Border Issues Update

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Last week the Canadian Trucking Alliance met with Canada Border Services Agency  to go over outstanding issues related to eManifest.  Here is a summary of issues discussed:

 Regulations and Enforcement Date of eManifest

  • The regulatory process in Canada is carried out in a series of steps that could result in lengthy delays to implementation and enforcement of regulation.  Earlier in 2014 the regulations for eManifest were published and stakeholders, including CTA, had an opportunity to comment.  The next step requires CBSA to respond to stakeholders’ comments.  CTA anticipates a response from CBSA within the coming weeks.  There will be 45 day warning before the Gazette Part II is published and then a delayed enforcement period after that originally slated to be an additional 45 days.  CTA fully anticipates that eManifest will be mandatory early in 2015.

 Sunset of the Post Audit Carrier Program

  • As of August 1st, 2014 CBSA sunset the Post Audit Carrier Program.  Post Audit carriers that are members in CSA program will continue to enjoy the privileges of the Post Audit program.  Post Audit carriers that had applied to CSA but had not yet been approved have had their applications expedited through the approvals process and will be grandfathered into the Post Audit privileges.

Mandatory eManifest for empty conveyances

  • Currently carriers using eManifest are able to voluntarily supply CBSA with eManifests for empty conveyances coming to Canada.  While CBSA intends to mandate eManifests for all empty conveyances, there is still the outstanding issue of the carriers ability to supply a driver with a bar code in the US for an empty.  The agency recognizes that industry is not yet in a position to comply with the requirements to present a bar code for an empty and while included in the mandate, there are no plans to enforce mandatory eManifest for empties until industry has a means to comply.

Sunset of RNS messaging and new message “maps”

  • In November of 2013, a small group of highly specialized carrier technical experts participated in a focus group with CBSA and CTA to determine the impact of sun-setting the current RNS system, replacing RNS messages with new messages.  The impact has many layers and CBSA fully intends to understand all impacts and provide mechanisms to accommodate industry needs.  At the time, the Agency needed to proceed with internal enhancements before further discussion could be had.  CBSA is now in a position to resume the focus group discussions with industry.  CTA anticipates the next focus group meeting to be scheduled in coming weeks.  In the meantime, carriers may already be seeing some of the new messages that are available.  An ECCRD for a subset of notices will be available Jan 2015 and the ECCRD for the full suite of notices is expected to be available spring 2015.

Multiple CCN’s on a PARS

  • Many importers and brokers have asked carriers to report multiple cargo control numbers to one PARS, but the legal requirement for carriers is to report one PARS for every cargo control number.  Many importer and broker system aren’t built on this principle, so CBSA has undertaken to  provide a mechanism where brokers can report multiple CCN’s on a PARS.  In order to do this, customs brokers must volunteer for the IID (Integrated Import Declaration).  Carriers requirements remain unchanged and carriers must continue to report one CCN per PARS.  Carriers that report multiple CCN’s on a PARS could be liable to penalty and should instead encourage all importers and customs brokers to volunteer for CBSA’s IID system.

Single Window Initiative

  • Much progress has taken place between CBSA and Participating Government Agencies (PGA’s) to develop data requirements and transition to a single window process.  Six PGA’s have already coordinated data requirements with CBSA; TC, HC, PHAC, CFIA, DFATD and NRCan).  The Single Window Initiative will allow importers and brokers to submit import permits and other required documents to CBSA and the PGA’s simultaneously.  While there is no direct impact to trucking, the success of this project will no doubt create a more seamless import process for goods regulated by these 6 PGA’s, meaning carriers hauling shipments controlled by these agencies will likely experience less delays and paperwork issues when trying to cross the border.

 CBSA Bonded Warehouse Issues

  • Some carriers are still reporting issues with CBSA Bonded Warehouses.  Reports indicate Montreal seems to be the most offender of inconsistent practices.  CTA is asking any carriers with similar inconsistency frustrations to get in touch with Jennifer at jennifer.fox@184.107.41.74 as CTA continues to work with CBSA to address the issues, and CBSA works to modernize the processes for bonded freight.

 

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