The Canadian International Freight Forwarders Association outlined several concerns its members have with Canada Border Services Agency’s eManifest program in May 23 and 28 letters to the agency’s Director General, Bruna Rados. Canadian Sailings asked CBSA to respond to many of those concerns, including those raised in the accompanying article. The following are lightly edited excerpts of several other questions and answers in that exchange.

Q: What are the current timelines and deadlines for eManifest. Its deadline for implementation was March 2013. Has that deadline been extended?

A: CBSA announced on March 6, 2013, that the eManifest informed compliance period for highway carriers was being extended from May 2013 to the fall as a result of the timelines associated with the regulatory process. At that time, CBSA also made a commitment to provide clients with as much as 45 days’ advance notice of the date on which regulations would come into force.

Q: CIFFA, in a May 28 letter, asked you to confirm its understanding of the correct procedure for handling mixed-destination eHBLs (house bills of lading) in a single container. (Namely that a bonded 8000 freight forwarder is responsible for ensuring the eHBLs are “arrived” into the respective sub-loc code/warehouse and that no re-manifest is required.) What is CBSA’s interpretation?

A: The warehouse operator is obligated to send an arrival message. This transfers the liability from the bonded carrier to the bonded freight forwarder (which is why the re-manifest is not required).

Q: At present railroads only accept marine carrier 9000 releases; policy also prohibits clearing of an 8000 eHBL from an AR (railway company) sufferance warehouse. However, CIFFA outlines scenarios where it transmits that data to the CBSA on an 8000 eHBL. What is CBSA doing to address this situation and ensure that the railroads “are fully prepared for the freight forwarder eManifest and fully prepared to handle all cargo control numbers”?

A: As per CBSA Memorandum D4-1-4, current warehouse policies allow for the deconsolidation of cargo only at CW type sufferance warehouses (operated by a consolidator, de-consolidator, bonded freight forwarder, or customs broker). This may be subject to change under the new policies being developed by the CBSA’s Cargo Control and Sufferance Warehouse Modernization Unit. However, as policy decisions have not yet been finalized, we are unable to provide implementation timelines. Customs notices will be issued to announce all changes being implemented under the CCSWM initiative. Clients seeking more information about this initiative are encouraged to visit the CCSWM section on CBSA’s Web site.

Q: Can you confirm that including HS codes in freight forwarder eHBL transmissions is optional and not mandatory?

A: Currently the House bill Electronic Commerce Client Requirements Document (ECCRD) and related maps list the HS code as a conditional data element. The condition on this element is “if available.” If the freight forwarder has the HS code, they will need to provide it.

Q: Is a company permitted to be issued a single bonded forwarder code even if it has incorporated entities in more than one province? CIFFA says that without allowing that, it would be difficult if not impossible under eManifest for a company to reconsolidate goods from a single container that is bound for multiple destinations.

A: A freight forwarder may only hold one carrier code for each legal entity to transmit house bill data no matter where in Canada the goods are destined. If a freight forwarder company has different legal entities then it may have a freight forwarder code for each of its different legal entities.

Q: What is the CBSA doing to ensure that marine carriers know that under eManifest they now have to release the Primary Cargo Control Number (CCN) at the time of booking and not wait until close to sailing or even prior to arrival of the cargo as is now often the case?

A: Marine carriers will need to communicate their primary CCN earlier on in the process to inform the freight forwarder community. House bill data elements were reviewed through the consultative process during the eManifest design phase, and it was agreed that the primary CCN was required for compliance monitoring purposes. CBSA has built manifest forward processes to allow for better information sharing between trade chain partners.

Q: CIFFA also expressed a concern about a freight forwarder in a “master co-loader” position being able to distinguish between bonded and non-bonded freight forwarders. To reduce risks associated with that, CIFFA is proposing that the application to obtain a carrier code include authorization to share the code. What does CBSA think of that idea? What about CIFFA’s interim recommendation that the CBSA share with the freight forwarding community the number protocols for bonded and non-bonded freight forwarders so they can tell them apart?

A: CBSA is not able to publish a public list of carrier codes for external client use due to privacy issues. Nor are we able to divulge the protocol behind the development of a freight forwarder code. Please note that if a non-bonded freight forwarder transmits a house bill with an in-bond movement, the transmission will be rejected. How freight forwarders select business partners is truly a business-to-business decision.

More information can be found on eManifest at the CBSA website,

Information on the eManifest portal can be found at