Canada Closer to Full eManifest Implementation

It has been over a decade since the Canada Border Services Agency (CBSA) first introduced and implemented the Advance Commercial Information (ACI) initiative. According to CBSA policy documents, ACI is about “providing CBSA officers with electronic pre-arrival information so that they are equipped with the right information at the right time to identify health, safety and security threats related to commercial goods before they arrive in Canada.”

Phase 1 of the ACI program was implemented on April 19, 2004, requiring marine carriers to transmit cargo data to the CBSA 24 hours prior to loading cargo at a foreign port. Roughly two years later, in July 2006, Phase 2 required air carriers and freight forwarders to transmit conveyance, cargo and supplementary cargo data to the CBSA four hours prior to arrival in Canada or, if the flight time is less than four hours, before the aircraft’s time of departure.

CBSA is currently in the process of implementing Phase 3 of the ACI program, known as the eManifest initiative. This phase will undoubtedly present the most significant challenges for industry members and the greatest opportunities for the CBSA.  In terms of challenges, expecting the 16,500+ highway carriers to electronically transmit advance cargo and conveyance data information to the CBSA within a minimum of one hour prior to arrival at the border may prove demanding. In order for highway carriers to meet their obligations under eManifest, it will require investments in IT resources, training and compliance. On the other hand, the opportunities for the CBSA to perform risk assessments on the advance data sent and the ability to pre-screen thousands of commercial shipments before they reach the border will allow the Agency to advance the frontier to unprecedented heights.

The overall costs and benefits estimated by the Canadian government for the full implementation of the eManifest initiative would result in a net benefit of $482 million ($376 million to the businesses and $106 million to the federal government) over an 11-year period from 2015 to 2025. These projected savings are mainly due to reduced delays at the border and the efficiencies realized from replacing paper with electronic information.

On May 6, 2015, the regulatory amendments for the eManifest initiative became law. Thereby, making specific trade chain parties involved in the importation of goods into Canada liable for the transmission of pre-arrival information. In essence, all carriers transporting specified goods into Canada must electronically transmit to the CBSA-specified data pertaining to the cargo and conveyance within the prescribed timeframes as described in the Reporting of Imported Goods Regulations. The good news is that, while technically the regulations are in force, there is an informed compliance period until January 1st, 2016 before any monetary penalties will apply.

The eManifest initiative sets out to accomplish three main goals: targeting high risks as early as possible in the supply chain, offering expedited border processing for commercial goods determined to be low risk, and improving the consistency and predictability of service delivery to stakeholders.

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