congestion, severe challenges with service and wait times and the not-so-secret possibility of a strike at the port. 2017 was a banner year at the Port of Montreal and the first three quarters of 2018 continued in that upward trajectory, with total TEUs at the port up to 1,395,165 versus 1,276,695 in the same period in 2017. Business is way up, terminals are hiring like crazy and the current labour contract, negotiated in 2013, expired in December.

In that article, we talked about the labour issues the port has experienced for the past several months during the negotiations between the MEA and the longshoremen’s union. We wrote at that time, “With regard to fears around a possible strike, the Port of Montreal said it remains hopeful that a negotiated labour settlement is achievable and that the parties continue to talk, with a government conciliator assisting in the discussions.”

It remains the case that the Port of Montreal and the MEA are optimistic for a negotiated settlement: “A spokesman for the employers association said negotiations are going well and its members are surprised by the union’s statements,” while it also remains the case that the union is using everything in its arsenal, including the strike mandate, to fight for the best deal for its members. The mandate to strike was expected, and is usually a normal course of action in the event that negotiations reach the point of impasse. Negotiations are continuing, and there is no reason to suggest that the right to strike will be exercised at this time.

The recent vote and the strike mandate are real and everyone must take these developments into consideration as they plan routings and make carrier selections. Members should explore all options available and plan prudently, watching the situation carefully over the next few weeks.

However, we must remember that a vote authorizing a strike mandate is not a strike. It is one tool in the union’s negotiating toolbox

CBSA: Stamping Manifests, Electronic Long Rooms and A10s

CIFFA has been represented and, we might add, very active on the Canada Border Services Agency (CBSA) Manual Operations Working Group which has wrapped up recently.  There is a hierarchy within the Border Commercial Consultative Committee (BCCC) where the Manual Operations Working Group falls under the Commercial and Operations Committee. Paul Hughes, Agility Logistics is a volunteer CIFFA director and chair of CIFFA’s National Customs Committee, representing members at the BCCC and on the Commercial and Operations Committee, among many other duties.  At a June meeting in Ottawa, the Manual Operations Working Group presented the results of recent activities.


Working Group Workplan / Priorities

  • Perform a collective analysis of the current issues with manual processing across all modes;
  • Prioritize the list of issues;

As with any consultative process, some issues are of more interest to freight forwarding operations than others.  Initial issues included: cash entries: date stamping: manifest stamping: receipt of cash: c-type entries: general entry accounting: system outages: hand carried goods

Of particular interest to CIFFA and its members is ‘manifest stamping’. Over the years we have visited CBSA operations in Vancouver and Toronto and the association has an excellent relationship with senior CBSA operations at many ports.  Earlier this spring Executive Director Ruth Snowden and volunteer member of the National Customs Committee Ted Chazin from Milgram International visited the Montreal Longroom (0395) for extensive discussions on the length of delays in manifest stamping.  Ted also represented CIFFA at the Manual Operations Working Group.

By shining a light on the situation and through the efforts of the CBSA both in Montreal and Ottawa and the BCCC Manual Operations Working Group, we have seen significant reduction in delays at the Montreal 0395 Longroom over the past several weeks – which we hope can be sustained through the summer and the next peak season.

One reason for our optimism is found in some of the notes from the BCCC Manual Operations Working Group, as presented at the June meeting, which read in part…

“Manifest Stamping

The lack of electronic options for deconsolidation and re-manifest of cargo, to request changes to previously submitted information, and other requests, require the continued use of inefficient paper based processes.  Freight forwarders are experiencing long delays in Montreal.  Commercial Operations Division is working outside this group with CIFFA and Montreal and other areas at HQ, to assist in minimizing manifesting delays at Montreal.  This includes an information exchange with the aim of reducing manifest rejects as well as exploring more efficient options for manifest submission and processing.  Delays at Montreal have been eliminated.


The Electronic Long Room

 Submitting paper documents in person at the CBSA office of release is challenging for clients, particularly those without a physical presence near to the CBSA office.  Some offices will accept them by email or fax; others will only accept them in person. Action: Explore accepting requests electronically at an increased number of offices, particularly those that are high-volume and experience delays.

Status:  Operations is working with Vancouver and Montreal on best practices which may be employed in other offices to provide greater client service and reduce delays.  At this point in time we are limiting the scope to manifests (excluding release documents, A48s).” 

Members have advised that for the first time in years, stamping delays in Montreal are close to 24 hours, and we are cautiously optimistic that the CBSA declaration above that ‘delays at Montreal have been eliminated’ is accurate.

A10 Abstracts

Finally, although not part of the official Working Group presentation, CIFFA did seek clarification on the use of the A10 Abstract as part of the Manifest Stamping issue.  There seems to be some confusion surrounding the use of the A10 Abstract versus the use of the forwarders’ 8000 Advice Notice, the A8A which is the correct document (or data set) used to de-consolidate shipments.

It was made clear that the A10:

  • Is importer driven; the importer has to have a reason to request that A10 abstracts be issued to abstract/divide their original shipment into two or more parts at the primary or inland sufferance location
  • Special circumstances have to exist in order to justify the issuance of the A10 such as:
    • Perishables (Example: One marine container bearing quota goods such as dairy where dividing the larger consignment into smaller parts might be necessary)
    • Goods sold in-transit (Example: Dividing the larger consignment into the individual components that have been sold since the goods left the port of loading)
  • The issuer of the A10 has to be the customs broker or the importer; the process is off-limits to a forwarder
  • The issuer identifying themselves as the importer’s customs broker should provide a cover letter prefacing any request for A10 explaining the importer’s reason behind their request
  • If a party other than a customs broker submits an A10 or if the broker cannot justify their request, they can expect their request to get rejected

The A10 option is open for customs brokers to use.  If a Border Service Officer refused to stamp an A10 for any reason other than the above, the customs broker should elevate to the Chief of the Longroom.

More fascinating reading and all of the rules of the A10 Abstract can be found in in paragraphs 64-70 of D3-1-1, Policy Respecting the Importation and Transportation of Goods.

And so, as we look at the next 12 to 18 months (we hope) and the full implementation of eHBL we can see some light at the end of the tunnel and some incremental improvements in the handling of paper re-manifests.  We hope to see CBSA Operations at various ports coming together to share their local best practices that will help find efficiencies. And CIFFA – staff and volunteers – will continue to shine a light on opportunities for improvement, offering solutions and sharing lessons learned from our shared experience.

Our message remains: Implement eHBL on a voluntary basis as and how you can.  Stop lining up to get paper A8A forms stamped by a resource constrained CBSA Long Room. (And don’t confuse A10 with A8A functionality)

ULD: The Grease in the Gears of Air Cargo

A guest blog by Bob Rogers

It has been over 40 very exciting years since the advent of the 747 and its containerized cargo system that changed the face of air cargo. Today, 900,000 Unit Load Devices, with a replacement value of about US$ 1-Billion move tens of thousands of tons of air cargo every day.  ULD are truly the “grease” that keep air cargo moving.

But here is the kicker – the primary function of any ULD is to provide proper restraint for tons of air cargo during flight. In other words, ULD are akin to seatbelts for passengers. And just as nobody would want to “buckle up” with a torn or damaged seat belt, nobody should expect cargo to be carried safely in a damaged or poorly loaded ULD.

Each and every ULD, be it the small A320 AKH or a 20 ft pallet for a 747 freighter, is an aircraft part. Its function is to keep itself and its contents secure in a defined location regardless of flight conditions. As such, ULD are flight safety equipment and are subject to strict regulatory oversight by the worlds civil aviation bodies.

And here’s the issue. On one hand, the airlines are responsible for the flight safety of the ULD they carry. On the other, the forwarding community routinely works with and load ULD have no such regulatory oversight. This is why ULD CARE has launched the ULD CARE ULD Code of Conduct. Details available at

Want to learn more about the “grease”? Visit the ULD CARE website at, watch the short video SOS-ULD at You can also find out more about the Code of Conduct at

All the details are available in our book ULD Explained available at .

ULD CARE is a not-for-profit Canadian corporation. Its membership is open to organizations whose scope encompasses any aircraft unit load device (ULD) activity.


ULD CARE started as an IATA committee in 1971 and became a legal entity in 2011. The Mission of ULD CARE is to use the collective resources, skills and grass roots experience of the ULD CARE membership to provide direction and deliver appropriate change in ULD operations throughout the global air cargo operating environment.

Beyond the Comfort Zone-New technologies and the changing hiring environment

By Kim Biggar

If you read from any news source for a day or two about freight forwarding or the bigger supply chain, you cannot fail to see that we are being inundated with new technologies. Keeping up with those technologies is a huge challenge, especially for small businesses with limited budgets.

Employers are concerned about their competitiveness if they don’t adopt new technologies, while employees are worried about their jobs if their employers do. According to findings of the Canadian Supply Chain Sector Council (CSCSC), acquired through recent community partnership workshops in Alberta on emerging technologies, employees have even been known to sabotage new technologies in order to make their adoption difficult and ultimately unattractive to employers.

Even when newly adopted technologies are not being intentionally sabotaged, their implementation can be fraught with challenges. As trade association MHI notes in The 2016 MHI Annual Industry Report, “In order to successfully implement any of these technologies, companies need access to a skilled workforce. According to the survey, this is the biggest obstacle facing supply chain professionals, with a full 58% of respondents indicating that they face a significant challenge in hiring and retaining a skilled supply chain workforce.”

Peter Hawkins, Managing Director at MELLOHAWK Logistics in Mississauga, Ont., jokes that he is having to push himself beyond his own comfort zone as his company takes up new technologies. While his partner in the company, Arnon Melo, embraces technology, Peter is doing so largely because he knows he must as a leader, to ensure that the employees he manages see him using tech, not avoiding it. It’s meant a mindset change for him to match the change some of his employees, in particular the older ones, have had to make.

As the CSCSC notes in its January 2018 report, The Digital Supply Chain: Creating skills for the future, technology-use skills are just part of the parcel of skills that employers need to succeed in the high-tech supply chain. Soft skills, while always important in the workplace, have perhaps become more critical than ever.

Skill Requirements in a Changing Environment

According to the CSCSC report, future supply chain skills requirements (i.e., over the next three to five years) will be focused in three areas:

  1. Analysis and problem solving
    Data and automation are reducing the amount of manual, repetitive work to be done, and making way for more IT and analysis work and systems thinking.
  2. Leadership and strategic vision
    New business models require leaders to manage change, lead collaboration, develop sound business processes, and understand the business case for implementation of new technologies.
  3. Increased need for adaptability and understanding of new technologies
    Digital literacy is a clear requirement in a digital workscape.

Sabah Sohail, President of LogisticsHires Search Consultants Inc. in Mississauga, Ont., and a board member of the CSCSC, adds communication skills and adaptability to the soft skills that will be increasingly important to workers’ success in supply chain occupations. The pace of technological change in the sector absolutely supports her emphasis on adaptability and flexibility.

She believes that many people, especially Millennials and their successors, have the tech know-how to use, or relatively easily learn to use, lots of the technology tools prevalent in the supply chain. As more and more pricing, booking and tracking systems, for example, work through smart phone apps, she says people accustomed to constant cell phone use do not find it a challenge to add an app and learn to utilize it.

Peter, too, has found, so far, that careful recruiting and hiring – of youngish people with a “propensity for change and technology, as well as good manners” – has enabled MELLOHAWK to stay up to date, but not leading-edge, with its tech use.

Despite the positive outlook of both Sabah and Peter, the news – and other stakeholders – tell a different story. Maybe some facets of the supply chain – maybe freight forwarding? – are facing a different challenge than finding people with the right skills. Maybe the problem is more to do with the slow adoption and implementation of technology by employers.

That is certainly what Sabah thinks.

What Should Employers Be Doing?

Sabah says small and medium-sized freight forwarding employers are, in many cases, “doing just what needs to be done, implementing technology only when they must, in most cases to meet government requirements.” Some employers, she says, are still using old systems that do not fully satisfy their business requirements. Sabah suggests that perhaps they feel they’re not in a position to adopt newer technologies because of a lack of money, manpower or time. She notes that, in cases where employees are still using spreadsheets, they input the same data over and over again, wasting time and surely making errors in the process. She believes that, because manual tasks like this hamper their productivity, they frustrate employees and cause them to look elsewhere for work.

While clearly there is a push in the freight forwarding industry to digitalize operations, MELLOHAWK’s experience in doing so has been an exercise in frustration. The company was an early adopter that prepared to meet the CBSA’s original implementation schedule for eManifest. Unfortunately, says Peter, early adoption simply meant the company faced costs that other companies have not incurred, as program-implementation delays continue.

This kind of experience scares employers, preventing many from making changes. How do you know what to do and when? Pat Campbell, Executive Director of the CSCSC, says that many participants in the organization’s emerging technologies workshops looked like “deer in the headlights” during discussions. “They know they should be doing something, in order to remain competitive, but when should they jump in and how do they choose what to invest in? They’re so afraid of making costly mistakes.”

With only so much money to spend, employers want to know that what they choose will have a positive return on investment. So, they wait to see what’s working for others. The problem with this approach is that, by the time they decide on an investment, the technology is likely already out of date, replaced by a new and improved version or concept.

If they don’t make choices at all, employers will be left behind. Investing in technologies and training in the supply chain is a must. Perhaps being a step behind works; being five steps behind will not.

CIFFA focuses on delivering Excellence through Education. Employees of CIFFA member firms, importers, exporters and those looking to start a new career in freight forwarding, benefit from industry leading education programs. Read more about our educational programs.

Failure of Canada’s Intermodal Transportation Network Demands Action

Yesterday CIFFA wrote a letter to the Honourable Marc Garneau, Minister of Transport and the Honourable François-Philippe Champagne, Minister of International Trade asking for the creation of an intermodal marine transportation strategy and escalated deployment of the National Trade Corridors Fund.

Today we are asking all CIFFA members to write to the ministers and we are asking that you send this eBulletin to all of your customers and ask them to write to the ministers. We have created a template letter with all of the names and email addresses so you and your customers need only download the letter onto your letterhead, fill in the blanks and send it.

Enough is enough. Intermodal cargo has not moved efficiently or acceptably in this country since the spring of 2017 and there is no end in sight to the extreme congestion, undue delays and unreliability of Canada’s intermodal movement of goods. The voice of cargo must finally be heard.

We would like to share here some of our concerns with the strategic and long-term future of Canada’s ports, railroads and intermodal movement of goods through the lens of some recent problem areas.

August 2017 – Present:

CN Rail terminal operations at Brampton Intermodal, Edmonton, Calgary and Montreal are severely congested resulting in service delays, exacerbating driver unrest and causing drayage operators to introduce new fees such as ‘wait time’ charges.

September 2017 – November 2017:

CN Rail terminal expansion at Prince Rupert caused on-dock dwell times at the port to spike up from a normal two or three days to two or three weeks in some cases.

October 2017 – Present:

On-dock container dwell times at Port of Prince Rupert and Port of Vancouver have crept up from normal average delays of +/- three days to averages now of + six or seven days. In some instances, containers are resting on the docks up to three weeks. And these ports are the supposed jewels in the crown of our Asia Pacific Gateway and Corridors.

January 2018 – Present:

Increased wait times and limited gate opening hours at the Port of Montreal, as reported by drivers, have caused many drayage operators to introduce wait time charges. Drivers are in short supply and many are unwilling to serve the port.

This untenable situation has been ongoing for months and there are no signs of improvement. The consequences to Canada’s traders, manufacturers, retailers and consumers are considerable. With no predictability in transit times, distribution and delivery costs skyrocket.

While some of the negative impacts of the failure of Canada’s intermodal network are outlined in our letter to the ministers, many of our members and their customers and non-members, particularly from the drayage community have provided additional insights, such as:

Lack of visibility to accurate Information: Has created unpredictability and unreliability impacting importers’ and exporters’ supply chains, making logistics planning impossible. Manufacturing lines shut down, export orders are cancelled, suppliers miss critical delivery deadlines, retailers have empty shelves, consumers will pay more.

Increased Cost – Hidden: Distribution companies, importers, retailers and 3PLs cannot schedule crews to work containers. On a normal basis, a company may schedule labour, trucks and facilities to handle ten containers a day, six days per week for ten weeks. What happens to that labour or those facilities or trucks when no containers arrive for three days and then six containers arrive the fourth day and then suddenly thirty arrive at the terminal the fifth day? With no predictability and no reliability, the costs of labour become unmanageable and distribution centres unworkable.

Increased Cost – Hidden: International freight forwarders, retailers, manufacturers facing two and three weeks’ delay carry additional and often crippling capital costs, cost of inventory, cost of receivables, cost of lost orders, cost of late inputs and cost of lost reputation.

Increased Cost – Fees: The drayage community, faced with increasing unrest from drivers, who are unwilling or unable to wait hours unpaid to access rail and port terminals have introduced wait time charges.

