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…
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.
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)