CBSA Set to Streamline Plans for Canada's Upcoming eManifest Importer/Broker Requirements

NIAGARA-ON-THE-LAKE, Ontario -- The Canada Border Services Agency looks set to streamline its plans for upcoming advanced import data transmission requirements for importers, similar to the U.S. Importer Security Filing, as it moves toward implementation of the eManifest importer requirement by 2018 at the earliest, according to panelists from CBSA and the Canadian Society of Customs Brokers at the CSCB National Conference on Sept. 26. Rather than require two separate transmissions, CBSA will instead require filing at the same time and in the same system as cargo release data, said Melanie Bedard of Milgram & Company, who led the panel discussion.

CBSA had originally been expected to adhere to a two-step “Advanced Trade Data” (ATD) framework, with importers submitting ATD and cargo release data separately, Bedard said. However, recent discussions between CSCB and CBSA have led to the Canadian customs agency’s informal adoption -- no regulations are yet in place -- of a single-step “Advanced Importer Data” (AID) approach, wherein the AID admissibility data would be submitted in a single transmission by the importer or its broker alongside the Pre-Arrival Review System (PARS, similar to the U.S. Pre-Arrival Processing System, or PAPS) release data. There would be no option to transmit the admissibility data on its own, she said.

As with ATD, transmission of AID would be required before arrival or loading, depending on eManifest requirements for each mode of transportation. Transmission for rail cargo would have to occur two hours before arrival at the border; for truck, one hour before arrival; for air, four hours before arrival (or at time of departure); and for ocean cargo, 24 hours before arrival for U.S. shipments, or 24 hours before loading for non-U.S. shipments. Particularly for ocean cargo, the one-step AID option, which would require cargo release data transmission 24 hours before loading, could present problems if the importer doesn’t yet have all the required data, Bedard said.

To resolve the issue, CBSA recently proposed to allow trusted traders in the Customs-Trade Partnership Against Terrorism (C-TPAT) and Canadian Partners in Protection (PIP) trusted trader programs to transmit 96 hours prior to arrival in Canada, Bedard said. For ocean shipments from China, that could mean 20 days after the cargo leaves the Chinese port, she said. “It was a very good solution” that will provide much-needed benefits to trusted traders, Bedard said. Importers that need the extra time will have to apply to be a trusted trader, so CSCB has “advised CBSA very clearly that for that to happen resources have to be there to process applications and work the importers through the program,” she said.

In another change, CBSA will also allow filing of the AID only by the importer or its licensed customs broker, Bedard said. Under CBSA’s plans for ATD, any party “working in the basement of their home” would have been able to transmit the data, she said. CSCB had advocated to have it filed by the customs broker or importer, “who have the expertise and information to submit that data,” Bedard said. The broker association had also pushed for transmission in one system to simplify any programming required for implementation, she said. “CBSA truly listened to those concerns,” Bedard said.

The AID and release data will be transmitted via the Integrated Import Declaration, the “single window” transmission type including data from CBSA and other government departments (OGDs) that is currently in the early stages of adoption, Bedard said. CBSA has said that importers and brokers would be given 18 months’ notice before the IID becomes mandatory, Bedard said. That means IID and the AID advance data would not be required until 2018 at the earliest, she said. CSCB will be pushing for CBSA to make both mandatory at the same time so the Canadian trade community can implement them in a single transition, Bedard said.