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Advocacy is one of CIFFA’s three key pillars. On the Customs-related front, here is an update of several initiatives CIFFA has been closely monitoring through its work on various committees.
CBSA “Single Window” on gradual approach
The Single Window Initiative (SWI) is a federal government process for gathering information on imports into Canada.
As of April 1, 2019, submitting an Integrated Import Declaration (IID) through CBSA’s new “Single Window” was meant to become mandatory. At press time, Canada Border Services Agency (CBSA), in partnership with participating government agencies, said it was “going to responsibly implement SWI by not imposing a mandatory go live on April 1, 2019.”
April 1 had been the deadline to “sunset legacy service options OGD PARS and OGD RMD,” per the CBSA SWI webpage.
CIFFA will provide more-detailed information as it becomes available.
Instead of submitting different information to different government agencies, as in the past, information on imported goods can be provided through a single submission to CBSA.
Once CBSA receives the required information, it shares the pertinent elements with the PGA(s)
Participating Government Agencies (PGAs) responsible for regulating the goods in question. The PGAs then assess that information and provide a decision if and as required.
With CBSA serving as the “single window”, the process has been simplified for importers, who no longer have to submit duplicate information to different agencies.
The aim is to simplify the import process but, in some cases, it will mean more advance information is required than before, with all data elements required by participating government agencies provided in the IID.
The IID can be sent to CBSA for processing up to 90 days prior to the arrival of the goods, so importers can receive recommended border decisions before shipments reach the border.
Once CBSA receives the required information, it shares the pertinent elements with the PGA(s) responsible for regulating the goods in question. The PGAs then assess that information and provide a decision if and as required.
CERS to Replace CAED: going live December 2019
CBSA is replacing the Canadian Automated Export Declaration (CAED) with the Canadian Export Reporting System (CERS)
Development is progressing and CBSA is in the process of extending the go-live date for CERS from July 2019 to December 2019 (pending confirmation).
CBSA, in partnership with Statistics Canada (SC), is developing an Activation Approach to support the transition of existing Canadian Automated Export Declaration (CAED) / Data Loading Module (DLM) /SRP users to the new system. This change is due to revised testing estimations to ensure CBSA can provide a solution that meets the needs of the export community.
All existing users of CAED/DLM/SRP will be required to activate their business account in CERS during the revised onboarding window (illustrated below).
The pilot phase will commence in January 2020 and include a select number of trade chain partners (TCPS). These TCPs would include active reporters from CAED, DLM, and SRP.
The waves will begin after the successful completion of the Pilot phase and include a gradual onboarding of the remaining TCP’s who are active CAED, DLM, and SRP reporters.
Electronic Export Reporting mandated: no more B13A
CBSA is proceeding with the implementation of a prescription document that will mandate electronic export reporting. Following implementation, the paper B13A Export Declaration form will be eliminated. The coming into force of the prescription document will be aligned with CERS implementation. The CBSA will start informing exporters of these changes in Spring 2019. Communications will occur through a Customs Notice, the CBSA and Statistics Canada websites, and at export reporting offices where paper B13As are stamped.
Definition of Exporter: Because the Reporting of Exported Goods Regulations does not clearly identify the party who is required to report exported goods and does not clearly identify all goods that must be reported, the definition of exporter has been identified as the primary cause of ambiguity in the Reporting of Exported Goods Regulations. Definition of exporter will then be repealed.
Summary Reporting Program (SRP): addressed in future regs
Since goods of unknown risk are being reported after export, thereby evading CBSA pre-export risk-assessment, the CBSA will amend the eligibility criteria to refocus the SRP to its original purpose, a “facilitative reporting method for bulk goods (e.g. wheat, lumber, coal).”
Goods that are not considered bulk will no longer be eligible for the program and will have to be reported on a transactional basis.
This regulatory change will not be included in this round of regulatory amendments and will be addressed in a future regulatory package.
CARM: Towards a Modern Interface
The CBSA’s Assessment and Revenue Management (CARM) project is a multi-year business transformation initiative. Once implemented, it aims to facilitate trade compliance and enhance the use of data analytics to streamline business processes, providing, as the agency puts it, a “modern interface” for importing into Canada, and giving importers self-service access to their own information.
As the project moves into the next stage, CARM will continue to work with the trade community to:
- Validate its design via the use of prototypes
- Refine business processes and requirements by running real-world scenarios with system functionality
- Seek trade’s participation in testing the CARM solution
- Perform “day in the life” testing using real-life business scenarios
- Perform certification testing to validate that integration points are working correctly