Customs ACI eManifest Changes and Imports with Multiple Loads

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By Latitia Scarr, CPMA Produce Now Jun 30, 2015

On May 6, 2015, CPMA sent out a notice from the Canada Border Services Agency (CBSA) that eManifest requirements were now mandatory. While the requirements announced are directed towards carriers, importers are affected by virtue of changes to the information provided by the carrier to a customs broker for submission to CBSA and the Canadian Food Inspection Agency (CFIA) for release. In particular, this change affects shipments with loads picked up from multiple vendors and may result in increased processing fees. Under the old system, one Cargo Control Number (CCN), also known as a PARS, could be submitted for an entire shipment, regardless of the number of pickups. However, under the new system, a carrier will be required to provide a CCN for each pickup and these must in turn be submitted separately to CBSA and CFIA for clearance. 

CBSA has come up with a solution to this issue using the Single Window Initiative (SWI), the new portal for submission of requirements from other government departments such as CFIA, Health Canada, etc. Single Window can be used to submit an Integrated Import Declaration (IID) and allows the submission of multiple CCNs for one release. However, as CFIA has not yet come onboard, this is not yet an option for use. CFIA has indicated that they expect to begin testing with industry this summer, and expects to be fully onboard at some point before the end of the year.  

CPMA has raised the industry’s concerns on this delay and potential for increased cost to the produce industry with CBSA and CFIA. They understand the concerns and are working to ensure CFIA onboarding to Single Window as soon as possible. 

As part of the implementation of the eManifest requirements, CBSA had provided the following timelines.  

• From May 6, 2015, to July 10, 2015, the CBSA will provide carriers with a period of transition during which penalties for non-compliance will not be issued. The Agency will work closely with carriers on corrective measures to help them comply with eManifest requirements.
• From July 10, 2015, to January 10, 2016, carriers who do not comply with eManifest requirements may be issued zero-rated penalties (non-monetary) under the CBSA’s Administrative Monetary Penalty System (AMPS).
• Beginning January 10, 2016, carriers who do not comply with eManifest requirements may be issued monetary AMPS penalties.

Until CFIA is available in Single Window, produce importers have two options for submitting their imports with multiple pickups for clearance. Imports can be submitted using the new system, with the potential for increased processing fees for your shipments.  The other option is to submit under the old system, with one CCN submitted for all loads. After July 10th, this may result in a non-monetary AMP being issued. However, CBSA has confirmed that it would not use contravention history from the zero-rated AMPS period to determine the issuance of future penalties. The non-monetary AMP period will end on January 10, 2016. CPMA encourages you to speak to your carrier about which option works best for you.

CPMA also encourages you to speak to your customs broker about Single Window and their plans to adopt the system to submit imports for release in the future. Single Window is an optional system and adoption of it by brokers may vary.   

Latitia Scarr
Manager, Government Relations and Issues Management
lscarr@cpma.ca
613-226-4187 ext 227

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