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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.