The Philippine Bureau of Customs (BOC) is planning to impose penalties on late submissions of the electronic air freight manifest by September, or three months after enforcing the switch-on mode, according to a customs official.
Management Information System and Technology Group (MISTG) deputy commissioner Gerardo Gambala, in a chance interview with PortCalls on July 21, said the penalty will finally be imposed after months of enforcement since compliance by stakeholders should have improved by now.
BOC deferred imposition of penalties when the switch-on mode for air manifest submission was implemented last month under Customs Memorandum Order (CMO) No. 10-2015. The memo requires airlines and freight forwarders to electronically submit their manifests through value-added service providers.
During a presentation at a July 20 air manifest forum, Gambala acknowledged struggles with the program’s implementation, but said the bureau will fix these difficulties. He added there is “no turning back”, as the system is “a vital process” and a needed tool to protect the country’s borders and prevent illicit trade.
MISTG Systems Management Division chief Nomie Gonzales, in an interview with PortCalls after the forum, said that despite lingering issues and concerns from stakeholders, there have been improvements in compliance, even in the online filing of entries.
MISTG has created a team and a dedicated email address (firstname.lastname@example.org) to cater specifically to concerns of stakeholders on air manifest submission.
There will also be another forum in August, and another in September before penalties are imposed.
Gonzales, in a presentation during the forum, said the switch-on mode means the entry declaration lodged by the declarant is linked to the airwaybill (AWB) submitted by the airline or forwarder to BOC’s electronic-to-mobile (e2m) system. Once this entry is processed and finally assessed by the authorized customs officer, the AWB will be “closed” and cannot be used anymore for another transaction.
What users must do
Stakeholders’ responsibility under the system include the following: on-time submission by the airline of the electronic inward foreign manifest (e-IFM) and by the freight forwarder of the electronic consolidated cargo manifest (e-CCM); submission of complete details of the manifest; proper information dissemination if the shipment will be off-landed or short-landed; and ensuring that information on the entry declaration is complete to avoid delays.
Gonzales also listed recommended procedures for short-landed and off-loaded shipments, one of the issues of stakeholders.
For one, Gonzales suggests that VASPs establish a mechanism to provide information among themselves, and to stakeholders, even if they are not their clients, in order to inform stakeholders their shipments will be short-landed or off-loaded.
Airlines are also asked to inform freight forwarders when shipments will be short-landed or off-loaded, as there are instances when freight forwarders are not aware of this.
The MISTG official also told stakeholders to contact their VASPs first for concerns but if they (VASPs) are unable to answer, then contact MISTG.
Other issues, concerns addressed
Another issue of stakeholders is if freight forwarders can submit e-CCM if the airline does not comply with the timely submission of the e-IFM. Gonzales said that the airline should be compliant as mandated by CMO 10-2015, and that freight forwarders cannot submit e-CCM if there is no e-IFM. If the airline submits the e-IFM late, freight forwarders may be penalized if they fail to submit the e-CCM within 24 hours upon BOC direct registration of e-IFM.
Another issue concerns the procedure for lodging the entry declaration if more than one AWB is submitted in the e2m since loading of cargo is done partially, even as the hard copy of AWB, the packing list, and the commercial invoice pertain to the total cargo.
Gonzales said the guiding principle is that one entry per AWB should be submitted in the e2m. The original AWB, packing list, and commercial invoice should be attached to one entry declaration. Then the other entry declarations of the partial cargo must have attachments of the certified true copy of AWB, the packing list, and the commercial invoice.
For corrections/errors in the quantity, gross weight, type of bill of lading (B/L), type of package, measurement, or description, Gonzales said there is no need to submit an amended AWB so as to avoid getting a penalty. The first thing to do to avoid penalty is to submit a formal request for amendment to the Office of the District Collector. Once the amendment is approved, the Office of the Deputy Collector for Operations will do the corrections directly in the E2M.
When submitting the amended AWB for corrections other than those on quantity, gross weight, type of B/L, type of package, measurement, and description, the airline or the forwarder should file the formal request to the Office of the District Collector for amendment.
Once the amendment is approved,the amended AWB must be submitted through the VASP. The amended AWB may have a new AWB number, or may use the old AWB number but with a suffix “A” in order to be accepted by the e2m. The amended AWB should use the old AWB number as the master AWB. Then the stored amended AWB is subject for BOC Direct Validation by the Office of the Collector for Operations. – Roumina Pablo
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