If you’ve spent any time at all in the transportation business then you know that, despite everyone’s good intentions, overages and shortages happen. Most carriers have systems and policies in place to limit these mistakes but we all know that it is more a matter of “when” they will occur than “if” they occur.
When it comes to domestic transportation, these mistakes are an inconvenience, can cause service failures and may negatively affect your credibility with your customers. When it comes to cross-border transportation, the implications are much more serious. “Hey, we forgot to throw a pallet on that truck from Toronto to Calgary”. No big deal, just get it onto the next truck. “Hey, we forgot to throw a pallet on that truck from Los Angeles to Vancouver”. No big deal, just throw it on the next tru-… Whoa! Not so fast. This is where things get complicated. You can’t just roll through the border with undocumented freight on your truck, even if it was previously accounted for on another load.
There are countless scenarios with respect to overages and shortages and almost as many different solutions, but one thing stands clear above all others – you need to report them to CBSA and/or CBP as soon as possible. Typically these regulatory bodies have a policy of voluntary compliance. In other words, if you make a mistake, realize that you have made one, report it to customs, and make every reasonable effort to ensure that you don’t make it again, chances are pretty good that you won’t face a penalty. By the same token, if you make a mistake and either attempt to hide it from Customs, or they find it before you have had a chance to report it, you will almost certainly be assessed a monetary penalty, plus, you can fully expect that your trucks will face even more scrutiny when crossing in the future.
The implementation of the ACI eManifest program has placed an additional administrative burden on carriers and also added another layer to the reporting of overages and shortages. CBSA recently hosted a webinar where they laid out the reporting requirements for changes and amendments to cargo and conveyance data. We have attached a copy of their presentation for you to review, but here are some highlights taken directly from that presentation:
- External commercial clients are obligated to provide true, accurate and complete information to the CBSA.
- In the event the carrier or freight forwarder needs to update any information it should be done as soon as it is known.
- If before the arrival at FPOA, a change is required.
- If post arrival (once CRN is logged), an amend is required.
- If one of the key data elements requires an amendment post arrival the House Bill, Cargo and Conveyance Correction Form (BSF 673) is also required to be submitted.
- Prior to arrival, the carrier or their third party service provider can make changes to any data elements.
- After arrival at the FPOA, amendments to Non-Key Data Elements can be made by the carrier or their third party service provider.
Carriers that transmit ACI eManifest Cargo and Conveyance data using the CBSA Web Portal are urged to familiarize themselves with the procedures outlined on the attached document. Carriers who use a third party service provider such as Border Pro for Carriers are encouraged to contact their service providers to report overages, shortages and other changes to key and non-key data elements.
It is also important to notify the importer of any discrepancies so that they can have their customs broker amend the customs entry. Failure to do so can place them in jeopardy in case of an audit.
Once again, we all recognize the fact that mistakes do happen, and will continue to happen in the transportation business. How you choose to deal with them is up to you. Know this though, if you are aware of discrepancies in your load and you decide not to report them, you are playing with fire. Even if these discrepancies are not caught at the time of crossing, there is a good chance they will be found down the road through the carrier audit process. We all need to make every effort to limit the errors that lead to overages or shortages, but when they do happen, we need to be honest and upfront, and report them as soon as they are discovered.
If you have any questions about ACI eManifest, or any other cross-border transportation matters, please do not hesitate to contact our Carrier Liaison at 855.542.6644 or via email at email@example.com.
- CBSA eManifest Highway Carrier Implementation Conference Call Nov 14 – Pre-Arrival Changes and Post Arrival Amendments
- Form BSF 673 – Cargo and Conveyance Post Arrival Manual Correction Request Form
Related Blog Articles:
- ACI eManifest: Requirements for Secondary Carriers vs. Carriers with Contracts of Exclusivity
- ACI eManifest: Know the Difference Between Proof of Report and Proof of Release
- ACI eManifest Informed Compliance Period Extended