Increased Cost – Fees: Vessels bunch, storms create havoc and congestion builds often causing delays at terminals. As drivers line up in long lines, running out of hours of service, the demurrage and detention clock continues to tick.

Increased Cost – Hidden: Drivers are refusing to serve certain rail terminals as they cannot make a living wage once wait time is added to their run.

Increased Cost – Hidden: Finally, the stress on management and on customer service with in the international freight forwarder community is paying a toll. Canada’s supply chain companies cannot work effectively with extremely low margins with the inconsistency and service levels we have experienced since May 2018.

Canada, once seen as a golden child and contingent option to US ports for American cargo interests has single- handedly lost its reputation as being able to handle critical volume with consistency and professionalism. Publicly traded companies have made reference in their quarterly financial reports that the principle reason for not making their numbers and forecast was in part due to Canadian National Railway’s inability to provide reliable, consistent service. The same can be said for CN’s inability to deliver service on Canada’s west coast container ports.

This shameful situation puts Canada in a negative view internationally. The shine is off the jewels of the Asia Pacific Gateways at Ports of Vancouver and Prince Rupert and action must be taken to return our intermodal marine networks to their former glory. Please add your voice to the chorus by writing to your federal ministers.

eHBL Restart Date: Not Anytime Soon

eHBL Restart Date: Not Anytime Soon

Are you a business owner, attempting to make decisions around staffing, agency development, resource allocation?  Or perhaps you’re an operations manager trying to create process efficiencies or customer service enhancements?  Or perhaps you’re the IT manager wondering how you’ll schedule or integrate eHBL with the Canada Border Services Agency’s Single Window initiative or Integrated Import Declaration (IID).

In any event, it seems that not a day goes by without a question coming into the CIFFA Secretariat about eHBL and potential restart dates. What can we expect?  When will the program take off again? What is happening? The short answers, in reverse order: Nothing. Eventually. Not much in the short term.

Last week Julia Kuzeljevich, Paul Hughes and Ruth Snowden made the trek to chilly Ottawa to meet with senior management at the CBSA’s Commercial Policy division and with eHBL policy and project staff.

CBSA’s eHBL project is on hold and at this time, there is no restart date to announce.  We have been assured that the eHBL program is funded and will be completed.  However, we assume because so many deadlines have been missed, the eHBL systems fix – the infamous systems Change Request (CR) – has dropped so low on a priorities list of IT fixes within the Agency that it might be months before we even get a date.

Our best guess is that the six months of informed compliance leading up to mandatory eHBL might begin in Q4 of 2018.  We seriously doubt if the CBSA will get its act together before that. What a colossal mess.  Wasted energy.  Wasted human resources. Wasted good-will.  Wasted opportunity.  And the last is the most disappointing.  We had an opportunity to bring Canada’s antiquated import system into the digital age.  We had opportunities to dramatically reduce paper, to increase efficiency across the country, to be prepared for the upsurge in commercial imports into this country that we’re currently experiencing.  All wasted – for months and, for all we know, possibly years.

That said, CBSA’s dedicated eManifest staff have been very open in communicating with CIFFA and remain committed to examining potential paths, workarounds and fixes. The CBSA staff on the eHBL file are to be commended for continuing to get up every morning, go to work and try to deliver a solution.

CIFFA’s outreach thus far on eManifest has been tremendous, with ongoing communications, explanations, and recommendations for planning prior to and during planned implementation.

We’ve been on this file since 2010, clocked hundreds if not thousands of hours in meetings, and regularly kept members apprised of developments on the eHBL front. Even as late as May 2017 in our Director’s Blog, CBSA Work Arounds – Too Many eHBL System Fixes, Not Enough Fingers  we identified some of the many work arounds and system holes that the Agency needed to address.

At that time, CBSA was working on many work-arounds, band-aids and fixes, and the community was awaiting the official communication from the CBSA informing the entire community that the July 12, 2017 mandatory data filing date would indeed be pushed back by several months, giving some breathing space to get proper fixes in place.

Fast forward to 2018, and unfortunately, a “workable system that is supported by an adequate policy structure” remains an elusive concept.

CIFFA will continue to work with the CBSA and to communicate decisions and guidance to our members. In the meantime, eHBL works well for consolidations. If you can ‘turn it on’ for air or marine consolidations clearing out of CW type sufferance warehouses, go for it.  Members who have flipped even a partial switch are pleased with the results.  Mostly they’re pleased that they aren’t waiting hours and days at Longrooms across the country for paper to be stamped.

Piqued by the peak: air cargo faces tight capacity

Guest Blog By Julia Kuzeljevich

We’re in the midst of air cargo’s peak shipping season, and it’s left many logistics service providers “peaked”, not to mention piqued by the resulting mad rush, delays, and volatility.

Ecommerce volumes and a healthy global air transport industry are contributing to a phenomenon where it seems there are two distinct “seasons” and two “processes” to handle them.

“These are good times for the global air transport industry. The demand for air cargo is at its strongest level in over a decade,” said Alexandre de Juniac, IATA’s Director General and CEO, in a recent speech. Certainly asset-based carriers are benefiting from the upswing. Benefits to forwarders who are trying to provide service to customers in such a volatile market, however, are much less obvious.

Forget about forecasting-in many ways this has gone out the window as nobody knows what, when or how buyers are buying. For the first time ever, neither airlines nor forwarders had an understanding of what to expect this peak season – because importers and exporters are unable to advise their requirements more than a few hours/ days in advance.

Belly freight capacity is tight into Canada from most regions and there is virtually no freighter capacity. CIFFA forwarders advise that main-deck lift out of Asia is booking now for mid-January and customers who expect lift to be available before then are not being realistic.

Added to this unexpected spike in demand and to the limited lift created over the past few years of declining air freight, is an unprecedented volatility in rates. Customers can now expect that air freight quotations will be held for just hours, not days or weeks as was the norm. Decision-making around air cargo has become a pressure filled, stressful undertaking – where often there are simply no options.

And it may not end with the arrival of Christmas. As an IATA survey to airline execs revealed this fall, over the next 12 months, we can continue to expect robust demand for air freight. The cargo business continues to benefit from a strong cyclical upturn in volumes, with some recovery in yields. Volumes are expected to grow by 4.5% in 2018 (down from the 9.3% growth of 2017). The boost to cargo volumes in 2017 was a result of companies needing to restock inventories quickly to meet unexpectedly strong demand. This led cargo volumes to grow at twice the pace of the expansion in world trade (4.3%). Cargo yields are expected to improve by 4.0% in 2018 (slower than the 5.0% in 2017).

The growth of e-commerce is expected to support continued momentum in the cargo business beyond the rate of expansion of world trade in 2018. On December 11, online pricing platform Freightos reported that airfreight in Europe had reached full capacity two weeks prior. Bad weather was compounding the situation across Europe with early snow impacting airport operations. Earlier this week Brussels Airport for example grounded freighters, allowing only passenger flights to move, due to extreme snow conditions on the ground.

Air cargo is expected to remain congested throughout the holidays and well into January. If relief comes at all, be prepared-it’s not expected to last long as the effect of Chinese New Year in mid-February hits the air cargo market.

A Mountain of Paper – CBSA Taking Steps to Reduce Stamping Delays at CBSA Longroom Port 395 Montreal

The Canada Border Services Agency (CBSA) at Montreal Port 395 is facing the same pressures as everyone else in the inbound movement of goods these days, plus a few problems unique to this specific time and place.  Members advise delays of +4 working days (+ weekend days) for the CBSA to stamp and return re-manifest documents at the Montreal Longroom. The Agency advises that although delays did spike up to 3 days earlier this week, times have reduced somewhat but are still much longer than desired.  The CBSA is acutely aware of the problem and is taking steps to address.

First, what has caused the longer than usual time to stamp and return documents?

Let’s consider what happens when you mix an extended and busy peak season, with the almost total failure of eHBL, refugees and normal human resource issues.

For the past several weeks the CBSA has been dealing with an influx of refugees at Canadian borders and experienced officers and clerical staff from Montreal have been sent to help out at Lacolle.  This has caused a shortage of experienced staff in the commercial area. Then, we must remember that it is September and time for the full-time temporary summer -student clerks to go back to school, leaving their desks in the Longroom empty, with new hires and part-time clerks taking their place. There is a learning curve to any job and the complaints from some members that manifests are being rejected for unknown reasons might be attributable to these new employees on the desk.

Finally, the CBSA is dealing with a huge surge in requests for stamping.  There are two reasons for this upsurge.

As we all know, we’re in the middle of a very busy, high volume, unanticipated, long peak season.  Volumes are up in both air and marine.

Add to this the  decision  by the CBSA not to allow eHBL filing for back-to-back shipments destined to a primary warehouse and somehow that has caused a huge reduction in all eHBL data filing.  It is as if we have made no progress over the past year and we are back where we started – even though the eHBL works very well for consolidations destined to a CW sufferance warehouse.

NVOCC and consolidators who did implement eHBL are frustrated because their customers – the forwarders in the tier upon tier within the co-load – have not implemented eHBL.  When one or two forwarders fail to file eHBL, consolidators are forced to run dual filings and paper rules.

For whatever reason eHBL is an almost total failure right now.  Probably because origin agents won’t maintain two systems, one for eHBL filing for consolidations and one for ACI S10 filing of data for single / back-to-back shipments, many forwarders have switched back to paper manifests. This is truly a shame, because eHBL works so well for consolidations, and THERE IS NO PAPER REMANIFEST STAMPING REQUIRED for a consolidation where eHBL data was filed.  And, because the back-to-back / single shipment clears on the primary 9000 cargo control number, those shipments don’t require stamping.

However, it seems that eHBL filing for consolidations has gone by the wayside and a deluge of paper has built up at the Longroom counter in Montreal – and Vancouver and everywhere across the country.

If Canadian forwarders could somehow insist that eHBL be filed for their consolidations, everyone would benefit and the CBSA might not have stacks of paper up to the ceiling.  Maybe it is time for the CBSA to put into place a mandatory date for eHBL filing on consolidations. That would force Canadian forwarders and the rest of the world to switch consolidations to eHBL and to stay there.

The CBSA in Montreal is asking its officers and clerks to work overtime to clear the backlogs and try to get back to a 24-hour turn-around time on document stamping.  We’re asking forwarders to switch to eHBL for their consolidations and get rid of paper re-manifests.

Importers face long delays at Prince Rupert and Vancouver’s Deltaport as containers sit for 6 or 7 or 10 days before being loaded to rail.  Train schedules are disrupted, with trains expected to arrive at inland terminals on a Thursday or Friday pushed back to Saturday and Sunday, adding extra days to the transit and creating stress as carters try to get containers out before storage begins. Drayage operators wait hours at rail terminals in Toronto and Montreal to retrieve cargo.  Now it seems added delays in stamping at CBSA Longrooms is adding more stress into the system.

These all combine to increasing frustration, increasing costs, and strain on importers’ supply chains.  This has been a long, tough peak season and there is no end in sight for the next several weeks although the CBSA in Montreal is doing what it can to relieve the stress of its delays.

Off-Peak Potential: A Targeted Objective in the Region of Peel

A Guest Blog by Martin Kelly

The Region of Peel has recently announced an Off-Peak Delivery (OPD) pilot project and they are looking for business participation. The strategy is to keep it simple for shippers/receivers of goods through, for example, selecting logical pieces of full truck/container load business and shifting their current peak hours haulage to what would be off-peak (defined as 7 pm to 6 am). This could be specific customers or suppliers or specific lanes–it could simply be one major lane! The idea is to shift reasonable volumes to off-peak.

CIFFA members should note that although the pilot would accept a wide range of possibilities in the entire GTHA there is an objective to reduce congestion around Toronto’s Pearson International Airport and vicinity

We all have experienced congestion not only in Peel Region but right across the GTHA. Action is needed to put innovative ideas into motion in order to mitigate congestion. This OPD pilot is one concrete initiative to pilot changes, learn about the outcomes, and inform how to continue long term planning of the shared goods movement network. In almost every case study in cities around the world, virtually all had resounding success with OPD and observed cost savings and time savings related to travel and delivery times. Some case studies have also observed emissions reductions and benefits related to sustainability. The majority of these trials led to implementing long term strategies related to OPD. Organizations that participate in Peel’s first pilot project have the opportunity to participate in what will likely be a high profile pilot project.

Should businesses choose to participate, Peel staff are committed to working with you to plan customized OPD pilot plans, offer performance measurement resources, and recognize your company’s pilot achievements. All of this is a clear indication of how serious a lead Peel is taking!

Peel Region is leading the way for what will become more of a province-wide set of initiatives in goods movement. There are advantages for your early participation and championing this initiative, along with opportunities for real collaboration with like-minded businesses.

In June 2017, Peel Region, Partners in Project Green, and me hosted a webinar to discuss the OPD Pilot Project and elicit business interest. You can find the webinar here:

Peel’s Regional Council is committed to improving goods movement for the 2015-2018 Term of Council. The implementation of an OPD pilot project is one initiative outlined in the Peel Region Goods Movement Strategic Plan 2017-2021.

Peel’s goods movement planning is led by the Peel Goods Movement Task Force which is comprised of business champions in Peel Region who understand the importance of goods movement. The Task Force is now into its second five (5) year fully approved and funded strategic plan and it can be found at


Peel Region is open to discussing what could best work for your company in this OPD Pilot Project and we urge you to please contact Elizabeth Bang, Principal Planner in Transportation Systems Planning, at 905-791-7800, extension 4694 or

Please also feel free to contact me, Martin Kelly, a logistics consultant who has over 40 years in the industry.


Martin Kelly

MRK Innovations


Looking “down the line” on new ocean alliances

Looking “down the line” on new ocean alliances

By Julia Kuzeljevich

Three newly formed ocean shipping alliances officially took effect at the beginning of April. These alliances will control 90% of shipments on major global trade routes.

More cargo on ships that will make fewer stops is the plan-what could some of the implications be downstream?  Everyone must be prepared for impacts at Canadian ports.

According to a recent editorial in Lloyd’s Loading List, the three mega alliances are dropping 380 direct routes and adding over 330 new direct routes to their networks in the Asia-Europe, trans-Atlantic, and trans-Pacific trades. This will open up many new port-pair options and routes.

For the OCEAN and THE alliances routes, compared to the alliance services their member carriers offered before April, for the trans-Atlantic trade routes, 47% of routes have a faster transit time and for Asia-Europe trade routes, 60% of routes have a faster transit time.

The new alliances have also dropped some ports from their services, which is one reason that the transit times overall are becoming shorter.

About 37% of the trans-Atlantic trade routes and 51% of the Asia-Europe trade routes will have an average transit time difference of three or more days compared to the routes offered before April. This means that over a third of the routes offered by the OCEAN and THE alliance members will be offering much shorter or longer options for their routes.

As the carriers and alliances offer new ports, their transshipment options grow as well. In addition to searching direct port pairs and published transshipment routes, there is the possibility of new transshipment combinations that may be faster or more reliable.

There is no doubt that the new alliances are creating the need for a lot of info-gathering and restructuring across the entire supply chain. The complexities are staggering.  For example, carriers may be keeping a port in the alliance rotation, but changing the terminal they utilize at that port. This will impact on-dock operations and movement to rail. Railroads will be required to do extensive planning to accommodate any switches in terminal. It also means that imports may be handled through a different terminal with implications for eHBL filings.

In a statement from CN on the new alliances, Dan Bresolin, Assistant Vice President, International Sales & Marketing, Intermodal, said that over the past few months, CN has been gathering information from the ocean carriers through face to face meetings both overseas and in North America to prepare for the restructuring of their vessel-sharing agreements (VSA) and transition from the old alliances to the new networks.

“Through this collaboration, and in conjunction with our supply chain partners and stakeholders, we have developed a good picture of what the aggregate volumes will look like at each terminal on all three coasts that CN serves,” he said.

This will involve building a robust train plan to move the volumes discharging and loading at all CN gateway ports through weekly volume forecasts received from the ocean carriers.

Through the transition period, the railway aims to keep dwell times as low as possible collaborating where necessary with Vancouver Port operators to truck containers to CN’s Domestic Terminal.

Managing risk

In 2017, diversifying carrier selection, not only by the carriers and alliances, but also by the vessel operator for critical routes, is considered a wise move.

Managing risk may also mean contracting across alliances, not carriers. Because carriers share vessels within their alliances, shipping with two different carriers is not necessarily a guarantee that you’re shipping on two different vessels.

The shipping alliances may appear to wield the power, but partnerships can build leverage. Leading up to the alliances’ launch, many ports have been investing in infrastructure improvements to prepare for bigger ships. Some have made steps to coordinate, to look at synergies. Hopefully, this provides an opportunity for true collaboration and transparency to emerge in the relationship between logistics services providers, carriers and clients.

