Under the revised draft memorandum on procedures for the submission of electronic air manifest through a value-added service provider (VASP), all airline manifests including those from airfreight forwarders and de-consolidators at all international airports will have to be submitted to the BOC through the VASP.
The inward foreign manifest (IFM), which consists of the master airway bills of cargoes consigned to ultimate and nominal consignees, would have to be submitted to the BOC upon arrival of aircraft with a port of origin in Asia, and four hours before aircraft arrival for those coming outside Asia.
The consolidated cargo manifest (CCM), which consists of all the house airway bills of cargoes consigned to the ultimate consignees de-grouped/split from the master airway bills of cargoes whose consignees are just nominal such as banks, forwarders and de-consolidators, should be submitted by airlines/airfreight forwarders/ de-consolidators to Customs no later than an hour after the aircraft’s arrival.
Under the revised draft, the VASP is required to provide the airport transit shed an electronic copy of the e-IFM and e-CCM once these are successfully validated via the electronic-to-mobile (E2M) system, as well as an electronic copy of the BOC-approved amendment of the e-IFM and e-CCM.
The revised rules also require hard copies of the supplemental manifest to be submitted within six hours of aircraft arrival for unmanifested cargoes provided these cargoes are included in the aircraft’s general declaration. Otherwise, shipments listed in the supplemental manifest will be considered unmanifested and subject to seizure proceedings.
Late submission of e-manifest is subject to fines of P10,000 for the first offense, P20,000 for the second and P30,000 for the third and subsequent offenses. The penalty for non-compliant submission as well as late submission is P30,000 per IFM or e-CCM.
“The frequency of the violation for late submission of e-IFM or e-CCM shall be counted on a yearly basis,” the draft memo stated.
Penalties are revoked if the BOC is responsible for the late submission or when this is due to fortuitous events or force majeure.
Meanwhile, air operators are suggesting some revisions in the memorandum.
On Jan. 8, the BOC’s Management Information System and Technology Group met with the Philippine Chamber of Air Express Operators (PCAEO) and VASPs to discuss issues relating to the air manifest.
PCAEO suggested that the submission of house airway bill (HAWB) should not be dependent on the master airway bill (MAWB) validation and the gross weight of cargoes, the MISTG said.
PCAEO prefers that HAWBs be accepted without checking whether the MAWB has been submitted, and without counterchecking if the gross weight exceeds the declared gross weight in the MAWB.
MISTG countered that the gross weight in the MAWB is used as a safety measure to determine that all HAWBs are submitted and that the gross weight would be formally amended if the declared gross weight in the MAWB turns to be more than 10%.
If the gross weight in the MAWB is 10% or less of the declared weight in the HAWB, a request for a correction should be made through email only to the Office of the Deputy Collector for Operations and a copy furnished to the MISTG site manager, the MISTG said.
On the submission of an HAWB without the MAWB, the MISTG will check with Webb Fontaine Group, the company that handles e2m, but said this may not be possible.
PCAEO is also seeking the removal of the mandatory assignment of Code 23 (consumption) and 24 (transshipment) on each and every shipment.
The MISTG said it will again check with Webb Fontaine if transshipments can be filed even if the nature of bill of lading falls under Code 23.
DHL Express, a member of the PCAEO, wrote a letter to MISTG Deputy Commissioner Primo Aguas in November suggesting the switching off of Codes 23 and 24, considering that lodging entries in e2m require the correct lodgment codes.
DHL explained that it processes more than 1,000 undocumented shipments and that assigning each a code would be “very difficult”.
One of the issues discussed at the Jan. 8 meeting was the discrepancy in gross weight of airlines and consolidators. The MISTG said this is due to airlines adopting international standards based on chargeable weight, not on gross weight.
The International Air Transport Association defines chargeable weight as “the actual gross weight or volume weight of a shipment, whichever is higher.”
For example, a shipment of cotton takes up a good amount of space even though its actual weight is very low. In this case, if airfreight charges are based of actual weight of cargo, the shipper needs to pay nominal airfreight compared with one who ships iron plates.
PCAEO also wants fees waived for late submission of the supplemental manifest.
The MISTG said it cannot distinguish the difference between supplemental and late submission. It also said that in the meantime, informal entry is processed manually and would not cause delays in cargo releases.
“Informal entry criteria need to be changed/revised as stated in the CMO first. Manual discharge of HAWB for informal (entries) shall be done,” the MISTG said.
Once approved and finalized, the order would be implemented at all international airports in the Philippines after the MISTG deputy commissioner announces it in a memorandum.
MISTG director Nomie Gonzalez said that as of now, there is no definite date for implementing the order because the BOC unit at Ninoy Aquino International Airport wants to first review the draft. –– Roumina M. Pablo
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