Good day all, further to my previous post EU – Entry Summary Declarations (ENS) – the new buzz word, below is an interesting article comparing the AMS filing for USA vs the ENS filing for EU.. Makes for interesting reading..
Shipper claims “Silliness” over carrier compliance requirements for EU advanced data rulesFILED UNDER 24 HOUR RULE, BILL OF LADING, CUSTOMS, ENS, ENTRY SUMMARY DECLARATION, EU, EUROPE, EUROPEAN UNION, SHIPPERS
How smoothly is the introduction going of the European Union’s requirement for an Entry Summary Declaration? It’s early days yet in the operation of the EU’s new requirement for submitting data about the freight being imported into the EU (or moving via the EU) prior to loading for export. The Shipper’s Voice has heard little by way of shippers’ reactions to this new obligation placed upon them, or indeed on their thoughts about the surcharges which many carriers (air and sea) are introducing. Arising from the Shippers’ Voice Linked In group (a closed shippers’ only group), however, comes one of the first signs of frustration from a couple of shippers.
A shipper in North America is concerned that one or two carriers are requiring the shipper to provide certain information as much as five days before loading. A European based shipper from the retail sector has also indicated a similar situation arising. Both shippers’ identities will remain confidential here.
Thus far the shipper from North America has only experienced this from a couple of the lines he deals with. He comments that this probably “says more about how different carriers cope with tackling the same problems”.
The EU’s advanced trade data rules requires that an Entry Summary Declaration (ENS) be submitted to EU authorities 24hrs before cargo loading. It is apparent that some carriers (and it is suggested to be European carriers) are threatening the imposition of charges (or “fines” as the shipper in question termed it) levied by the carrier, if the shippers exporting to the EU do not supply them with a complete ocean bill of lading (OBL) including the container number and seal by a deadline set by the carriers. In order to comply with this requirement, in practical terms translates to providing the carrier with an OBL roughly 120 hours before sailing, “Which, in reality, will often mean that meeting the carrier’s EU 24 rule deadline…complete OBL details including container and seal details would need to be provided to the carrier before cargo is even containerized”, says the North American shipper.
He goes on to explain that in order to comply, because of the nature and characteristics of his business and freight, this would “actually lead to our having to supply them [the carriers] with container numbers before the carrier even releases empty containers for loading by the shipper….and as the line has no plans to release empty reefer containers any earlier than they have in the past, I guess we’re supposed to make up the container numbers. Today one of these carriers has gone so far as to require government health certificate numbers by the same cut off date despite the reality that empty containers may not even be released for loading by their documentation cut off date and government regulators certainly aren’t going to issue OMIC certs [certificates] before cargo is containerized.”
He suggests that shippers will be forced to look for carriers with less ‘silly’ demands.
The European shipper, points to the requirement imposed on him by his forwarders for an extension to the “CFS cut off by up to 4 days (because of the weekend) which has been much longer than originally anticipated. This has also been more than the factories can absorb, and so has affected our lead time by up to a week”.
The Shippers’ Voice is curious to know if other shippers were experiencing similar impractical demands from carriers (air or sea), or whether this is merely a situation unique to just a few shippers and one or two carriers.
The American shipper expresses surprise that the EU rules should cause any major shipper or their carriers a problem: he cites that they all work within the similar requirements for the US, for example without any difficulties; the only major difference with the EU rules is in the requirement to supply the container number and seal details with the OBL number prior to loading, but as the North American shipper states “ frankly as an importer that manages to supply the US government with ISF advanced trade data 24 hours before our containers sail from China, Europe or elsewhere….and given that this EU advanced trade date [rule] didn’t just pop up out of thin air…I’m surprised to see that it appears to be such a huge administrative issue for some carriers and a breeze for others”.
If you wish to shed some light on your experiences, but anonymously, please email Andrew.firstname.lastname@example.org, who will be happy to take your comments in confidence. Otherwise you may seek an invitation to join the Shippers’ Voice Group on the Linked In networking tool, to share your thoughts with shippers and shippers’ representatives; or else submit a comment below this article.
FTW also had an article based on this topic, under the heading Are shipping lines in SA making the new EU security rules too onerous? ..