There are still a number of hurdles to consider: a joint survey by Drewry and the European Shippers’ Council published in April asked 189 shippers and 82 freight forwarders and non-vessel-operating common carriers how satisfied they were with services provided by ocean carriers in 2016.

On a scale of 1 (very dissatisfied) to 5 (very satisfied), customers on average did not rate carriers higher than 3.3 for any of the 16 service attributes, the survey showed.

Respondents were mostly dissatisfied with carrier financial stability, the quality of customer service, and reliability of booking/cargo shipped as booked.

On the flip side, respondents were most satisfied with the price of services, accurate documentation and the quality of equipment (containers).
Nearly 80 percent feel carrier financial stability is worse than a year earlier, and more than half say the range of different available carriers for them is worse.

(Note: as we were writing this blog, Yang Ming had just issued an update on its financial status to mitigate shipper and service provider concerns after the suspension of its shares on the Taiwan Stock Exchange the week previous.

 The carrier, part of THE Alliance, has been under considerable pressure to clarify its decision to temporarily suspend share dealing, amid fears the troubled Taiwanese carrier could follow Hanjin Shipping into bankruptcy.)
The key message from the survey was that with more complex supply chains, partnership is of key importance.

“Shippers and forwarders clearly see the necessity for the carrier industry to invest in IT and to balance the needs for cost competitiveness and for more predictability and reliability,” said Philip Damas, head of Drewry’s logistics practice.

Julia Kuzeljevich is the Public Affairs Manager at CIFFA

Prepare Now – CBSA Planning to Cancel eHBL for Back-to-Back Shipments Clearing from a Primary Warehouse

Due to security and program integrity concerns, the Canada Border Services Agency (CBSA) has determined that until systems enhancements are in place to fully support eManifest program integrity, an interim process to address electronic house bills is necessary.  The CBSA is presently drafting a new Customs Notice that will ‘stop’ allowing back-to-back/ single shipments filed as electronic house bills to release from primary warehouses.  This ‘suspension of eHBL for back-to-back/ single shipments’ will be in place during the interim period announced in Customs Notice 17-15.

The new Customs Notice will state “All electronically transmitted house bills must be destined to a CW warehouse.”

Essentially this means that the CBSA will prohibit eHBL back-to-back/ single shipments from clearing from a primary warehouse.  We are ‘rolling back the clock’ to pre-November 2016.

Forwarders must revert to filing ACI S10 Supplementary data and clearing on the primary carrier cargo control number for all back-to-back/ single shipments clearing from a primary warehouse.  The sooner forwarders make the change the better, to ensure marine back-to-back eHBL filings don’t have to be cancelled while enroute when this new rule comes into effect.

There are several reasons that the CBSA must take this step.  First and foremost is lack of security with the Deconsolidation Notice and 8000 cargo control number (CCN) release requests from primary warehouses.  In our January blog Don’t File eHBL on Back-to-Back Shipments: Liability Too Great, we outlined the reasons why filing eHBL for back-to-back/ single shipments was risky for forwarders.  Well, that risk has proved too great for the CBSA so they are rolling back eHBL for back-to-back/ single shipments clearing from primary (terminal, rail, airline) warehouses. If you are one of the forwarders that managed to control your risks and started filing eHBL for back-to-back shipments, you have more work ahead to change back.

The other problem is that the business relationship for cargo reporting and arriving is between the primary warehouse and their customer, the carrier, not with the forwarder. As a result, the primary warehouses have no visibility to the freight forwarder 8000 CCNs, their systems don’t recognize the 8000 releases, and so they are drowning in paper.  Also, currently back-to-back release requests on 8000 CCNs at the primary warehouse must be on RMD as the primary warehouses generally cannot ‘arrive’ an 8000 CCN, which is causing considerable problems for everyone.

The Good News:

The good news is that back-to-back/ single shipments will revert to clearing on the 9000 CCN.  This means that there is no Deconsolidation Notice and no paper required at the terminal / railroad.  This also means that back-to-back shipments can clear on PARS in the same timeframes as any other 9000 release request.

The Bad News:

More work and more changes for forwarders. Forwarders must change their processes and communicate with origin agents as soon as possible to make the switch back to ACI filing for back-to-back shipments.  Everyone must revert back to ‘pre-November 2016’ procedures for back-to-back shipments.

It will take the CBSA at least a couple of weeks to finalize their Customs Notice, get it translated and up on their website.  Their notice period may be relatively short. The situation at the railroad terminals is critical and we’re heading into peak season.

We urge everyone to get out ahead of this change and revert back to filing ACI Supplementary S10 data and clearing on the primary 9000 as soon as possible.  Forwarders do not want to be caught with back-to-back eHBLs on the water that would have to be cancelled.

Start now.

PS: Remember, a back-to-back shipment is a ‘single’ shipment where one primary carrier bill of lading or airway bill is consigned to the freight forwarder and one housebill is consigned to the importer.  Canadian freight forwarders manage thousands and thousands of these inbound transactions every year.


Revised and reposted June 30, 2017

Weighing the risks in your perishables supply chain-a knowledgeable forwarder can help

By Julia Kuzeljevich, Public Affairs Manager, CIFFA

Canada’s Food Inspection agency has just wrapped public consultation on the proposed Safe Food for Canadians Regulations.

The consultation, which closed April 21, was an opportunity for all Canadians to have their say on the proposed regulations. The CFIA is now in the process of reviewing over 1,300 submissions to finalize the regulations and prepare for implementation, a process that’s expected to take several months.

Final publication in the Canada Gazette, Part II is anticipated in Spring 2018.

In early May CIFFA Executive Director Ruth Snowden spoke at the SIAL Canada Food and Beverage trade show at Toronto’s Enercare Centre. SIAL is key to the Canadian agri-food industry, and acts as entryway to the US and international markets.

Snowden participated in a panel discussion about the perishable supply chain, along with Keith Mussar, Vice President of Regulatory Affairs for the Canadian Association of Importers and Exporters, and David Clark, Senior Director, Industry Relations at GS1 Canada.

The Safe Food for Canadians Act is expected to bring tremendous change over the next 12-18 months with the government streamlining its compliance requirements, regulatory and consolidation amendments under the Act. Three pillars will govern safe food policy: licensing, preventative controls and traceability. Having protocols in place for recall and traceability will become mandatory.

This traceability will be of paramount importance in the supply chain especially where it brings visibility and transparency to all aspects of transportation.

The perishables supply chain is growing by leaps and bounds. There are so many risks for product damage: a good logistics service provider knows the breaks in the chain: with perishables sometimes it’s not obvious that there has been physical damage to the product.

Ground handling in air cargo can be an issue, as is the impact of the reduction in freighter capacity. On the marine side, there are the effects of heave and yaw to consider; in rail, shunting of trains. Weather, port changes, the availability of plugs at terminals, and delays because of regulatory requirements like container inspections all add pressure to the perishables supply chain.

The grocery landscape is ever-evolving. We have more access to content of varying types than ever before. But accuracy is paramount and mislabeled products make companies lose consumers in the long run. GS1 identifiers can capture extensive information, noted GS1’s David Clark. With increased regulation to come we need to effectively communicate recalls on common platforms, especially in instances requiring immediate traceability of the product.

In 2018 the regulatory framework will change under The Safe Foods for Canadians Act, which will come into effect over the next 12-18 months.

The new regulations will focus around three pillars: licensing, new food safety control requirements, and regulating business procedures that ensure the safety of food. These procedures must also be in place around packaging. There will also be increased attention around product recall and traceability, which will eventually be mandatory.

What are the implications for trade? If you’re a US company exporting products to Canada, and you’re a non-resident importer, you will be able to hold a license to import product if that product originates in the US.

If you’re a non-resident importer who imports from a third country you will not be eligible to hold a license and you’ll be required to change your supply chain if you want to continue to access the Canadian market, with some exceptions for agri-food, and manufactured food additives.

The new regulations will see a world where evidence must be provided that business decisions and protocols meet the regulations.

Regulations don’t however take the place of Government of Canada inspections.

The US also going through food safety modernization-they have distinctly different requirements but are aiming for the same outcome.

The key elements of the proposed regulations are based on international food safety best practices, so for example having preventive controls and traceability systems in place helps to protect your customers and your reputation. Due diligence across the chain will go a long way, as will having a logistics service provider who knows the ins and outs of perishables transportation.

CBSA Work Arounds: Too Many eHBL System Holes, Not Enough Fingers

One can’t help but think of a little Dutch boy in blue cap and short pants, lying on the ground with his finger in a hole in the dyke holding back the flood waters. In this story, however, it is dozens of IT staffers with metaphorical fingers in dozens and dozens of very real holes trying to fill the gaps in the Canada Border Services Agency’s eHBL system. There are so many holes in this system and the work-arounds are so cumbersome that there simply are not enough fingers to go around.

The CBSA is working on many work-arounds, band-aids and fixes – some policy related, some systems related and all designed to help get the eHBL program back on track. It is going to take quite a while.  We are awaiting the official communication from the CBSA that will inform the entire community that the July 12, 2017 date for eHBL mandatory data filing will be pushed back by several months, giving some breathing space to get proper fixes in place. We have been assured that monetary penalties will not be implemented until the CBSA stands up a workable system that is supported by an adequate policy structure. Neither of which we have at the moment.

Where to start?

Late last week the CBSA issued TCC17-109 – Arrival of back to back shipments at inland warehouses which CIFFA shared in its May 15th eBulletin. The eBulletin points out some flaws of the solution. It is limited to freight forwarders with access to the Warehouse Arrival Certification Message (WACM), think organizations that also operate CW sufferance warehouses. Any forwarder would also need the human resources to do these extra WACM ‘arrivals’ and the time – for example, over the weekend when cargo arrives at railyards and terminals across the country. For all its faults, however, this ‘arrivals’ solution at least gives some forwarders an option to help sometimes with the huge hole that has been created in the inbound process by the problems with back-to-back shipments in eHBL.

Several members contacted us to express frustration about this ‘finger in the dyke’ fix that is certainly sub-optimal and is just one of many such fixes. We share below a message received from a subject matter expert at a CIFFA member forwarding company who suggests a more workable workaround than that outlined in TCC17-109.

“There is a known issue with the eManifest HBL system: The Warehouse Arrival Certification Message (WACM) of a primary Cargo Control Number (CCN) at the inland/rail terminal does not cascade down to house bill(s) below which are declared with the same sub location, as was intended / documented in the original eManifest HBL notices design.  As a result, there is nothing that arrives the underlying 8000 series CCNs on Full Container Load (FCL) / back-to-back shipments clearing at a rail terminal.
The solution / work-around offered to by CBSA in TCC 17-109 to compensate for this, is to have forwarders send a WACM themselves for their 8000 series CCNs at the terminal to arrive these.
This work-around actually exploits another bug of CBSA’s RNS/WACM system, which is that a CW warehouse can WACM a CCN even though that CCN is declared at a different sub-location than the warehouse doing the WACM – which CBSA have acknowledged is another bug on their list of issues to fix. How does this make sense? CBSA are suggesting to exploit a known system issue, as a work-around to fix another system issue.

But most importantly: the only parties who have (and should have) capability to arrive (WACM) should be terminals / warehouses that are registered and that hold a sub-location code. Does CBSA not realize that most forwarders are not set up or tested for RNS WACM? (The only ones that are would be the ones who also have a warehouse with a CBSA-assigned warehouse sub-location code).

Really, the most practical work-around for this issue (that WACM of a primary CCN at the inland terminal does not cascade down to the 8000 series CCN below) for now, is that on Full Container Load (FCL) / back-to-back shipments clearing at rail terminal, the forwarder should instruct the Customs brokers to track the arrival of containers at the destination terminal. Once ‘known’ to be arrived, then the Customs broker submits a post-arrival RMD release request. This post-arrival release request then serves to automatically ‘arrive’ the 8000 CCN and trigger the release. Of course, this means that these cannot be cleared under the PARS service option (where PARS relies on the arrival of the CCN to trigger release).


Instead of CBSA putting out these instructions / work-arounds which are not thoroughly thought out or even practical, CBSA need to focus on fixing the system problem at the root: WACM of a CCN at a given sub-location should cascade to all related CCNs below that CCN whose destination sub-location is the same as the CCN above/ primary CCN”

Another member, whose organization operates a CW warehouse, shared his experience with ‘arriving’ back-to-backs.  “Once again because the CBSA has built a deficiency into their new eHBL system, forwarders have to do all this additional work.  In order for the 8000 release to be triggered on back-to-backs at CN and CP terminals, the cargo must be re-arrived … at times twice, for reasons unknown. I’ve done about 30 arrivals and it’s quite basic, it’s 3 pieces of information per container and you hit send … but then you have to wait for the release, then match it to the container, then send out the delivery or pick up information to the correct party because that can’t be sent in advance anymore. Now that part is a lot of work.”

So, with TCC17-109 we have a temporary finger in a temporary hole in a complex system filled with holes.  Thanks to the members who shared their experiences and suggestion above – and we are assured, the CBSA is working towards more permanent solutions.

Ruth Snowden is Executive Director of CIFFA. 

Looking “down the line” on new ocean alliances

Looking “down the line” on new ocean alliances

By Julia Kuzeljevich

Three newly formed ocean shipping alliances officially took effect at the beginning of April. These alliances will control 90% of shipments on major global trade routes.

More cargo on ships that will make fewer stops is the plan-what could some of the implications be downstream?  Everyone must be prepared for impacts at Canadian ports.

According to a recent editorial in Lloyd’s Loading List, the three mega alliances are dropping 380 direct routes and adding over 330 new direct routes to their networks in the Asia-Europe, trans-Atlantic, and trans-Pacific trades. This will open up many new port-pair options and routes.

For the OCEAN and THE alliances routes, compared to the alliance services their member carriers offered before April, for the trans-Atlantic trade routes, 47% of routes have a faster transit time and for Asia-Europe trade routes, 60% of routes have a faster transit time.

The new alliances have also dropped some ports from their services, which is one reason that the transit times overall are becoming shorter.

About 37% of the trans-Atlantic trade routes and 51% of the Asia-Europe trade routes will have an average transit time difference of three or more days compared to the routes offered before April. This means that over a third of the routes offered by the OCEAN and THE alliance members will be offering much shorter or longer options for their routes.

As the carriers and alliances offer new ports, their transshipment options grow as well. In addition to searching direct port pairs and published transshipment routes, there is the possibility of new transshipment combinations that may be faster or more reliable.

There is no doubt that the new alliances are creating the need for a lot of info-gathering and restructuring across the entire supply chain. The complexities are staggering.  For example, carriers may be keeping a port in the alliance rotation, but changing the terminal they utilize at that port. This will impact on-dock operations and movement to rail. Railroads will be required to do extensive planning to accommodate any switches in terminal. It also means that imports may be handled through a different terminal with implications for eHBL filings.

In a statement from CN on the new alliances, Dan Bresolin, Assistant Vice President, International Sales & Marketing, Intermodal, said that over the past few months, CN has been gathering information from the ocean carriers through face to face meetings both overseas and in North America to prepare for the restructuring of their vessel-sharing agreements (VSA) and transition from the old alliances to the new networks.

“Through this collaboration, and in conjunction with our supply chain partners and stakeholders, we have developed a good picture of what the aggregate volumes will look like at each terminal on all three coasts that CN serves,” he said.

This will involve building a robust train plan to move the volumes discharging and loading at all CN gateway ports through weekly volume forecasts received from the ocean carriers.

Through the transition period, the railway aims to keep dwell times as low as possible collaborating where necessary with Vancouver Port operators to truck containers to CN’s Domestic Terminal.

Managing risk

In 2017, diversifying carrier selection, not only by the carriers and alliances, but also by the vessel operator for critical routes, is considered a wise move.

Managing risk may also mean contracting across alliances, not carriers. Because carriers share vessels within their alliances, shipping with two different carriers is not necessarily a guarantee that you’re shipping on two different vessels.

The shipping alliances may appear to wield the power, but partnerships can build leverage. Leading up to the alliances’ launch, many ports have been investing in infrastructure improvements to prepare for bigger ships. Some have made steps to coordinate, to look at synergies. Hopefully, this provides an opportunity for true collaboration and transparency to emerge in the relationship between logistics services providers, carriers and clients.

There are still a number of hurdles to consider: a joint survey by Drewry and the European Shippers’ Council published in April asked 189 shippers and 82 freight forwarders and non-vessel-operating common carriers how satisfied they were with services provided by ocean carriers in 2016.

On a scale of 1 (very dissatisfied) to 5 (very satisfied), customers on average did not rate carriers higher than 3.3 for any of the 16 service attributes, the survey showed.

Respondents were mostly dissatisfied with carrier financial stability, the quality of customer service, and reliability of booking/cargo shipped as booked.

