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)