If you've spent any time at all in the transportation business then you know, despite everyone's good intentions, overages and shortages happen. Most carriers have systems and policies in place to limit mistakes but it is more a matter of "when" they will occur rather than "if" they will occur.
When it comes to domestic transportation, 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 truck - 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.
Report Your Overage And Shortages To Customs
There are countless scenarios with respect to overages and shortages or any other changes to invoices or bills of lading and almost as many different solutions, but one thing stands clear above all others - you need to report them to Canada Border Services Agency (CBSA) and/or U.S. Customs and Border Protection (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 an Administrative Monetary Penalty (AMPS) ranging from $250 to $8,000 per shipment. In addition, you can fully expect that your trucks will face even more scrutiny when crossing in the future.
Additional Responsibility On Carriers
The implementation of the ACI eManifest program has placed an additional administrative responsibility on carriers and also added another layer to the reporting of any changes or amendments to cargo and conveyance data transmitted. Here are some highlights as they pertain to changes and amendments.
- External commercial clients are obligated to provide true, accurate and complete information to the CBSA within the required timeframes.
- 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 First Point of Arrival (FPOA), a change is required.
- If post arrival (once CRN is logged), an amend is required.
- If one of the key data elements such as a CCN or CRN requires an amendment post arrival, the online Highway and Rail Cargo and Conveyance Correction Post Arrival Manual Correction Form (BSF 673) is required to be submitted to CBSA prior to making the amendment.
- Prior to arrival, the carrier or their third-party service provider can make changes to any data elements. Individual data elements can not be transmitted separately. A change pre-arrival, requires the entire record (all applicable data elements) to be changed.
- The reporting timelines for changes pre-arrival remain the same, 30 days but not less than 1 hour prior to the arrival of the truck at the First Point of Arrival (FPOA).
- If a CCN on a cargo transmission or the actual CRN on a conveyance transmission needs to be changed, then you must first delete the cargo or conveyance and then transmit an "Add" for the new report with the new CCN or CRN.
- After arrival at the First Point of Arrival (FPOA), amendments to non-key data elements can be made by the carrier or their third-party service provider. Amendments which are done post-arrival must be made as soon as they are discovered.
Carriers that transmit ACI eManifest Cargo and Conveyance data are urged to familiarize themselves with the procedures in the Electronic Commerce Client Requirements Document (ECCRD) or CBSA Memorandum D12-3-1. Carriers who use a third-party service provider such as the Carrier Help Desk are encouraged to contact their service provider 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 Help Desk at 855.542.6644 or via email at [email protected]
eManifest Filing Services
Our Carrier Help Desk eManifest filing services can assist you in submitting all relevant information to CBSA within the required time period to ensure your trucks cross the border as quickly and efficiently as possible.