Late Manifest Submission

OUR column today will provide refresher information to import documentation staff of shipping lines and forwarders/consolidators who face day-to-day challenges dealing with late submission of the electronic manifest.

Customs Memorandum Order 37-2009 dated 14 August 2009 on the subject “Submission of e-Manifest Through A Valued Added Service Provider (VASP) and implementing guidelines for Customs Administrative Order 1-2007” is the basis for the mandatory advance submission of shipping line and seafreight consolidation cargo manifest to the Bureau of Customs electronic-to-manifest (e2m) system.

e-Manifest submissions are classified under three time frames:

1. On Time submission (before expiry of cut-off time defined by BOC)
2. Late Submission (after cut-off time but before actual vessel arrival time)
3. Non-Compliant Submission (upon vessel arrival and after)

For late submission, acceptance of manifest by the e2m system involves manual process of “direct register/validate” undertaken by the office of Deputy Collector for Operation of the concerned port.

Three documentation requirements must be submitted by the shipping line/agent or forwarder/consolidator in support of request for “direct register/validate”:

1. Formal letter request
2. Manifest sending history (provided by the VASP used for e-manifest submission)
3. e2m server log (provided by BOC MISTG Help Desk)

In the latest version of the final draft CMO for mandatory advance submission of electronic airline and airfreight cargo consolidation cargo manifest, the documentation requirements for “direct register/validate” are the following:

1. Formal letter request
2. Manifest sending history (provided by the VASP used for e-manifest submission)
3. VASP server log (provided by VASP)

Both the e2m server log and VASP server log contain highly technical information on messaging connectivity between the VASP system and e2m and provide reliable date/time stamps used to determine if late submission is justifiable.

Leo V. Morada is a domain expert on IT applications in Philippine port operations with 25 years’ senior IT management experience implementing technology solutions in port operations, electronic transactions with customs & port authority, and air/sea port community system applications. He is CEO of Cargo Data Exchange Center, Inc, a customs-accredited Value Added Service Provider. He may be contacted at lmorada3fl@yahoo.com.