On the flip side, respondents were most satisfied with the price of services, accurate documentation and the quality of equipment (containers).
Nearly 80 percent feel carrier financial stability is worse than a year earlier, and more than half say the range of different available carriers for them is worse.

(Note: as we were writing this blog, Yang Ming had just issued an update on its financial status to mitigate shipper and service provider concerns after the suspension of its shares on the Taiwan Stock Exchange the week previous.

 The carrier, part of THE Alliance, has been under considerable pressure to clarify its decision to temporarily suspend share dealing, amid fears the troubled Taiwanese carrier could follow Hanjin Shipping into bankruptcy.)
The key message from the survey was that with more complex supply chains, partnership is of key importance.

“Shippers and forwarders clearly see the necessity for the carrier industry to invest in IT and to balance the needs for cost competitiveness and for more predictability and reliability,” said Philip Damas, head of Drewry’s logistics practice.

Julia Kuzeljevich is the Public Affairs Manager at CIFFA

Marine carrier sub-location code data a key eHBL dependency

The Canada Border Services Agency is working to improve the eHBL/ eManifest implementation presently underway.  One significant cause of problems with the Deconsolidation Notice is that some ocean carriers are not filing the correct “destination sub-loc code” on their carrier ACI filings. Although the sub-loc code is a required element for the carrier’s ACI transmission, the language in the Marine ECCRD was not clear, and the CBSA has not exercised a rigorous compliance for several years.

When CN and CP implemented the Deconsolidation Notices last fall, everyone realized that without that sub-location code, the terminal/primary warehouse cannot “arrive” the cargo with a WACM. Without the WACM, releases don’t flow and cargo doesn’t move — until paper is submitted.

The CBSA recognizes that compliance on this data element by the ocean carriers is a critical dependency for eHBL implementation. If you are using a carrier that is not compliant, please direct them to the new CBSA website information — which reiterates officially that this data element is required.

Also, let carriers know that the Marine ECCRD has been updated and translated and is pending final review. If the carrier has any doubt that this is a required data element, the revised ECCRD will reiterate the message on the CBSA website. The new document is under final review and will be available shortly.

The CBSA has also drafted reminder letters to all registered marine 9000 series-carriers that will be distributed shortly. Finally, the D-memoranda are being updated.

It has become critically important that carriers supply this sub-location code, and forwarders are encouraged to tell their carrier suppliers that it is not an option. One would expect that, once the CBSA has updated, corrected and informed the carriers of the requirement, non-compliant carriers will face compliance action. (This article appeared in the March 6th, 2017 member only eBulletin)

Don’t File eHBL on Back-to-Back Shipments: Liability Too Great

Container yard

Don’t File eHBL on Back-to-Back Shipments: Liability Too Great

In the December 19, 2016 eBulletin CIFFA issued guidance to its members to ‘Stop Filing eHBL on Back-to-Back Shipments: Liability Too Great’.  The situation on the ground has not changed and is not expected to change in the near future.  The liability is still too great and forwarders are urged to stop filing eHBL for those shipments.

Remember, a back-to-back shipment is a ‘single’ shipment where one primary carrier bill of lading or airway bill is consigned to the freight forwarder and one housebill is consigned to the importer.  Canadian freight forwarders manage thousands and thousands of these inbound transactions every year.

The problem is that a container can get delivered before it is released from Customs. (Or an airfreight shipment, but containers are far riskier.)  The risk is also greatest when the FCL or MAWB single is clearing from the primary terminalA back-to-back housebill on housebill inside a consolidation does not face the same risks as it clears from a CW warehouse, not a primary warehouse: control of delivery is easier from a CW sufferance warehouse.

What could go wrong you might ask? 

A container of fireworks was loaded in China, headed for Canada. (Yes, fireworks.) The Chinese non-bonded foreign forwarder filed eHBL data under its 8000 carrier code, without advising the Canadian consignee forwarder that it had done so.  The Canadian forwarder received the 9000 carrier’s import advice and passed the 9000 CCN on to the Canadian customs broker to clear. 

Concurrently, the container arrived and moved inland to the rail terminal.  The rail terminal operator received the Deconsolidation Notice and updated its system.  The importer sent in a trucker, retrieved the container, took it back to its location and unloaded the fireworks.

While this was happening, the customs broker received a reject notice because the entry should have been made on the 8000 cargo control number (CCN) and not the 9000 CCN. And, the container was called for examination – on the 8000 eHBL CCN.  But, it had already been delivered.  Gosh, you say. That’s a problem – delivered before release and without being examined.

The essential issue is that terminals update their systems from the automatic EDI D4 Deconsolidation Notice — or from the validated paper, as per CN16-20, as “Released” or “Re-manifested.” Drivers can then pick up the container – which may or may NOT be acquitted.

If you have containers that are already inbound on an eHBL filing, be vigilant. It is possible that the EDI D4 Notice will go automatically to the primary terminal and the container can easily be picked up and delivered without proper customs clearance. If the eHBL 8000 CCN is yours, you are on the hook for duties, taxes and AMPs.

The only way we know of at this time to keep some control is not to issue the pick-up number to the importer / trucker until after the goods have been customs released and you have the acquittal. That, of course, only works at terminal where there is a pick-up order system in place.

A much better solution is to stop filing eHBL on back-to-back containers until this is fixed.  And instruct your agents that you will refuse to handle these single shipments if an eHBL is filed overseas.  Back-to-back / single shipments should revert to ACI Supplementary data filings and clear on the 9000 CCN just as you have done in the past.  It is regressive, but it is the only safe way.  Until the CBSA comes up with a solution to ensure cargo moves securely, don’t file eHBL for single shipments.  It is too risky.

CBSA Changes the Game in Mid-Play with Foreign Bonded Freight Forwarders


On December 6th the Canada Border Services Agency (CBSA) posted Customs Notice CN16-29.  One of many Customs Notices released over the past few months by the CBSA as eHBL / eManifest bogs down in a quagmire of implementation challenges, this one could have significant impacts on Canadian freight forwarders.

With a stroke of a pen, the CBSA has granted non-resident freight forwarders the same rights and privileges to obtain a bond and conduct business in Canada as Canadian resident freight forwarders.  Previously freight forwarders were required to be physically located in Canada to be eligible to apply for a bonded freight forwarder carrier code. This requirement has been amended to allow freight forwarders who are located outside of Canada to apply for a bonded freight forwarder carrier code.”

It seems that the CBSA received a written legal challenge to its original policy that only Canadian resident companies could apply for and receive a bonded 8000 carrier code.  And so, the policy was changed.

Not a big deal you think?  Think again.

Since 2008 the Canadian international freight forwarder community has been sitting at the table with the CBSA on the design and development of the eHBL portion of eManifest.  And, we have conducted countless meetings, workshops, road-shows and webinars with the CBSA setting the rules in its policies and regulations and IT systems – all in the name of helping forwarders prepare for the new reality of eHBL.

To change the rules at this stage of the game is not playing fair.  Every Canadian forwarder has agreed new service arrangements for transmitting eHBL data, established operational procedures, implemented training, re-organized workforces and drafted new agency agreements with overseas agents – all based on the premise that only a Canadian bonded freight forwarder could move unreleased goods.  Now, that all changes.  Now, every Canadian freight forwarder will need to spend more management hours and more costs reaching out to every agent and ensuring everybody knows who will file the eHBL and whose bonded 8000 carrier code will be used

Un-level Playing Field

Thousands of non-bonded agents in virtually every country of the world file ACI supplementary data today.  And, the ecommerce service providers in those countries who charge them monthly and transactional fees have, apparently, no intention of losing that revenue.  So, all of a sudden, those agents can apply for a bond and move unreleased goods around the country.

What happens to the Canadian forwarder who has invested thousands of dollars and hundreds of management hours in this new program?  What about the Canadian freight forwarders who are today facing huge implementation challenges?  It is the Canadian forwarders that have eHBL air shipments stuck in limbo for three weeks because the CBSA operations guy at the counter doesn’t know what paper to stamp. It is the Canadian freight forwarder running paper to the longroom for validation because terminals and airlines don’t have D4 Notices.  And because D4 Notices aren’t working yet anyway.

These are the companies that have borne and continue to bear the cost of an ugly eHBL implementation.  And now foreign forwarders can reap the benefits.  How is that fair play?

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


CIFFA eHBL Frequently Asked Questions has dozens of detailed questions and answers, sorted by category.


The CBSA is available at:



Enabling Innovative Supply Chain Disruptors

fiata-logoGuest Blog by Gary Vince, President , CIFFA board of directors

While this title may seem slightly counter intuitive it is actually a theme that the logistics community needs to adopt very quickly! Having just returned from the annual FIATA congress in Ireland I am now convinced that the future of our industry hinges upon us embracing innovation and technology.

The dominant theme throughout the FIATA conference this year was “e-commerce” and how e-commerce will both enable and disrupt our supply chains. The e-commerce market size as, quoted during the conference, in 2015 was 181 billion euros; by 2019 this is expected to grow to 350 billion euros. However, it was clearly pointed out that while e-commerce facilitates speed of purchase, logistics and the last mile delivery continues to be the largest challenge.

Some of these logistical constraints include regulatory detractors that still exist in many countries and continues to hamper the overall e-com value proposition. This was made clearly evident by the many presentations around the WTO Trade Facilitation Agreement which is still in the ratification stage in many countries. This agreement, once ratified, will help clear some of the regulatory e-com roadblocks in many countries.

So what can we as Freight Forwarding Logisticians due to facilitate innovation? I would encourage everyone to embrace technology and take time, every day, to look for technology enablers to help improve our processes and service delivery. Never assume that something is out of reach or not feasible, just look at one of the newest technology enabler/disruptor 3D printing. Companies like Amazon are moving forward at light speed in terms of patent pending this technology through the new Amazon on the Fly concept.

Even companies who are not in the logistics business such as Mercedes Benz in partnership with the startup company Matternet are looking to further e-com by enabling Drone technology and on demand delivery services.

So perhaps the idea of “enabling supply chain disruptors” is not as counter intuitive as it appears? Commit to change knowing the future is now.

Guest blogger Gary Vince is the new President of the National Board of Directors of the Canadian International Freight Forwarders Association (CIFFA).  He is a thirty year veteran of the industry with special interest in air cargo.  Gary can be reached via

Guest Blog – Issues arising out of Hanjin bankruptcy

gavin-pmlawOn 2 September 2016 Hanjin Line declared bankruptcy and a Receiver has been appointed under Korean law. The sudden collapse of one of the major global steamship lines has sent shockwaves through the supply chain as the Receivers, Hanjin’s partners, their customers, and subcontractors such as ports and railways scramble for solutions in an uncertain environment.

 While the situation remains fluid, the following Frequently Asked Questions are intended to provide guidance on some of the issues that have or may arise. CIFFA cannot provide legal advice, so if you and your customers are impacted by the bankruptcy you should seek the advice of a lawyer.

 What do I need to do right now?

Communicate, communicate, communicate. The circumstances of the bankruptcy and resultant additional costs are events which a Forwarder could not have avoided even with the exercise of reasonable diligence. Forwarders need to be proactive in keeping their customers apprised of the situation and advised on any and all additional costs and charges, and in obtaining their instructions where necessary on how to deal with goods that are delayed or re-routed. Make sure these communications are documented (e.g. by email). Under the common law principles of agency as well as the CIFFA STCs, your Customer is responsible for the additional charges that result.

 Who is in charge now?

The Receivers have taken control of Hanjin and all of its assets. In general, it is their obligation to realize as great a recovery as possible for the secured creditors, and so they have an interest in delivering up cargo so that empty vessels and boxes can be monetized. In so doing, however, they are bound by Korean bankruptcy law and the orders and procedures of their courts, and so ultimately it is the Korean Courts that are in charge.

 Will Hanjin vessels be arrested?

In bankruptcy, actions against the assets of the bankrupt under control of the receiver are “stayed”, which means they cannot be commenced and cannot proceed if already commenced, unless the claimant receives permission from the court. The Korean proceedings include such a stay, which is commercially necessary to enable the receivers to dispose of the assets reasonably. However, bankruptcy laws are national in nature and therefore creditors of Hanjin in Canada or elsewhere could attempt to obtain an order for the arrest Hanjin vessels in their national waters without regard to the stay on proceedings under Korean law. For this reason, a large number of Hanjin vessels are currently laid to in waters outside of (for example) US waters, a situation that is likely to persist unless and until Hanjin has confidence the vessels will not be arrested. As of the time of writing, there are several Hanjin vessels that have been docked for an extended period of time at ports in China and there is some speculation that they have been detained or otherwise prevented from proceeding.

So can Hanjin get services and not pay for them?

No. The stay affects all obligations and claims arising prior to the date of bankruptcy. The Receivers are fully authorized and obligated by the Court to meet obligations to which they agree from that date forward. Accordingly, for example, an unpaid contract for freight made with a rail carrier prior to bankruptcy for oncarriage of a multimodal carriage would be stayed, so rail and motor carriers that had been engaged for oncarriage cannot sue for those charges but rather must await their share of the proceeds of the bankruptcy; these parties will obviously be reluctant to provide freight services for arriving Hanjin cargoes as they will have no expectation of payment. If a Hanjin vessel docked after the bankruptcy to take on fuel, by contrast, that contract would have to be paid by the receivers in the usual course and in full, since it was agreed subsequent to the bankruptcy and does not form part of the debts of the bankrupt.

 Isn’t there a US bankruptcy proceeding?

Yes. Representatives of Hanjin sought protection in the US Bankruptcy Court for the District of New Jersey. That Court granted an Order confirming that the Korean proceeding is the main proceeding within the meaning of US bankruptcy law, however, there are a very large number of trade creditors and other interested parties and as such the situation there is quite fluid.

 What about Canada?

The Hanjin Scarlet discharged it’s Canadian cargoes and has left Prince Rupert apparently without incident, but at the time of this writing it and other Hanjin vessels in the region appear to be in a holding pattern. As yet there have not been arrest or insolvency proceedings commenced in Canada. Courts prefer to avoid a multiplicity of proceedings as being inefficient and rife with potential conflict, so in the event there are domestic proceedings it would be reasonable for the Canadian Courts to defer to the jurisdiction of the original proceeding in Korea.

 Will I be able to get delivery of incoming Hanjin containers?

Right now the answer is yes. The Receivers have an interest in emptying the vessels and retrieving the empty containers. As these arrangements were made pre-bankruptcy, however, both the affected ports as well as CN and terminal operators are seeking pre-payment or credit arrangements for their charges for their services in respect of the carriage. Arrangements need to be made directly with the designated representative of the port or CN:

CN Rail


DP World, Prince Rupert:

Tabare Dominguez, Commercial Director, E:

GCT Vancouver

Chris Ng, Vice President, Marketing & Sales, E:

 Who is responsible for these additional charges?

Every CIFFA Member is obligated to trade under the CIFFA STCs or conditions at least as strong. Paragraph 11 deals with changed circumstances that affect performance of the Customer’s mandate, and require you to take reasonable steps to obtain their further instructions. If you cannot confirm instructions, you are authorized to store the goods at the customer’s expense or to sell the goods for the beneficial interest of your customer.

 What do I do about export cargo intended for Hanjin vessels?

These will need to be re-routed, and this will result in additional costs about which you need to keep your customers advised. If the cargo was booked with Hanjin and moved to port prior to the bankruptcy, new arrangements will need to be made from where the cargo is currently located. Where the cargo was booked on a Hanjin vessel by another line and is being re-routed at their direction, the carrier’s right to impose additional charges for this interruption will be determined by that carrier’s bill of lading terms, and you should consider seeking legal advice.

What about the empty containers?

The containers belong to Hanjin and are at the disposal of the Receivers. CN has advised that, where containers were the subject of a prepayment or specific credit agreement, they will accept them for return. As of the time of writing (23 September) CN will not accept Hanjin containers that left their system prior to the bankruptcy under their confidential agreement with Hanjin. For commercial reasons, Forwarders having numerous Hanjin containers should consider making arrangements for their storage off-site at lowest cost. As Hanjin is not your customer and would not in the usual course of business owe a Forwarder money, you do not have a lien in the container as you would in cargo for unpaid freight. If exposure to storage for containers is an issue for you, we recommend seeking legal advice.

What about perishable or time-sensitive goods?

Under paragraph 15 of the CIFFA STCs, damages for delay are highly circumscribed, and they are similarly limited or even unavailable under common carrier terms and international Conventions. Under paragraph 5 of the STCs, you are not responsible for on-time delivery unless you provided a written guarantee. Ensure good communication with your customer and take all reasonable authorized steps in order to minimize the potential for claims.

 What if a customer abandons their goods and refuses to pay?

Abandonment is also a changed circumstance under paragraph 11, and you are permitted to divert, store, and sell the goods on account of your charges. Paragraph 18 provides details on your right of lien for charges outstanding from such customers. Where customers refuse to give instructions in respect of cargo, or declare that they are abandoning cargo, you should seek legal advice.

