BOC requires electronic air manifest by May

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ID-100101323After two resets, the Bureau of Customs (BOC) will finally enforce in May the mandatory submission of manifest for air cargo through the electronic-to-mobile (e2m) system using value-added service providers (VASPs).

The original target date for implementation was April 6 but this was moved to April 13 after BOC’s consultation meeting with stakeholders last month. The final date of implementation is now May 11.

Customs Memorandum Order No. 10-2015, dated April 10, mandates that all manifests for air cargo be filed electronically with the BOC. Efforts to implement this procedure had been made since 2010, entailing several meetings between BOC, stakeholders, and VASPs. Since 2011, 11 airlines have voluntarily submitted manifests electronically.

Under the CMO, airlines and air express operators must submit their flight schedules to the BOC’s Aircraft Operations Division (AOD) at the airport where the flight will arrive at least one month in advance. The AOD will then encode the estimated time of arrival in the e2m as a prerequisite for allowing airlines and air express operators to submit the electronic inward foreign manifest (e-IFM). Soft copies of the flight schedules should also be submitted to VASPs.

An e-IFM is the electronic list of house airway bills (HAWBs) or master airway bills (MAWBs) that contain information about the cargo arriving on a flight. An electronic consolidated cargo manifest (e-CCM), on the other hand, is a list of HAWBs or MAWBs which contain information about the cargo covered by a MAWB. It is filed for each MAWB consigned to an airline, air express operator, air freight forwarder, or de-consolidator.

Airlines and air express operators should submit an e-IFM for every flight arrival and fill in 23 fields in the e2m.

BOC advises filers to take extra care, as the files are case- and values-sensitive, and revisions to the data may require a formal amendment which may cause delays and  penalties.

Schedules for submission cut-off

Cut-off time for submitting e-IFMs is upon arrival of the aircraft if the port of loading is in Asia, and four hours before aircraft arrival if the port of loading is other than Asia. BOC noted that if an airline or air express operator submits the e-IFM after cut-off, it is considered a late submission subject to a penalty of P10,000.

As for the e-CCM, cut-off is one hour after the aircraft’s arrival. If the e-IFM is submitted late, the e-CCM will be accepted without penalty if submission through the e2m does not exceed 24 hours after the e-IFM is registered by the Office of the Deputy Collector for Operations. This will also apply if e-IFMs are not validated in time due to, for example, system errors or late encoding of date of last discharge.

A supplemental e-IFM, on the other hand, must be filed for cargo that arrives on a plane for which an e-IFM has earlier been submitted, or was not covered by either master or house airway bills that were part of the submitted e-IFM.

The airline or air express operators must send a formal request to the district collector to approve the supplemental e-IFM. Provided an e-IFM has been filed, a supplemental e-IFM may be submitted without penalty up to the 24 hours after cut-off for the e-IFM.

An e-IFM submitted past the timeline is considered late. As with the supplemental e-IFM, the airline or express operators should file a formal request for approval with the district collector, who will then decide whether to charge penalties. If failure to submit is caused by lapses on the part of BOC, then penalties may be waived, the CMO states.

Late filing of e-IFM will only be accepted within eight government working hours after the actual arrival of the aircraft, BOC noted.

Meanwhile, amendments to quantity and gross weight in e-IFMs will not be penalized provided these are done before the cut-off time. These amendments must be made directly with the VASP. Amendments other than those on quantity and gross weight, even if done within the cut-off, must be coursed through BOC’s Legal Division, as do amendments to e-IFMs after the cut-off time. The district collector may impose penalties for major amendments to the initial submission, BOC said.

Hard copies are still required, but BOC has split up the cut-off times for every batch of documents. Upon arrival of the aircraft, hard copies of the general declaration, passenger list, and store list must be submitted by the flight purser or other officer to the Customs officer. Upon opening of the belly of the aircraft, the cargo manifest, master airway bill, and house airway bill must be submitted to BOC’s AOD. And upon opening of the tail of the aircraft, the AV7 (mail list), which includes the number and weight of sacks, must be submitted.

Short-landed and off-loaded cargoes

The CMO also includes exceptions for short-landed cargoes and off-loaded cargoes.

Short-landed cargo is the subject of an airway bill in the e-IFM, but which arrives on the flight incomplete (i.e., only a portion of the quantity listed on the airway bill arrives on flight). It has two parts. The first is for when a portion of the short-landed cargo arrives on the flight for which an airway bill is first filed in the e-IFM and the second, for when a portion of the short-landed cargo does not arrive on the flight for which an airway bill is first filed in the e-IFM.

Off-loaded cargo, on the other hand, is the subject of an airway bill in the e-IFM, but for which none of that cargo arrives on the flight.

BOC, under the CMO, has outlined several procedures to be undertaken if no entry is filed, if entry is filed but not paid, and if entry is filed and paid for short-landed and off-loaded cargoes.

BOC also pointed out that whether short-landed or off-loaded, once an entry is filed and payment is made, but the remaining cargo does not arrive, or is not dealt with in the circumstances under the CMO, then the consignee can file for a refund of duties and taxes paid.

The issue of short-landed and off-loaded cargoes was raised by air express operators during the consultation with BOC. — Roumina Pablo

Image courtesy of cooldesign at FreeDigitalPhotos.net