Starting November 7, 2016, one of the long-anticipated timelines for Canadian eManifest will begin: the implementation of ACI eHBL (Electronic House Bills) that applies to all freight forwarders, as mandated by the Canada Border Services Agency (CBSA). Are you ready for the transition? Here are some key points to remember as you prepare for compliance.
What is eHBL?
The Government of Canada’s Advance Commercial Information (ACI) program includes the eManifest initiative, which aims to improve the identification of high-risk shipments to Canada while facilitating the movement of legitimate cross-border trade. ACI is being implemented in stages to allow the trade community to prepare for the transition. eManifest is the third phase of ACI, following the rollout of phases 1 and 2 that required air and marine carriers to submit electronic advance cargo and conveyance information to Canada Border Services Agency (CBSA).
When fully implemented, carriers, freight forwarders and importers in all modes of transport (air, sea, rail and highway) will be required to submit cargo and supplementary data to CBSA before arrival at border crossing or loading at a foreign port. For freight forwarders, electronic House Bill of Lading (eHBL) data must be submitted to Customs in advance.
Electronic House Bill of Lading (eHBL)
Since June 2013, freight forwarders in all modes of transport have been able to transmit advance House Bill of Lading information on consolidated shipments to CBSA using electronic systems. Today, a voluntary compliance period is in effect for freight forwarders. However, CBSA urges forwarders to prepare as early as possible and ensure their ability to comply with the eHBL requirement before it becomes mandatory. Until that time, supplementary reports in air and sea modes are required to be filed using the EDI (Electronic Data Interchange) method.
Once advance eHBL filing becomes mandatory, freight forwarders in air and sea modes will be required to submit supplementary cargo data for consolidated Freight Remaining on Board (FROB) only. This covers shipments entering Canada or shipments in transit through Canada. The general requirements are:
· Advance eHBL data must be received and validated by Customs within the specified eManifest time frames.
· Freight forwarders or Non-Vessel Operating Common Carriers (NVOCCs) must obtain a CBSA-issued carried code, a four-character code that begins with 8.
· Freight forwarders or NVOCCs can submit advance eHBL data to CBSA using Electronic Data Interchange (EDI) or the eManifest portal.
· Freight forwarders/NVOCCs and service providers adopting EDI must apply to the Electronic Commerce Unit and undergo acceptance testing first.
Vessel Operating Carriers (VOC) Requirements
Vessel Operating Carriers (VOCs) may act as third party agents and submit eHBL data to CBSA on behalf of Freight Forwarders/NVOCCs. The submission must be sent using the forwarder or NVOCC’s carrier code.
eHBL and Close Messages Time Frames
The freight forwarder must submit House Bills and Close Messages to CBSA within the specified time frames (up to 90 days in advance). Transmissions must be received and accepted by Customs within the following eManifest time frames:
· Sea: 24 hours prior to loading or arrival, depending on the type and the origin of goods
· Air: 4 hours prior to arrival or at time of departure
· Rail: 2 hours prior to arrival
· Highway: 1 hour prior to arrival
eHBL Submission Process
The freight forwarder who has contracted with the primary carrier prepares the House Bill(s) and sends the electronic data to CBSA via EDI or eManifest portal. Upon the receipt of the House Bill, the portal automatically flags missing data or incorrectly formatted data for correction before sending the message to CBSA. If there are no errors, the Portal directly submits the message to CBSA. The status of the submission during this time is set to “Updating.”
Once validation is complete and CBSA acknowledges receipt of the House Bill, the status will change to “Accepted” or “Rejected.” Rejected submissions usually contain business rule validation errors, and the forwarder can check the reason for rejection under “Status Details.” The user must correct the error and either re-submit or cancel the House Bill.
After sending all required House Bills, the forwarder must submit a Close Message that connects all the submitted House Bills to the previous Cargo Control Number (CCN) to declare closure of the shipment. For deconsolidated House Bills, each subsequent freight forwarder is responsible for submitting House Bills and Close Messages to CBSA to close the shipment. If the pre-arrival release or Close Message on file with CBSA is linked to the client’s House Bill, the Matched status is set to “Yes,” meaning that the document has been linked to another document.
For non-consolidated House Bills, “Matched” means the document is linked to the pre-arrival release submitted by an importer or broker. For consolidated House Bills, “Matched” means the document is linked to a submitted Close Message.
Shipments are considered “consolidated” when multiple shipments are grouped together by the carrier/freight forwarder and shipped to a carrier, agent or forwarder as one shipment. The consolidated shipment is reported to CBSA under one CCN and one cargo control document (CCD). Shipments are considered “deconsolidated” when a consolidated shipment is divided into individual shipments consigned to individual consignees. The deconsolidated shipment is reported to CBSA on individual CCDs, which are also called supplementary reports.
In-transit or U.S. Exports through Canada
For consolidated in-transit shipments moving by rail or highway, the carrier must provide consolidated pre-arrival electronic cargo and conveyance data to CBSA, while the freight forwarder must provide pre-arrival House Bill data including detailed description, consignee and shipper information.
Freight Remaining on Board (FROB)
For consolidated FROB, the carrier must submit consolidated pre-arrival electronic cargo and conveyance information to CBSA, while the freight forwarder must submit supplementary reports.
Mode of Transport and Route Changes
If the carrier changes the mode of transport or route, a change should be submitted reflecting the correct primary CCN and correct mode of transport. The HBL Close Message must be cancelled and re-submitted to link the changed house bills to the previous CCN.
Consolidated Cargo with Multiple HBLs and Single Consignee
Consolidated cargo with multiple shippers means multiple separate shipments. In this case, CBSA would require multiple House Bill submissions reflecting the details of each shipment. Each House Bill submission must be linked to the consolidated cargo (previous CCN) with the same Close Message. For example, four different shippers mean four different shipments within the consolidation. Four HBL submissions are needed, with each HBL linked to the consolidated cargo with the same Close Message.
If a forwarder is managing one House Bill without sub-House Bills, this would be considered non-consolidated and subject to release. However, the House Bill still needs to be filed to CBSA within the specified eManifest time frames.
Lower-Level and Top-Tier HBL Filings
Lower-level and top-tier HBL filings must contain all mandatory data elements as part of the HBL submission. Cargo description for consolidated house bills is less detailed, however.
e-HBL for Back-to-Back Shipments
For back-to-back shipments, the carrier submits the House Bill for primary consolidated cargo, while the freight forwarder submits the House Bill Close Message. This Close Message references the CCNs of the HBL directly below it and the CCN of the previous cargo above. The primary cargo does not have to be on file before the Close Message is submitted.
The freight forwarder submits House Bills for non-consolidated cargo. This House Bill contains a unique identifier or CCN and references the CCN of the primary cargo. Each House Bill represents the shipment within the consolidation and contains the cargo description, shipper and consignee details and other data.
Data Transmission Options
Freight forwarders can send electronic house bill data to CBSA using the eManifest portal, third party solution or Electronic Data Interchange (EDI).
ACI e-HBL Portal
Free to use
Repetitive manual data entry
Suits low volume users
Third Party Solution
Paid services for greater customization and integration options
Minimise data re-entry as users’ past and present shipment details are stored to enable data reuse in the future
Suits high volume users
One of the CBSA-approved ACE ACI eManifest and eHBL service providers is CrimsonLogic Global eTrade Services (GeTS).
ACI e-HBL Portal: Transition Period
During the transition period from for ACI eHBL, the CBSA will not issue penalties for non-compliance and will work closely with freight forwarders to implement corrective measures.