 What about goods on Hanjin vessels stopped at foreign ports?

It is important to recall that bankruptcy law is particular to each nation, and while the process appear to be working as intended in Korea, the USA, and Canada, there is always the possibility of independent action under the national law of any port of call will permit arrest of vessel, for example.

Guest blogger is Gavin Magrath, Barrister & Solicitor, Magrath’s International Legal Counsel, CIFFA legal counsel. He is a civil and commercial litigator focusing on maritime, admiralty and transportation law, representing forwarders, carriers, ship owners, and cargo interests in litigation and dispute resolution before the Superior and Federal Courts. Can be reached at

eHBL – Dramatic Impacts on Terminal and Warehouse Operations

eHBL – Dramatic Impacts on Terminal and Warehouse Operations if Deconsolidation Notices Not Implemented on Time


Imagine if you will, the thousands of “single or back-to-back’ shipments requiring a ‘Customs stamped’ paper authorizing a container to move off the terminal.

Imagine if you will, the line ups at the counter to have those papers stamped by the CBSA before they are couriered over to the terminal.

 Imagine if you will, the number of new staff the CBSA will need to hire just to handle the stamping of paper for all singles or back-to-back shipments at terminals or airline facilities that have not implemented the D4 Notices – and the Deconsolidation Notice in particular.

 This nightmare scenario is real and it is coming to a terminal near you.

 With the November 7, 2016 coming into force of the eHBL phase of the CBSA’s eManifest program there is a significant change to the ‘release request’ procedures.

 Back-to back’ or “Single” Shipments:  Shipments where the carrier bill of lading is consigned to a freight forwarder and there is an underlying single house bill of lading consigned to an importer.

Today, through a manual work-around or manipulation of the ‘importer/ consignee’, the release request on a single “back-to-back” shipment is made on the primary carrier 9000 carrier code or MAWB.  Because the release request cargo control number (CCN) is the 9000 carrier Cargo Control Number, terminal, airline, railroad IT systems recognize the Customs status and release information etc. against the 9000 CCN or the airline MAWB.

Tomorrow, with the mandatory introduction of the eHBL on all shipments arriving at a Canadian First Port of Arrival as of November 7, 2016 that changes.  The Customs’ release request on ‘back-to-back’ shipments will no longer be on the 9000 CCN.  The release request – and subsequently the RNS and all customs status and messaging will be on the 8000 CCN

If the terminal/ warehouse’s EDI system is not programmed to receive and handle the CBSA D4 Notices – and in particular the Deconsolidation Notice, the terminal will be required to receive, handle and store a paper authorization to allow the container to move. 

There are thousands and thousands of these ‘back-to-back’ shipments moving through Canadian terminals every year.  Unless terminals and airline handlers are prepared to manage these thousands and thousands of new paper “authorized to move’ documents, they must implement the EDI Deconsolidation Notices.

Freight forwarders large and small are preparing to flip the switch to the new eHBL before the November 7, 2016 deadline.  Every organization must be prepared to recognize 8000 CCNs in their EDI system or be prepared to receive, handle and store these additional thousands of paper documents.

Primary warehouse operators are urged to take action immediately with their EDI service provider or in-house IT department to obtain the “Deconsolidation Notices.”  It takes weeks to get through the CBSA TCCU testing – and you must start now.

 Airlines – the same message applies.  Every shipment clearing under the MAWB today will clear under a ‘single’ 8000 eHBL.  It is a big deal.

 For detailed information contact:

E-mail:  Telephone: 1-888-957-7224, Option 1 for EDI transactions / Option 2 for Technical Portal Assistance (Canada or US)

For all other eManifest policy-related enquiries, refer to eManifest client support and contact information.

Service providers tested and in production with CBSA for Notices:  (Many more are expected within the next few weeks)

The Customs Notice CN 16-17 outlines the requirements and urges freight forwarders to get the Deconsolidation Notice.  Terminals and warehouses must also be prepared or handle the paper consequences.

Our letter on the Deconsolidation Notice is posted at:

Guest Blog – Cargo Security or Cargo Insecurity?

Gary Wince NewOn October 17th 2016 Transport Canada is “expanding the air cargo Secure Supply Chain” to include shippers or “originators” of cargo by way of the new “Known Consignor” category. Innocuous as this sounds, the implications could be significant.

What will this mean in terms of the actual flow of cargo? What can forwarders and carriers expect in terms of screening volumes as of October 17th? Will this impact exporters in terms of transit times? Will there be screening bottlenecks? Cargo security may be coming in October 2016 but unanswered questions are creating cargo security insecurity today.

These are questions for which we currently have no answers. There are also no answers as to how we mitigate the growing level of insecurity within the Canadian air cargo industry as it relates to cargo screening volumes. While there is a heightened awareness of the need for investment in both labor and infrastructure to manage the increase in cargo screening the proverbial “fence sitting” appears to be the most common response in the industry.

Uncertainty Drives Insecurity

So why is there not an air cargo industry call to arms on this?

It is simple. Our industry is not unlike any other industry. Investments require money and money requires business cases and business cases require information and data. If I go to a bank today and ask for a million dollars the bank will want to know how I’m going to make money to pay this investment back. To determine this I need to provide them a revenue stream projection based on facts and figures. Economics 101 right? In the case of air cargo screening, we need to know the volumes of cargo that will require screening to have this revenue stream projection to give to our banks to get the money. Screening equipment, the space to house the screening facility, staff hiring and training to conduct screening – these investments take hundreds of thousands of dollars. The input data such as projected screening volumes is definitely a missing link in the investment chain and is a major cause of our cargo security insecurity.

CargoAt this point, there is no expectation that the new ACS Regulations implementation date will be delayed so we need to prepare for a significant change in the way we manage our customers’ business and a significant change in our costs for doing business.  Air shippers should be preparing now to become Known Consignors and if not, should be preparing to pay additional screening costs.  Forwarders and third party service providers should be completing requirements to become Regulated Agents – to make the investment and get ready for screening. This is a call to action for the entire community to help address our cargo security insecurity.

CIFFA offers cost effective, on-line, on-demand training for all participants in the program through its Authorized Cargo Representative (ACR) and Cargo Security Coordinator (CSC) training.  Known Consignors must get on board quickly if we are to be ready for October 17th.

Guest blogger Gary Vince is the new President of the National Board of Directors of the Canadian International Freight Forwarders Association (CIFFA).  He is a thirty year veteran of the industry with special interest in air cargo.  Gary can be reached via

Container Examinations Out of Control


PictureA Vancouver based CIFFA member wrote, “Welcome to Canada. The CBSA has become the best marketing tool for the Port of Seattle.”  Incredible as it may seem, delays from vessel discharge to containers being called for examination are as long as six weeks and more at Canada’s busiest port.  And, while the entire process appears to be broken, it also appears that the rate of examinations at Vancouver is on the rise.  Importers face the consequences of six and seven week delays to their goods – reduced sales, dissatisfied customers, cancelled orders – and then are hit with exorbitant examination, storage and demurrage invoices that can be $4000 and more per container. 


The entire system lacks accountability.  The terminal operators charge storage fees of + $150 per day so what incentive do they have to make goods available to the CBSA for examination?  Why do they care if containers identified for exam are buried in the stacks?  Steamship lines pass on the charges, often with heft administrative fees and additional equipment demurrage fees, so why do they care? The CBSA shrugs its collective shoulders and claims that it has no culpability in continuing to identify containers for examinations knowing full well that the terminals are not able to handle the requests. In today’s letter to the Canada Border Services Agency, we urge the CBSA to take action to resolve the delays and expense incurred by Canadian importers at all ports and most especially at the Port of Vancouver.  While our letter calls for immediate steps to be taken to ameliorate the situation at Vancouver, in it we urge the CBSA to address both the pricing model and the regulatory framework surrounding container examinations across the country. Our letter reads in part, “Lack of leadership by the Canada Border Services Agency in addressing this long-standing and persistent problem has resulted in considerable cost to Canadian traders.  There is no accountability or transparency anywhere through-out the process and Canadian importers are paying the price.  I should rephrase.  Canadian consumers are paying the price as the cost of the delays, the cost of lost sales, the cost of physical examinations are passed on to every Canadian who purchases an imported good from a retailer in Canada.  Additionally, Canadian manufacturers and exporters who rely on imported components are paying the price as they and their suppliers struggle to deal with these extremely high and unexpected costs and delays.  The consequences of the CBSA’s approach to container examinations are considerable.  In Appendix B you will find a sampling of emails received at our office from importers and members detailing some of the impacts.” Thank you to our member firms who took the time to share with some examples of the exam costs they received and passed on.  Appendix A in the letter has some brief analysis of that data. Read the full letter here

Guest Blogger Gary Vince, CIFFA VPI Shares Insights from Transport Canada Roundtable – “Trade Corridors to Global Markets”

Gary Wince NewWe’re pleased to introduce today’s guest blog by incoming President of the CIFFA National Board of Directors, Gary Vince. Last week Gary participated at an intimate, invitation-only round table of 15 senior industry spokespersons, hosted by Canada’s Transportation Minister.   I have to say that it was truly an honour and a pleasure to have been invited to represent CIFFA at the recent “Trade Corridors to Global Markets Roundtable” hosted by our new federal Transportation Minister, The Honourable Marc Garneau. While the words “honour” and “pleasure” may seem like strange bed fellows in the same sentence this particular meeting was in fact structured in a way that truly shows a renewed approach by our Government and its Ministers. Minister Garneau is currently leading a series of “thematic roundtable discussions which will permit him to speak directly to a limited number of Canadians about their priorities and concerns”. The fact CIFFA was an invitee to this roundtable truly speaks to our commitment to governance and to CIFFA’s long term strategic plan. This particular roundtable gave CIFFA an opportunity to table and discuss our recent submission to the Canada Transportation Act Review Panel and the subsequent “Emerson Report” which detailed many of the suggested amendments that need to be considered by the current Government and the Transportation Minister specifically. While the roundtable itself was limited to a two hour session, the four topics/questions provided to us gave all of the attendee’s opportunity to comment on each area, in this open forum, these topics/questions were;

  1. What are the key strategic priorities for transportation infrastructure and policy in Canada to enable efficient and reliable connections to global markets?
  2. How can the Government of Canada best engage with our partners and stakeholders to develop a national outlook on trade-related transportation infrastructure priorities? 
  3. What is your view of the partnership model that was used over the past decade to support multimodal transportation infrastructure and policy investments? How can this approach be improved?  Is a new model required?
  4. What kind of information and data on transportation is needed to provide a good evidence base that will allow for analysis to inform investments in trade-related transportation infrastructure?

The theme of this meeting which was provided to us by Shawn Tupper, the Assistant Deputy Minister, Policy, said it all; “Together we will explore the path to move Canada’s transportation system forward “ and based on what I saw and heard during this first roundtable session, we are off to a great start!

New CIFFA/ Schulich Management Course Awards Certificates to First Class

Schulich CIFFA Grad Photo

The first management training course offered under the new Schulich/ CIFFA partnership wound up yesterday after an invigorating and thought-provoking three days. Subject matter expert and part-time faculty member at the Schulich School of Business – York University, Sanjay J. Dhebar MBA led the group on a journey of discovery of just what a Sales Strategy for Non-Sales Managers means in today’s fast paced, rapid- change world. With a great blend of academic and group work, Sanjay kept the class thoroughly engaged, peppering the learning with anecdotes and stories from his own experience.

I’m still high from the energy created from interaction with others in the class. The third day was spent in facilitated group work based on a case study – and Sanjay encouraged everyone not “to think outside the box” bRuth York Diplomaut to create a new box. I’m remembering some of the key takeaways that fellow participants shared as we wrapped up a few hours ago.

Key Takeaways (not in any particular order!)

  • Don’t be afraid to be a ‘challenger’ and bring your customer through to change.
  • POSITIVE steps make a great sales call.
  • A good CRM is critical to an efficient and effective sales force.
  • Lead your team to success by showing them where they’re heading, giving them the tools and incentives to achieve, but don’t micro-manage.
  • The art of coaching is a critical skill.
  • Marketing prepares the plan: ‘sets the table’ – Sales executes.

Finally, have to say that I was impressed by the facilities at the Schulich Executive Centre at York University. The Centre creates an excellent executive learning environment – from classroom to dining room. And the catering is exceptional. I’m not going to eat for a week. But I am going to sign up for the next course offered June 21-23 “What the Non-Financial Manager Needs to Know about Financial and Managerial Accounting”.

Amazing Possibilities for the Future of Canada’s Transportation System

The 286 page Canada Transportation Act Review known as the Emerson Report  tabled in the House of Commons on February 25th is a far ranging, thought provoking voyage along Canada’s transportation system from our early days long ago to thirty years into the future. The Report hasn’t received much attention yet from the press, except for last week’s Hill Times Events Transportation Forum; perhaps because our national transportation system is working and there are so many other critical issues that need immediate attention. Nonetheless, over the next months we hope to have more blogs and comments on various aspects of the Report because one underlying theme comes through loud and clear. Canada’s economic prosperity is tied to international trade and our international trade is inextricably linked with our national transportation systems. Following are some notes prepared for the Hill Times Transportation Forum, a public policy think tank where professionals, pundits and policy wonks discussed just a few aspects of the Report.

Director Blog Amazing Possibilities 1
photo taken by Jeff Cullen

Global Hub Strategy 

It its written submission  to the CTA Review in January 2015, CIFFA called for the creation of Canada as a ‘transit hub’. What the Report calls a ‘Global Hub Strategy’ will help bring options and opportunities that Canadians need to win in this highly competitive international trade arena.

In its recommendations for a Global Hub Strategy, the Report emphasises the benefits that will accrue to air passengers. Freight forwarders – or global logistics service providers – are all about moving goods – into, out of and through Canada. But you have to remember that the movement of goods is linked, particularly in the air mode, to the movement of people. We have some freighters but generally our international air cargo moves in the bellies of passenger aircraft. And so the Report’s far-reaching recommendations to improve the international and transit passenger experience – and cost – can only support similar opportunities for improved performance for air cargo.

I was in Hong Kong last November, speaking with a local HKG trader who the previous week had moved a 10 tonne shipment by air from Hong Kong to Brazil. He was a little surprised when I was said, “Tell me you used Air Canada over Toronto or Vancouver” and I was pleased when he responded ‘Why yes we did.’ That routing isn’t one that springs naturally to anyone’s mind – unless, of course, you are a Canadian international freight forwarder – but IF we want to have the options, if we want to have the carriers, if we want to have choice – we have to have the transit cargo and the transit airlines through Canada.

The Report mentions that in 2005 airlines carrying passengers through Canada for travel between South America and Asia had a 4 percent share. By 2013, it had dropped to 2 percent.     That’s a shame because every transit air passenger and every transit kilo brings jobs and economic benefit to Canada.

The Report s emphasizes – and rightly so – that higher volumes of travellers and freight lowers costs and creates opportunities in other sectors, and transit traffic can increase airline volumes by 25‐50%. Our domestic markets are small and we need the options / carrier selections. Like the Air China Cargo freighter that flies Shanghai, Edmonton, Dallas three times a week, carrying transit cargos as well as Canadian origin and destination cargoes. It is good for everybody – including Vancouver’s cherry exporters who may access that capacity during peak season for their produce.

While the Report talks to the need for a Global Hub Strategy for the air passenger industry, it doesn’t however, continue that discussion to include the development of a global hub – or as we say transit hub – for Canada’s critical maritime trade. When a carrier calls at Prince Rupert or the Port of Montreal or Halifax to pick up and drop off containers from or to the US mid-west every Canadian shipper benefits. We have more options of carrier selection, frequency of calling and routing to get our precious exports to market.

Look at Prince Rupert. Ten years ago there was nothing going on in the intermodal business.  When the new terminal opened in 2007, the original capacity was 500,000 TEU. Today, effective management, productivity gains and an efficient workforce have seen throughput grow to 776,412 TEU in 2015 and construction has already begun on the expansion which will bring 1.3 million TEU capacity by mid-2017. That port was built on US transit cargo and it will be successful on US transit cargo.

Projects Pipeline

Like any good system, there are many layers and considerable inter-connectivity in Canada’s complex transportation system. Recommendations to support the National Framework on Transportation and Logistics, the Advisory Committee and the Projects Pipeline will be critical over the next 30 years.

Take one example. CN’s Milton Logistics Hub is sorely needed to reduce congestion around the GTA and it would support transit cargo to and from the USA, particularly over Canada’s East Coast ports. One hopes that the development of the recommended Projects Pipeline, ‘in collaboration with provinces and industry – and one might add municipalities – would bring to government the focus – dare I say the will to ensure effective / efficient/ timely delivery of similar, private sector, infrastructure investments in the future.

