The Bureau of Customs (BOC) rules on advance manifest submission was implemented beginning May 1 under a “transition” period that will last until May 15. For now, the rule covers manifest submission of container and non-container vessels but not of non-vessel operating common carriers (NVOCCs) and forwarders.
Customs Administrative Order (CAO) No. 01-2016 mandates the electronic transmittal of cargo information to BOC “within 24 hours after the time of departure of carrying vessel from the port of origin, first from the mother vessel or any vessel departing from the actual exporting port of origin and finally, if any, from feeder vessel destined to any importing port in the Philippines.”
The previous practice was to submit the manifest 12 hours before the vessel arrives at a Philippine port.
READ: BOC requires earlier submission of sea manifest
In a weekend advisory sent by BOC value-added service provider (VASP) Cargo Data Exchange Center to NVOCCs and forwarders, company CEO Leo Morada said there will be “no penalty for the transition period” covering May 1-15, 2016.
CDEC said “VASPs were instructed to prepare their systems to accept the advance manifest submission.”
There will be a meeting on May 2 between BOC Management Information and System Technology Group (MISTG) and VASP officials to “discuss mechanics of advance manifest submission,” CDEC added.
The BOC had earlier created a technical working group composed of four groups (shipping lines, forwarders, VASPs, and tramp operators and agents) to iron out issues surrounding the implementation of the controversial CAO. Each of the groups was given an April 29 deadline to submit their recommendations.
The Philippine International Seafreight Forwarders Association (PISFA) transmitted its consolidated recommendation to BOC deputy commissioner for MISTG Vladimir Dennis Reyes on April 28.
The PISFA letter, signed by president Doris Torres, recommended that the submission of the advanced cargo manifest (ACM) be treated separately from the submission of the inward foreign manifest (IFM) or consolidated cargo manifest (CCM) as they “serve two different purposes.” The ACD is for risk management while the IFM and CCM are for customs clearance, PISFA explained.
The two submissions go through different portals as well, the association pointed out. The ACD will be sent via the Cloud by Amazon, as advised by MISTG, while the IFM and CCM will be submitted through the VASPs. PISFA said since there is already a system in place for IFM and CCM submission, this should be left as is.
“Due to the complexity of freight forwarding activities (groupage and regroupage of cargoes at the transhipment port), freight forwarders will not be able to submit complete and final data at the port of origin. Therefore we suggest that ACD should be submitted 24 hours prior to departure at the transhipment port instead of 24 hours after departure at the port of origin,” PISFA said.
It added that the 24 hours after departure at origin requirement for ACD submission “is not workable nor practical for the freight forwarder considering the time differences around the globe.” The association suggested a “longer period be given to the forwarders to submit their ACD to compensate for the time differences…”
A 40-day information dissemination program was likewise suggested after implementing rules are issued. This will give stakeholders time to understand the new rules, PISFA reasoned.
Another PISFA recommendation is a six-month dry run of the rules prior to imposition of penalties. “Considering that this is a new process…, sufficient time should be given to all the users to be able to familiarize themselves with the new system. Otherwise, the forwarders will be hit by enormous penalties while they are still in the learning process.”
The association also sought clarification on whether there is a need to submit an ACD for every change in mode of transport during the whole transport process.
The Association of International Shipping Lines (AISL) had much earlier appealed to the BOC to exercise more understanding toward carriers, urging the agency to move back the date for imposing penalties on those that fail to comply with the policy.
READ: Carriers appeal for tolerance in initial implementation of PH advance manifest policy
In a letter dated April 4, AISL general manager Atty. Maximino Cruz requested BOC’s Reyes to extend “some leniency in the submission of the information required within twenty-four (24) hours after departure of the mother vessel from the port of origin” under CAO 01-2016.
“We have explained to you the difficulty/ies faced by shipping lines in providing the complete information enumerated in par. No. (5) of CAO No. 1-2016,” Cruz added.
Cruz earlier told PortCalls shipping lines won’t be able to include all details required in the manifest within the prescribed period, pointing out they “can only supply whatever information is/are available when the mother vessel departs origin port en route to the port of transhipment.”
Cruz said that within 24 hours of departure of the mother vessel from the origin port, AISL member lines can only provide the following information: booking/BL number; shipper; consignee; port of origin; voyage number; carrier identification; and the International Maritime Organization number of the mother vessel.
Other information required under CAO 01-2016 includes the marks and numbers of cartons, drums, boxes, crates and others forms of protective packaging; container and seal number if containerized, and the initials FCL if full container load, and LCL if less than container load; number and kinds of packages; descriptions of contents of cargo; gross weight in metric tons; measurement in cubic meters; and party to be notified.
“In the meantime that shipping lines are adapting their system to the new procedure, it is likewise requested that the non-imposition of penalties be extended until June 15, 2016 instead of May 23, 2016 as originally intended by the Customs Commissioner,” Cruz said.
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