Integrated Data Pipeline and Multimodal Data Dashboard

A couple of times in the Report there are references to a fragmented approach by the Government of Canada, citing various gaps and redundancies. I would hope that the National Transportation Framework and the Advisory Committee will be all-encompassing – particularly at the federal level and that the Integrated Data Pipeline and Multimodal Data Dashboard are deployed across all government agencies and divisions.

For example, the collection of security related Advance Commercial Information in both air and marine modes has to be aligned with the Director Blog Amazing Possibilities 2.pngUnited States’ data collection and cannot create any barriers to cargo transiting Canada – or remaining on board a vessel or aircraft that visits a Canadian port.

The CBSA’s eManifest or “Advanced Commercial Information’ strategies have to support in-transit cargos and make it easy for foreign and US shippers and freight forwarders to choose routings that transit Prince Rupert or Montreal or Vancouver for their US or South America or Asian or European originating or destined cargo.  Because if there is even a hint that regulatory compliance will be more burdensome than shipping cargo over a US port or airport – don’t kid yourself, the cargo will flow, just like water, through the path of least resistance.

SOLAS Verified Gross Mass Requirements in Legislative Limbo

Posted on 11 January 2016 by Gavin Magrath


The Safety of Life at Sea Convention (SOLAS) is a treaty of the International Maritime Organization (IMO), the United Nations agency tasked with maintaining a comprehensive framework of rules for international carriage by sea. 171 nations are members of the IMO, so virtually all national governments are State Parties responsible for implementing its treaty measures.

In 2014 the IMO approved amendments to SOLAS, which comes into effect on 1 July 2016, requiring at Paragraph 6.6 that “[a]fter finalisation of stuffing and securing of containerised cargo, the total container weight must be verified and documented” by the Shipper prior to the tendering of cargo using one of two methods:

  1. Weighing the packed container using calibrated and certified equipment; or
  2. Weighing all packages and cargo items, including pallets, dunnage, etc., and adding the tare mass of the container to the sum of the masses of the cargoes using a certified method approved by the State’s competent authority.

Of course, it has always been the responsibility of shippers to provide an accurate declared weight for cargo; the new obligation is to ensure the weight is verified using one of the two methods.

The impetus behind the changes arose from the circumstances of the sinking of the MSC Napoli in severe weather in the seas between England and France. The subsequent investigation by the British Marine Accident Investigation Branch found that significant discrepancies between declared and actual weights of the containers stowed on deck was a contributing factor in the disaster The new SOLAS requirements require that the verified gross mass is documented, signed by someone duly authorized by the shipper, and provided to the Master or their representative “sufficiently in advance to be used in stowage planning.”

Freight Forwarders as Shippers

It must be recalled that under the IMO Guidelines the “Shipper” is the entity or person named on the bill of lading or sea waybill as shipper, and in whose name the contract for carriage has been concluded. Where the forwarder acts as NVOC, they are the shipper on the Ocean or Multimodal Bill of Lading or Sea Waybill, and accordingly the party responsible for documenting the verified weight and providing it to the Master or terminal in a timely fashion. Any forwarders engaging in NVOC activities must therefore be prepared, from 1 July 2016, to provide certified weighing equipment under Method 1 or use a certified method for summing individual cargoes under Method 2.

National Implementation

The IMO is not an enforcement or administrative body, and implementation of treaty obligations is the individual responsibilities of the States Party to the treaties. To date, Transport Canada has not offered significant guidance on what will constitute “calibrated and certified equipment” for method 1, nor on what will be the approved certified method for summing gross weights under method 2, and this leaves substantial uncertainty in crafting the industry response. Notwithstanding the lack of specific guidance, it is probably safe to assume that the authority responsible for “certified and calibrated” devices will be the national authority on weights and measures – in Canada, this is Measurement Canada, an office of Industry Canada.

In Europe, however, there has been a more harmonized approach, which will hopefully serve as a …

Read the complete article at

The Belt and Road: Visions of Marco Polo in the 21st Century 281475132819710.htm

Toronto, Ont December 4, 2015       Remember Marco Polo and tales of the Silk Road? With the Silk Road Economic Belt and the new 21st Century Maritime Silk Road, China aims to open a new era for global trade, simply called the Belt and Road initiative. The opening plenary at the Asian Logistics and Maritime Conference (ALMC) in Hong Kong a couple of weeks ago brought some 2000 logistics professionals together to learn more about how the powerhouse that is China intends to accomplish this feat and what it might mean for countries touched by the belt and for traders around the world.

The Belt and Road: Journey to the New Era panellists presented insights on challenges that must (and I suspect will) be overcome for this new vision to be realized. Certainly there are physical infrastructure requirements of railroads, bridges, tunnels and stations that Mr. Zhao Huxiang, Chairman, Sinotrans & CSC Holdings and President of FIATA addressed. Even more challenging perhaps than physical infrastructure projects are the issues relating to trade facilitation, border crossings, customs facilities and the interminable delays and costs in transiting so many countries, many of which lack modern Customs administrations.

Organized by the Hong Kong Trade Development Council and the Government of the Hong Kong Special Administrative Region, the AMLC covered many other subjects. Some of the numbers presented in the discussions on eCommerce were astounding. The scale and potential of eCommerce in China and throughout Asia is almost unbelievable. Last year on Singles’ Day, it took about 8 hours to process 100 million orders. This year, according to conference speakers, it took 43 minutes to generate 100 million orders and Alibaba processed US $14 billion in one day. For everyone in the business to consumer (B2C) logistics industry these numbers are significant and are, I think, the harbinger of significant change in how consumers shop. Black Friday and Cyber Monday are nothing when compared with the power of the volumes of China. Every order must be picked, packed, shipped and paid for efficiently.

Not all of Asia is ready for such explosive B2C growth or eCommerce as China has experienced. In many countries individuals don’t have credit cards, there isn’t reliable internet, the last mile is a congested nightmare of exhaust belching trucks, but change is coming to the entire region and it is coming quickly. There is incredible opportunity in the region.

In another panel dedicated to Shipper-Liner Dialogue, the Global Shippers’ Forum (GSF) Secretary General Chris Welsh described how better communication across the whole supply chain is vital to ensure customers’ needs are not compromised by the container shipping industry’s drive to cut costs through mega-alliances. He went on to advise that GSF is not opposed to mega-alliances in principle but they must deliver enhanced quality in services as well as reduced prices. As we all know, there are plenty of challenges facing the container industry: depressed freight rates, mega-vessels and over-capacity and the new reality of shipping alliances.

All in all, the ALMC created an excellent opportunity to think about the brave new world of trade with Asia and how Canadian traders should begin to consider these vast new markets. Hong Kong, with its strong financial institutions, strict rule of law and port and airport infrastructure is perfectly positioned as the gateway to China and beyond.

Want to learn more – view the video produced by the Hong Kong Trade Development Council for the ALMC. It can viewed at the following link and my interview and the CIFFA booth are at minute 2:51: 

Logistics Performance Index (LPI) – Great Data, Easily Viewed

Toronto Ont,  November 19, 2015           In Singapore at the 2013 FIATA World Congress one of the plenary speakers from the World Bank impressed me so much with his discussion of the value of the World Bank’s Logistics Performance Index (LPI) that it stayed with me over the past two years and it took me onl151119 Logistics Performance Indexy seconds to find my notes from that event. He explained that the data in the survey is relative and it should be viewed as trending data. How does your country (Canada) perform against other countries in any given year? And, perhaps more importantly, how has Canada scored over the past three or four surveys. How are we trending under the key indices Customs, Infrastructure, International Shipments, Logistics Competence, Tracking and Tracing, and Timeliness.

The World Bank speaker went on to describe how we can use these data to create a Canadian global logistics efficiency roadmap. He also recommended that we take our country data to relevant authorities such as the Canada Border Services Agency and Transport Canada, using the survey results to give credence to questions about trade facilitation activities, infrastructure investment, procedural and regulatory improvements. What can the government of Canada do to improve our results?

These are our results. Freight forwarders (global logistics service providers) provide the data.

Canada’s 2014 performance: Country Score Card: Canada 2014

Comparing Canada’s 2014 performance: Against World Leader, Germany

Comparing Canada’s scores across the four survey years: (2007, 2010, 2012, 2014)

With the implementation of eManifest at the highway and rail crossing and the pending transition to eHBL it will be very interesting to compare our results in 2016 to 2014 and 2012. Maybe we won’t see the efficiency improvements we and the CBSA anticipate from the modernization activities until the 2017/18 survey?

If you are working at a global logistics service company and you’re dealing with international shipments, please take the survey at 2015 / 2016 Survey. It should only take around 20 minutes.

The World Bank’s Logistics Performance Index (LPI) benchmarks logistics performance in around 160 countries. The next edition will be published in the spring of 2016.

Key to the relevance of the LPI is that the index is the voice of logistics professionals. The LPI is based on a survey among international freight forwarders who share their experience in moving goods and organizing international supply chains for their customers. This is a unique opportunity to “vote” and ultimately influence the environment that you, as professionals, operate in.


Toronto, Ont November 13, 2015      This week I’ve been in Toronto where I live and in Vancouver and Calgary to facilitate the CIFFA eManifest Town hall events. Thousands of people everywhere I’ve been, on every street, on every flight, in every meeting proudly wear the red poppy in remembrance of those who have served to protect our democracy. And I reflect on the nature of that democracy. We have just had a federal election which resulted in a change in our federal government. One leader out and another leader in. One party out and another party in. One cabinet out and another cabinet in. No fuss. No muss. No danger to any citizen of any party. What a wonderful thing.

Sure, some things will change. Some of us wonder if the major programs we’ve been working on will continue to receive the funding and agency resources that were mandated by the previous government.  I expect that thebeautiful-poppy-field_00438499y will. The Canada Border Services Agency (CBSA) will continue to work on the transformational modernization initiative it has undertaken for commercial goods and in which it has invested hundreds of millions of dollars. Let’s not kid ourselves. The changes coming with eManifest and the new eHBL, with sufferance warehouse modernization and with cargo and release will cause transformational change in how we conduct our business. Certainly the two hundred people who attended the eManifest: Strategies for Success Town Hall sessions across the country in the past few weeks have begun to realize just how significant the changes will be. eManifest dates have slipped once, but we have been assured by the CBSA that when the new ‘mandatory’ date – or coming into force date –  for eHBL is announced, it will be firm. The CBSA has worked with CIFFA and the freight forwarders in BCCC meetings, in bi-lateral meetings, in telephone and web based consultations to develop and deliver this new way of doing business.

Sure, we expect the implementation period to be challenging. (OK, the transition will probably be brutal). Every time we bring industry and Agency together – such as at our most recent events, we hear of a new scenario, a new challenge, a new ‘how will this work’ that we haven’t worked through yet. This week’s events were no exception. The brilliance of our country, the brilliance of our democracy is that the CBSA is in the room with us – explaining the regulations, trying to understand our business and working with us to figure out how to deliver the modernization that we need.

And so I remember those that fought for our country and our democracy 100 years ago, 60 years ago and last week.

Air Cargo Security: Finding a Balance

Toronto, Ont October 8, 2015
Our international association, FIATA is often asked to provide stakeholder input to governments and NGOs on issues ranging from Air Cargo Security Finding a Balancethe SOLAS container weight verification to revisions to some obscure EU regulation on the CMR.  CIFFA relies on FIATA  to keep us informed on issues of global importance and FIATA relies on its members, like CIFFA, to provide guidance where we can.   Recently, FIATA was asked to provide the thoughts of our global freight logistics sector to ICAO, to help define some of the challenges facing the aviation community that ICAO must take into account in the future of its work plans.

Simplicity and transparency are essential to trade facilitation and that one of the greatest challenges facing ICAO is the absolute necessity to balance trade facilitation with security.  Air cargo security and aviation security cannot be achieved at the expense of efficiency and simplicity.  Yet, increasingly the results of the work of organizations such as ICAO create an air cargo environment that is overly complex, frequently modified and is duplicated or handled by multiple agencies within member States.

For those who may not know “the most important legislative function performed by ICAO is the formulation and adoption of Standards and Recommended Practices (SARPs) for international civil aviation. These are incorporated into the 19 technical annexes to the Convention on International Civil Aviation, also known as the Chicago Convention. Of critical importance to the future of civil aviation and to the international community at large are the measures taken by ICAO to prevent and suppress all acts of unlawful interference against civil aviation throughout the world. SARPs for international aviation security were first adopted by the ICAO Council in March 1974, and designated as Annex 17 to the Chicago Convention. The latest Amendment to Annex 17 – Amendment 14 – became applicable on 14 November 2014.”

Every Member State is responsible for regulating its country’s air cargo security following what is commonly known as Annex 17.  In Canada, that task falls to Transport Canada and has resulted in the Air Cargo Security program that we all know and love.

Over the past fifteen years ICAO has been committed to increasing aviation security. We are all familiar with the work of ICAO in developing security requirements, which have been progressively revised, updated and made more stringent.  These include air cargo security, screening technologies to detect prohibited articles, strengthening international standards, improving security information-sharing and providing capacity-building assistance to States in need.  In 2014 updated security requirements were contained in the 12th revision of Annex 17 (Security) to the Convention on International Civil Aviation, adopted by the Council of the Organization.

And therein lies the challenge.  Air cargo security and aviation security cannot be achieved at the expense of efficiency and simplicity.  Yet, increasingly the results of the work of organizations such as ICAO create an air cargo environment that is overly complex, frequently modified and is duplicated or handled by multiple agencies within member States.

Capacity-building and training development in areas such as Africa, South America and parts of Asia can do only so much to promote both aviation security and trade facilitation.  ICAO must work with its member States to simplify and standardize security requirements in every country.  National Customs authorities and Transportation / Security Administrations must align their work so as to eliminate duplicative requirements, reduce advance data requirements to the minimum data necessary to ensure safety and security, and standardize globally.

Click to read CIFFA’s full response to FIATA’s request, complete with references and footnotes.

From Here and Now, Think Global: FIATA World Congress Taipei 2015

ruth blog 1Toronto, Ont September 21, 2015         From the here of Taipei and the now of the September 2015 FIATA World Congress, it was an easy step to think global.  Some 1000 participants from 67 countries came together last week for informed presentations, animated discussions and engaged networking events. Ours is a global industry where successful players are aware of emerging trends and cognizant of changing standards, pending regulations and an ever-changing playing field.  The annual FIATA World Congress creates the perfect opportunity to get up to speed on global freight logistics issues.

Opening ceremony keynote speakers included Mr. Shih-Chao Cho, Deputy Minister, Ministry of Economic Affairs, Taiwan; Mr. Bronson Hsieh, Second Vice Group Chairman, Evergreen Group Director, TT Club Board; Mr. Edward Lin, Chief Executive Officer, Dimerco Express Group; Mr. Massimo Geloso Trade Policy Analyst, OECD (Organisation for Economic Co-operation and Development)These thought leaders shared their success stories and their thoughts for the future on global issues from their unique perspectives. 

Mr. Kaya Karakaya of Schenker of Canada was on the main stage to receive his award as the America’s Region Young Freight Forwarder of the Year (YIFFY) winner.  FIATA celebrates the achievements of young freight forwarders working for companies in its ranks at its annual congress every year.  This year at the Taipei Congress participants also applauded the overall winner of the Young Freight Forwarder of the Year (YIFFY) Award, Daniella Smal of Zambia.  Insurance provider to the international freight transport industry, TT Club has sponsored this award for each of its seventeen years and Claims Manager Mike Yarwood was on hand to announce the winner and present the award with a brief speech, evocative of the important achievements in training made by FIATA and its members.

Airfreight Institute (AFI)

Mr. William Gottlieb (Canada) spoke about the challenges of the revised agency agreement Cargo Agency Modernization Program (CAMP), which has absorbed FIATA and IATA for the past three years.  Independent legal reviews of the proposed program have recently been received by FIATA and there is cautious optimism that the revisions will move forward soon.   Keynote speaker Mr. Glynn Hughes, head of cargo for IATA, spoke passionately about the need to change the current agency structure and the need to develop a more partnering relationship between freight forwarder and airline.    Mr. Hughes also addressed the need to promote eAWB and IATA is considering an eAWB solution as outlined in Congress coverage by The Loadstar.

Concerns are growing within the air cargo industry over the transport of lithium batteries. In his comments, Mr. Hughes said the industry needed to be increasingly aware of some shippers trying to circumvent regulations and deliberately shipping dangerous cargo. “As an industry we have to be vigilant. We have to be thinking about how we can spot these shipments and prevent them, because in some cases there is willful neglect in terms of the resolutions, the regulations and the shipping requirements of ICAO”.

CIFFA has recently made its on-line dangerous goods handling  training  on lithium batteries available to all FIATA members. 

FIATA Provides SOLAS Container Weight Verification Toolkit

At the FIATA Multimodal Transport Institute, Chairman Mr. Robert Keen (UK) announced to delegates an initiative to provide all FIATA Members with a comprehensive guide to the changes due in July 2016 when the verification of container weights becomes mandatory.  The changes to the SOLAS Convention (Safety of Life at Sea) were agreed at the International Maritime Organization (IMO) in 2014 and the implications have been considered in detail by the FIATA Working Group Sea at their regular meetings.

The toolkit is a guidance document covering the background to the changes and an overview of the new legislative requirements. There is a detailed analysis of various contractual scenarios when the forwarder transacts with shipping lines or with other parties and it concludes with a “next steps” section giving helpful advice to FIATA Members in dealing with stakeholders in their own countries. [note: CIFFA is engaged in talks with other industry representatives and Transport Canada on the implementation of the new requirements in Canada.] 

FIATA and Mercury Gate sign MOU to Provide IT Solutions for Freight Forwarders

ruth blog 2Of interest to many CIFFA members, is the new agreement between FIATA and Mercury Gate for provision of an extremely well-priced operating system for freight forwarders. As the day settled and the last meeting neared, the audience remained steady in their seats waiting to hear details of this highly anticipated Memorandum of Understanding for which they had heard whispers all week. Daniel Vertachnik, Mercury Gate’s Chief Commercial Officer advised We have really never offered such a deal like this and it’s exclusive to FIATA Members”. The operating system provided by Mercury Gate comes with a list of key functions and features at an affordable price to enhance efficiency in FIATA members’ day to day operations.  More on this as details become available. 


Last, but certainly not least were the hotly contested elections to the FIATA Presidency and Extended Board, held at the annual general meeting of the membership on the last day of the congress.   Canada’s Mr. Marc Bibeau was elected as one of twelve Vice Presidents and Mr. Huxiang Zhao, from China became the new President of FIATA. Canadians at the annual general meeting Mr. Bibeau, Mr. William Gottlieb, Mr. Chris Gillespie and Ms. Ruth Snowden offered Mr. Huxiang Zhao their congratulations.

For some sense of the scale and scope of the 2015 World Congress, check out the photo blog at The Loadstar.

Getting the Most from Your Employee Training and Development

Guest Blog – Stephen McDermott, CIFFA Director Education and Training

Toronto Ont September 3, 2015        Sending your new and tenured employees on training to enhance job skills and knowledge can be a significant investment, the cost of which can only be calculated by combining the cost of formal training plus the time spent by co-workers and managers to coach and develop that employee.  Consequently, having a well-trained employee working efficiently and following compliance guidelines should make your company money in the long run.  But are you fostering the learning in your employees after they have been formally trained?  And are you assessing the effectiveness of the training in the long run?

When I teach an air dangerous goods course, I ask the students what types of DG they typically ship, and how often they come across a DG shipment.  For some it is daily, for others, two or three times per year.  Employees who go back on the job and apply what they have learned right away will always fare better than those who apply what they have learned two months after the fact.

To take advantage of this investment in employee education, companies would be well advised to consider a coaching or job mentoring strategy geared to the on-going development of an employee who just completed an in-class or online training course through CIFFA.  For example, if an employee completes dangerous goods training for the first time, are they paired up with someone in your organization to fulfill a shipment order for their first attempt?  If there are no regular DG shipments, can you provide them with a fictitious shipment to keep their knowledge fresh?

blog pir

Donald Kirkpatrick created the 4-level training evaluation model.   To learn more on Kirkpatrick’s model, click here.  At CIFFA we are able to assess learner reactions (Level 1) through surveys and feedback on the training, as well as to evaluate how effective the learning was through examinations (level 2).

The transfer stage (level 3) consists of HOW your employees apply what they learned in training and post training on the job.  This can only be observed if your organization is supportive of what they have learned and provides them with an opportunity to integrate that learning on the job.

Finally, the results phase (level 4) assesses if your investment in training was worth it, and will depend on your organizational goals.    Using DG shipments as an example: are fewer shipments being turned back by operators because of missing documentation or incorrect packaging?  Are fewer ‘hidden’ dangerous goods making their way into shipments resulting in costly fines?  Are sales increasing because of your employees’ knowledge of something they have learned?

In conclusion, an employee’s training does not end once they finish the class, online lessons or complete the exam.  Training should follow them back to their job, and should be fostered by their organization.  It will take some time and effort to establish new processes to ensure you can properly assess the effectiveness of that training in the long run, but it’s worth it to be able to quantify the ROI on your chosen training program!

Be Vigilant on Truck Carrier Selection: Peak Season Pressures

Be Vigilant blogAs supply tightens in the full truck load market, logistics service providers face challenges and pressures in carrier selection. The customer needs the cargo, your normal supplier doesn’t have the capacity to handle your load right now and you feel forced to seek a new trucker, quickly.  The temptation is to skip one or two of the key checks that logistics service providers must take with every carrier selection – that ‘quality’ supplier check-list we remember so fondly from our ISO9000 days.  With the increase in internet sourcing, fraud and theft, conducting due diligence on trucking carriers is more important today than it ever was.

A recent article posted on FreightWatch shares some scary American statistics – which should make us all sit up and take notice.  “In 2014, theft activity concentrated during the seasonal peak period of September through December with a cumulative 245 incidents; the greatest number of incidents, almost one third of the report period’s total, occurred in October as the surge of products flooded the demand to support Black Friday. Two coveted commodities targeted every year at this time, electronics and clothing & apparel, comprised 23% of the reported thefts yielding average loss values of $1,376,750 and $328,051 respectively.  … Theft of full truckloads constituted 89% of cargo theft in the United States with a majority of reported cases occurring at unsecured parking areas.  Many events also included driver theft incidents involving either direct theft by the driver, the driver’s voluntary collusion or complicity in the crime, or a deceptive criminal posing as a legitimate carrier resource.”  According to the American Transportation Association (ATA), driver turnover rate for large truckload companies reached 96% percent at the end of 2014. Who is that person driving the truck with the $200,000 of high fashion?

The next four months, the annual ‘peak season’, are traditionally some of the busiest in North American transportation.  Loaded containers flow into North America from around the world as retailers stock their shelves with the latest and greatest in anticipation of the Black Friday and Christmas shoppers who, they hope, will buy, buy, buy.  Organized crime is getting ready.  Crooks are watching, getting drivers in place and preparing.  It isn’t enough to check on-line to see that the carrier has adequate insurance – websites and insurance policies can easily be faked.  Update your carrier selection criteria. Take the time to ask the trucker for references and follow them up.  Verify the legitimacy of the insurance provider, call and ask them to confirm the coverage.  Check for membership in a provincial trucking association or local transportation club.  Ask for the trucking company’s physical address and if you can’t get someone out to visit the site, at least Google map the street view.  Only work with well-known load boards that you have vetted as you would a carrier.  This is the time when everyone with carrier selection responsibility must be extra vigilant.

2015 WTO annual trade report cover page

Great Trade Data in a Few Clicks: How Cool is the WTO’s Website

Ruth Blog- How cool it WTO WebsiteToronto, Ont August 7, 2015     In last Friday’s eBulletin we ran an article WTO Updates Its Exports/Imports Statistics Database with Revised Data for 2014.  It being a Friday morning and having arrived at the office early and dealt with emails, I read the whole eBulletin, including this article with the boring title.  What a stunner.

The WTO’s Statistics Database is so well laid out, user-friendly and fast that I was able to obtain comparative trade data on various commodities in moments.  Within seconds I had Canadian and US imports and exports of iron and steel for 2013 by current USD value.  Not that I am the least bit interested in these specific data, but I am interested in general trade trends, how and where manufactured goods are moving around the world and how certain countries or regions are participating in international trade.

International freight forwarders, known for agility in the market-place, should also be interested in general trade data.  Which emerging countries are developing capacity in certain commodities?  Where will Canadian traders be selling or sourcing goods over the next decade?  What will be the next important trade lanes?   How easy will it be to trade with certain regions?

Building trade capacity is a core area of activity at the WTO  and is fundamental to the promotion of trade facilitation.  Again, the WTO’s website was excellent.  I searched trade facilitation and immediately received the following definition Removing obstacles to the movement of goods across borders (e.g. simplification of customs procedures).”  Ah, a subject near and dear to my heart.  Sure, freight forwarders have large multi-national organizations as customers.  Thousands of small and medium sized traders, however, are also customers of freight forwarders.  It is these traders around the world for whom we must have simplified customs procedures, import and export regulations that are transparent and clearly communicated so that trade compliance does not become an uncompetitive burden.

On a final note, I explored DFATD’s website.  The Canadian Government’s Global Markets Action Plan talks to priority markets and provides a Toolkit  for exporters.  While the website is pretty good, the ‘value of trade’ seems to equate only to the ‘value of exports’.  It is time that the Canadian government recognizes that import trade is as vital to the well-being of Canadians as export trade and invests in trade facilitation that supports the movement of goods into, out of and through Canada.

Ever Wonder What Freight Forwarders Do?

Toronto, Ont July 31, 2015

rblkogWe want everyone to ask the question, because we have the answer. The future of our sector, the young people embarking today on post-secondary education and just starting to think about their careers, probably are not thinking ‘freight forwarding’ as a career of choice.  They don’t even know to ask the question, let alone have any idea of the skills and competencies needed to succeed in a career in global logistics or how to get from where they are today to ‘there’.

During the thirty some years I’ve worked as a freight forwarder, introducing myself and my work at countless social events, invariably I receive a quizzical look and the question ‘What kind of forester?” “No, no”, I reply.  “Not a forester.  A freight forwarder!” As CIFFA’s Executive Director I find myself again explaining the role of the freight forwarder.  Now, however, I’m explaining the finer nuances of the work of international freight forwarding to senior policy wonks at the Canada Border Services Agency or Transport Canada.  Or I’m speaking with terminal operators or business association managers who have only some vague idea of the role of the international freight forwarder.  I’ve even started referring to “global logistics service providers” or “global freight logistics providers” or my old favourite “architects of transportation solutions”.

Every chance I get, however, I show our video, “Ever Wonder What Freight Forwarders Do?” which answers the question with a few energetic examples.  I encourage you to share this link with the young and not so young.

Most importantly, I use CIFFA’s new tag line to explain the role of the freight forwarder.  Our role has evolved to so much more than moving goods and information from one place to another.  Our role is about trade facilitation; about making international trade easier, faster, and more efficient.


Graduation, CIFFA, Member Value,

Vocational Training – Investing in the Future of Our Employees


This morning as I scrolled through the photos of the June CIFFA Certificate graduation events (Montreal ,  Vancouver  and Toronto) I was struck by an incredible sense of pride in the excellence of the training delivered to the sector on behalf of members.  And, I was stuck by a sense of gratitude that my staff and I have the privilege of continuing to develop and deliver world-class vocational training in subjects that matter to employers of today – and employees of tomorrow.

International Transportation and Trade, and Essentials of Freight Forwarding, the two courses that comprise the introductory Certificate program are tough.  Not every student succeeds. But those who dedicate the time and effort deserve the recognition they receive as holders of a CIFFA Certificate.

The content and structure have been built over the past 40 years by dedicated volunteers like George Kuhn, Job Nicolai, Craig McKay and more recently Paul Glionna; senior managers in the sector who know the knowledge and skills sets that their employees need for their companies to succeed.  It is a privilege that the association has been able to take the work of these and many other volunteers, to invest in specialized staff at the Secretariat and continue to build vocational training based on the right set of core competencies.

Over the past two years, we’ve invested some $100,000 in a competency assessment, revision of the textbooks, introduction of process mapping and instructionally designed on-line delivery; investments needed to ensure these two courses and the Certificate program stay relevant and the best bang for every student’s buck. CIFFA’s strong financial foundation, built bit by bit over the past decades, combined with the commitment of a dedicated National Board of Directors and a professional Secretariat staff, delivers training that is relevant.  Forty years on, our Certificate grads set the standard for vocational training – in Canada and around the world.

If you are an employee working in the ‘global freight logistics’ sector register for the training you need, and look for your picture in the grad event photos next June.  If you are an employer, consider those of your employees deserving of an investment in their future – these individuals will provide your bench strength in the future.   We should all be proud of the vocational training we’ve built together, and grateful that we can continue to deliver the CIFFA Certificate program.

Why is eManifest so Badly Needed? A Review of Recent Events in Vancouver Helps Explain.

eman ruth blog

Toronto, Ont June 24, 2015       How much longer a global trading country like Canada can compete in an international trading arena with such archaic, outdated, obsolete, expensive, deconsolidation procedures is a serious question.  Since 2007 CIFFA has been at the table providing input and sector guidance on the design and development of eManifest for freight forwarders.  Did you ever wonder why we are so keen?

A review of recent events at Vancouver and at the CBSA Longroom in Montreal shows clearly why this country needs nationally standardized processing of Customs transactions, especially for our deconsolidation procedures.  Only with eManifest, the freight forwarder eHBL and the elimination of paper will we find any relief from the arbitrary actions of individual CBSA officers.

On May 31st the CBSA closed their satellite office at the Simard-Westlink warehouse where many freight forwarders had presented consolidation re-manifests for stamping by the CBSA.  On April 23, 2015, CIFFA wrote to the Canada Border Services Agency (CBSA) expressing our members’ concerns over the closing of the CBSA commercial satellite office and the termination of services at Simard Westlink in Vancouver. We could just tell that troubles would follow and sure enough they did.

As a result of the closure, starting June 1st requests for re-manifest validations were presented for stamping to other (different/ new) officers. Those officers didn’t agree with how re-manifests had been presented for the past decade and so rejected many consolidations.  Within three or four days chaos reigned.  Freight forwarders didn’t know why their manifests had been rejected, containers were going on storage and the phones at the association office began ringing.

After investigating with members and speaking with CBSA supervisors we identified the cause of the rejects, advising members in the eBulletins of June 4th and 16th of the change and the new procedures.  Again we wrote to the CBSA explaining that delays, frustrations and costs could have been avoided in this instance and could be avoided in the future if individual officers did not introduce immediate change – without notification or explanation.  In its response letter, it is clear that the CBSA simply didn’t understand that it wasn’t the closure of the satellite office that was the issue – we were well advised in advance about that.  It was the fact that suddenly a different CBSA officer was stamping paper and deciding – without any justification – that s/he didn’t like how re-manifests were presented and so rejected dozens of re-manifests out of hand.

Fast forward two weeks to Montreal and the problems forwarders are encountering with re-manifests at that Longroom.  The CBSA is under-resourced at Montreal.  New officers and temporary staff are manning the counter and are rejecting manifests left and right.  Remember, it takes +/- 48 hours these days to get stamped paper back in Montreal.  If a consolidation is rejected, it has to go back down to the Longroom and back in a pile.  If these reasons for rejects don’t make you laugh they will make you cry.

  • No Country for the shipper: 8000 all clearly show Chittagong, Bangladesh.  When the forwarder called to ask ‘What the ?? … the response was … wait for it …”Oh, is Bangladesh a country?”
  • Insufficient description: “Men’s Leather Baseball Gloves”. Response when queried” Oh, I thought we needed more than that”
  • My personal favourite – and a new one to me, “The description of goods on your 8000s don’t match the description of goods on the primary 9000 CCN.”

Some processing errors by the CBSA – which result in the same delays:

  • HBL’s came back stamped (in back of mail copy) but the 9000 not stamped, so couldn’t get freight from carrier.
  • 1 out of (example) 11 HBL was not stamped due to 9000 series being incorrect, which was the exact same number on all the other 10.

To make a long, sad story short – we must push through eManifest.  We must get to a place where we don’t send five pieces of paper for every HBL for stamping (Toronto) or two pieces (Montreal) and where individual officers can’t interpret complex DMemo’s.  We must have an electronic, data-driven, paperless process to move cargo in this country.  eManifest / eHBL can’t come soon enough.

Thoughts on Annual General Meetings and Member Value

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Jeff Cullen, CIFFA President

Toronto, Ont. April 17 2015   This year’s annual general meeting  (May 7th at the Mississauga Convention Center) is fast approaching and with it, my thoughts turned to two arresting questions. First, I wondered why someone would want to attend the AGM. That lead me to think about why companies and their employees commit to the association as they do every year and what value members receive from CIFFA. We’ll come back to talk about member value in a moment. First – what is the annual general meeting and why would someone want to attend?

The AGM is a business meeting that informs and gives members an opportunity to be heard. As an enticement and as part of our mandate to inform and educate we’ve arranged two exceptional guest speakers to start the afternoon. Betty Jo Parent will entertain us with the logistics of arranging North America’s biggest sporting event ever, the Pan Am/Parapan Am Games. Then, the GTAA’s Scott Collier will share with us some of the joys and challenges of moving goods and people through the country’s busiest airport.

National Board of Directors

At the AGM your volunteer national board of directors reports to you, the membership and asks for your approval on certain items. President Jeff Cullen will open with some short comments – rather like a State of the Union address that American presidents like to deliver. (But with no TV coverage).  Treasurer Bruce Rogers will share the audited financial statements and ask you to approve them and the choice of auditors for next year. All of the directors whose two year term is up have agreed to stand for re-election and you’ll be asked to vote on their nominations. In short, an annual general meeting.

And it is more. Last year CIFFA created new national volunteer committees: Airfreight, Seafreight and Customs. Come to the AGM and learn first-hand of some of the many actions CIFFA has taken on issues that affect your business every day, as the chairs of these committees recap the highlights of our work over the past year.

For the first time since 2009, this year you will be asked to vote on a motion to increase the member fees that every company pays to belong to CIFFA. And it is this vote that lead me to think about the value that members receive from the association and to think about cost and benefits of membership. What is member value and why do members support their association?

Member Value

The answer is that value means different things to different members, depending on their needs.

For some it is an instant response to a technical question. Others may value access to latest industry information; great networking opportunities; representation with government, ports, carriers; world class training; or discounted products and services.

How member benefits translate to member value depends on you, your business, your customers, your needs. Membership is about expanding your opportunities and taking advantage of member benefits.

Check out CIFFA’s new website to view some of the benefits. Some – maybe all of these benefits can provide great value for your company. If you know the benefits you can decide how membership can create value for your organization.

Come to the annual general meeting. Learn more about your association. Ask questions. Be heard.

CIFFA is run by members for members and is dependent on members’ support. It is member commitment which contributes to the growth of the association.

‘Freight forwarders: helping Canadians do business with the world’

CIFFA Represents FIATA at ICC/USCIB “Customs and Trade Facilitation Symposium” in Miami

Trade logistics and customs regimes: Boosting regional and global supply chains?

Q1: International freight forwarders arrange the movement of goods through global supply chains that must, by their very nature, be highly collaborative across all sectors.  Global trade is the lifeblood of global logistics service providers. As the ‘Global Voice of Freight Logistics’, what does FIATA believe are the ‘ideal conditions’ that would promote an enabling environment for global logistics, transportation and cross border movement of goods?


Thank you Oliver and thank you to the ICC and USCIB for inviting FIATA, the international federation representing freight forwarders and ‘global logistics service providers’ to share our thoughts today on trade facilitation. And, just to clarify any confusion, I am not Marco Sorgetti, the Director General of FIATA.  Unfortunately Marco has broken both of his ankles and is in a Swiss rehab hospital and so asked me to come from Toronto to speak on his behalf.

We have just heard from Mr. Simon Schofield about Samsung’s global value chain.  I’m sure you can all imagine how complex Samsung’s supply chains are.  And I ask you to imagine just how complex it all becomes when you have to deal with a few hundred (or a few thousand) of these global supply chains for different customers…. And imagine how sophisticated a logistics service provider’s systems must be to accommodate the different requirements of every regulatory agency in every geography — and how robust their capacity must be and how knowledgeable & competent their staff.

Every year FIATA supports a Young International Freight Forwarder of the Year Award – a valuable prize awarded to a young (under 32) freight forwarder who has completed the FIATA Diploma.  Just a glance at the winning dissertations posted on the FIATA website shows a small sampling of the complexity facing the global movement of goods.  Whether it is flying radioactive isotopes from South Africa to Namibia, or moving containers of paint and a football (soccer) grandstand for the world cup from Germany to Brazil or arranging to fly frozen or infected brain tissue to a lab in Ireland, the sheer volume and types of goods moved by forwarders is mind-boggling.

And just imagine how complexity explodes when every customs authority and every transportation / regulatory body introduces just one little anomaly / unique requirement.

And so, what are the ideal conditions that would promote an enabling environment for the effective and efficient movement of goods across geographies and, most especially, over the barriers that borders create?

At the outset, I will say that capacity and competency are two critical factors in the movement of goods.  Governments must invest in the development of physical infrastructure – at ports, airports, railroads needed to handle the amount of cargo moving around the world.  And governments must invest in the information – technology infrastructure – needed to support the movement of data around the world.  And, governments must support human capital requirements for labour in an evolving world where jobs are changing rapidly and where training / re-training is needed.  In particular, governments must develop holistic, strategic intermodal transportation strategies and the underlying technology strategies to ensure that goods and data can move into, through and out of a country.  These seem to me, to be obvious, relevant and essential.

Ideally, Customs authorities must have the funding and resources to ensure that technology can be used wherever possible to conduct risk assessment, to audit compliance and to facilitate the movement of goods over the border.

FIATA also believes that improvements can best be achieved through development of performance indicators for infrastructure and border management processes, including for instance transit and wait times, Customs release times, examination and security delays.  I’m sure that our next speakers will also talk to the need for acquisition and analysis of key data against established objectives.  Oh, did I mention the need for benchmarking against best in class performance?

What are some other ideal conditions?

We must work to global standards and FIATA fully supports the work of such organizations as the World Customs’ Organization and their SAFE Framework of Standards.  Coincidentally, just a month ago we became alerted to the fact that Canada had signed a ‘Customs sharing agreement’ with China.  Flags went up, everybody got their knickers in a twist, letters were written and meetings were held.  Only to discover that Canada has some 9 ‘Customs Mutual Assistance Agreements (CMAA)’ already signed– including with the USA and with the EU, that the USA has more than 60 similar agreements and that Canada uses the standardized template provided by the WCO.  There was no need to be anxious just because the press announced a Customs Sharing Agreement with China, because globally accepted templates were used.  It is the same with the use of something as simple as the ICC’s Incoterms2010 – where everyone in the chain who sees that term of sale understands what it means.  So, the development, promotion, communication and use of global standards is ideal.

Rules must be clear, and they must be in simple language – what in Canada the courts are calling ‘clear English’;

o   they must be predictable;

o   clearly communicated

o   and in a timely manner

o   must be universally applied

As Customs authorities implement ‘advanced information’ regulations for example, FIATA supports the use of an established standard, such as the World Customs’ Organization’s Safe Framework of Standards and the 7+1 data elements.  This makes rules predictable. Everyone understands those data elements and universal compliance is possible.

If you want to look at regulations that have not benefited from clear communication and good timing one cannot help but note the “lost in translation” effect when China changed their business tax and VAT on international transportation last year. FIATA was about the only body with first-hand information, but the misinterpretations that some unofficial translations allowed caused massive confusion in the transportation sector and driving costs. Like the on-again, off-again Chinese Customs Advance Manifest (CCAM) Regulation it is challenging for organizations to embrace and implementation what are almost life-size tests for the Chinese, so cultural differences impact clarity.

FIATA posted a paper in 2012 underscoring the concept that data (advanced data in particular) must be eligible to be provided by the party most likely to have the data:

‘Dual filing or multiple filing’ as supported by the WCO SAFE Framework of standards.  So for example, the EU system in which the carrier is solely responsible for ENS filing could, to our thinking, compromise sensitive commercial data.  The Canadian eManifest system on the other hand will allow filing by the carrier, the importer and the freight forwarder.

Globally, we must have knowledgeable, trained, engaged work forces  – not only within the importer/ exporter community and not only in global logistics service providers, but in Customs authorities and other regulatory bodies.  The private sector is ideally positioned to provide insights to regulators. The FIATA Diploma program, which is administered in some 54 countries by national associations, delivers exceptional vocational training – and in countries where resources are very constrained, FIATA provides Train the Trainer programs to help jump start their training.  Something else that the association strongly supports is that national governments should develop a consultative framework that supports private sector/ Customs authority interaction. The private sector knows how business works around the world and is prepared to help develop feasible and practical rules.

We have to talk briefly about systems. Systems connectivity is critical to the efficiency of logistics networks– data cannot be provided in paper. Systems must be secure, privacy must be enforced and recognition given to the concept of safeguarding commercial information.  The world’s traders compete in a highly competitive global arena and they must be absolutely assured that commercial data will be secured.

Transportation networks and underlying technology & regulatory regimes must support and facilitate the movement of goods into, through and out of every country in the world.  Almost every national government supports ‘export’ and almost every national government restricts/ limits imports and transit goods.  Regulators must recognise that in today’s global economy inputs and outputs are imported and exported many times across many borders before final consumption anywhere in the world.  The global economy is truly a multi-faceted, inter-linked and inter-looped chain – connected by logistics.

In its position paper on the Open Working Group (OWG) of the UN General Assembly on Sustainable Development, FIATA closes with the comment that ‘ideally we should all travel on smart infrastructure, enjoy seamless border procedures and reach our destination (goods as well as passengers) undisturbed and without any waste of time and energy. One can say this is a dream, but FIATA maintains that we must live up to our dreams and work to make them possible with appropriate policy choices, today and tomorrow.

pdfICC for FIATA Miami 2015 Trade Facilitation Symposium

Executive Director’s Blog: Finding Value in Conferences: CLC in Vancouver and ICC/ USCIB in Miami

TORONTO, Ont. February 16, 2015    Acronyms aside, CIFFA is receiving more and more opportunities to represent the international freight forwarding sector on the world’s stage.  One of the association’s three strategic pillars is representing our industry, ensuring that the views of member firms are considered by regulators, carriers, ports and the trading community, not only here at home, but around the world.  Normally, we look to our international association FIATA to express our views on the international stage while CIFFA speaks for forwarders in Canada.  At the end of February, however, due to an unfortunate accident that has laid up FIATA’s Executive Director who was scheduled to speak, I will represent FIATA in Miami at the International Chamber of Commerce (ICC) and its affiliate the United States Council for International Business (USCIB) Customs and Trade Facilitation Symposium February 22-24th and at the following meeting of the ICC Commission on Customs and Trade Facilitation.

But first things first. Last month the industry came together at the fabulous Vancouver Convention Center to network, share insights, speak and learn at the Cargo Logistics Canada  conference and tradeshow.  The show organizers seem to have the formula right – charging for individual sessions and drawing crowds to the tradeshow floor.  The challenge comes from trying to choose the right seminar/ panel / workshop to attend as often three or four events run concurrently.

At the opening morning panel on January 28th, I was pleased to moderate a lively question and answer format discussion entitled “Intermodal Supply Chains:  Creating Realistic Expectations.” Four industry leaders talked with me (and some 200 delegates), sharing their thoughts on two basic questions.

  1. How do Canada’s traders – the importers and exporters who drive our economic growth, know what to expect from their global supply chains?
  2. What can we — the carriers, ports, freight forwarders, railroads — do to help establish realistic expectations for our customers and our customers’ customers?


Brian Martin, Vice President Sales and Marketing , Kuehne + Nagel
Wolfgang Freese, President, Hapag-Lloyd (A) Inc.
Jean-Jacques Ruest, Executive Vice-President and Chief Marketing Officer, CN
Tony Boemi, Vice-President, Growth and Development, Montreal Port Authority

The subject was especially timely, considering the current chaos at US West Coast ports and Port Metro Vancouver and the unsettled railroad labour situation in Canada.  The panelists reinforced the need for importers and exporters to recognize that marine intermodal shipping – with extremely long supply chains and complex interrelationships between multiple players – cannot be considered ‘precision shipping’ and that traders must take steps to manage their supply chains accordingly.  One of the key messages that came from the panel included the need for better and more frequent communication and data sharing.

Mr. Ruest from CN shared a frank and informative ‘short –term’ future when he talked about the labour situation at both of Canada’s major railroads, a future which we are living as I write this blog of multiple some two weeks later. Mr. Ruest’s remarks focused on what Canadian shippers have experienced for the past few winters regarding labour and what they might expect this year. (Members see eBulletin January 30, 2015).

On the second day of the CLC conference Rui Fernandes , Partner, Fernandes Hearn LLP and Matthew Yeshin, Managing Director, Marine Practice Leader, Marsh P joined me at a fascinating (and just a little scary) review of contract law at a second panel I facilitated for CIFFA entitled “Read the Fine Print: Risk and Liability in Global Shipping.”

It is with pleasure that I note here that all six of our expert speakers at the CLC conference represent employers who are associate members of CIFFA.

And then, on to Miami February 22-24th for the ICC/USCIB Customs and Trade Facilitation Symposium where CIFFA will take the role of the global logistics service provider in conversation with senior delegates from the World Trade Organization (WTO), the World Customs Organization (WCO), organizing ICC and a myriad of other speakers and delegates. Discussions will focus on the most effective means of facilitating the global movement of goods while balancing security and risk at the border. My job at the symposium will be to answer two questions.

Q1: International freight forwarders arrange the movement of goods through global supply chains that must, by their very nature, be highly collaborative across all sectors.  Global trade is the lifeblood of global logistics service providers. As the ‘Global Voice of Freight Logistics’, what does FIATA believe are the ‘ideal conditions’ that would promote an enabling environment for global logistics, transportation and cross border movement of goods?

Q2:  We live in a world of ‘advanced cargo data’. What improvements could be made in regards to exchanging tracking information – or any data – associated with clearing containerized goods through customs, port and terminal, and rail carriage systems for inland transportation?

As the Symposium website says, “The world economy relies on unprecedented interdependence and connectivity. Global supply chains are increasingly vital to connecting enterprises to raw materials, labor force expertise, new markets and consumers. No area of international economic policy is more integral to expediting globalized trade than customs and trade facilitation. Harmonized and efficient trade boosts competitiveness for all businesses, especially for small and medium-sized enterprises in emerging markets. “Finding Global Solutions to Cross-Border Challenges” will focus on streamlining trade and limiting cross-border inefficiency and friction.”

I relish the opportunity to share our voice and to focus on opportunities to help reduce the inefficiencies and friction which freight forwarders face every day as we “Help Canadians Do Business with the World.”

Choke Points, Challenges, Congestion, Capacity – West Coast Ports

Our west coast ports in particular point to a supply chain that is stressed. Last month I participated in a live JOC webinar where we discussed signs that increasingly point to a supply chain struggling to keep up. Starting around minute 20, I describe the ‘snapshot of the summer of 2014’ and outline some of the reasons for the problems. The pictures of Prince Rupert and Vancouver were not pretty and the situation hasn’t changed dramatically since.
See: Prince Rupert Performance Statistics

Both west coast ports and terminals are backlogged trying to load containers to rail, many of which are bound for the U.S. Midwest through the two major Asia Pacific Gateway ports, a spike at least partially due to this summer’s US west coast labour negotiations. Congestion is also evident on the intermodal network, where railroads are struggling to recover from a 2013-2014 winter ‘from you know where’ that hit service levels hard. Add in a bumper grain crop and lots of oil moving by rail and we have a recipe for challenges. But, we have to ask the question – “Is this a ‘perfect storm’ type of scenario not likely to be replicated over the next five years or is this an indicator of the need to build greater capacity because this could happen more and more frequently over the next few years?”
Global trade is a mainstay of Canada’s economic growth strategy. Canada has negotiated nine new free trade agreements since 2006 and has many more in the works, from the CETA (Comprehensive Economic and Trade Agreement) with the European Union to the Trans-Pacific Partnership (TPP). To support this international trade, Canada needs to invest in our physical and our communications infrastructure and in ensuring that we have the right regulatory regime in place to support trade.

Last March, in the middle of the truckers’ action at the Port Metro Vancouver CIFFA wrote a letter to the Honourable Lisa Raitt, Transport Minister. We opened by saying, “Canada’s successful conclusion of a free trade agreement with South Korea this week will most certainly fail to drive economic growth, employment or opportunity for Canadians if Canada’s premier Asian gateway at Port Metro Vancouver is not open for business. And, more importantly, Canada’s entire investment in international trade will be for naught if Canadian exporters and importers do not have a global transportation system that is reliable, trustworthy and competitively priced.”
Everything isn’t doom and gloom. The Port of Halifax on Canada’s east coast has invested heavily over the past few years in pier extensions, new gates and cranes and has 6 km of rail on and are preparing for the big boost in trade expected from the CETA. Likewise Port Saint John New Brunswick has rapidly growing container numbers and flexible rail service. The Port of Montreal is also investing heavily to connect that European market serving the US mid-west, Ontario and Quebec. All of our east coast ports seem ready and able to accept all water cargo from Asia now and position themselves for a spike from Europe in the future.

The Association of Canadian Port Authorities President Wendy Zatylny wrote in the Globe and Mail “We will only be able to capitalize on this expanded market and increase our competitiveness through strengthened port facilities and improved supply chain efficiencies. With the expansion of trade comes the necessity for the expansion of port infrastructure.”

It is more, however, than simply investing in port infrastructure and physical capacity. It is investment in the development of an integrated, national, intermodal transportation strategy. It is working across industry sectors to create an information pipeline that delivers data to every stakeholder – terminals, railroads, the CBSA, carriers, forwarders when needed. It is developing a regulatory environment that supports international trade and the movement of goods. It is building capacity and competency.