FAQ - Release Time Frames

With the final eManifest implementation (eHousebill Change Request) tentatively scheduled for late 2020, importers and brokers will be directly impacted by system changes affecting release. The CBSA will be moving to a cargo-based arrival processing model which will alter the timeframes for release of commercial goods. With these system changes, shipments will be eligible for release only after all related cargo documents attain “arrived” status.

1. How does “cargo-centric arrival” processing work and how does cargo attain “arrived” status?
   • With electronic cargo mandatory in all modes and electronic house bills (eHB) delivered in the final eManifest implementation, the CBSA is moving towards a cargo-centric model to determine the arrival status of a shipment. This will eliminate program integrity gaps and fully support the eManifest regulatory requirements.
   • Cargo will be considered “arrived” in CBSA systems when the cargo reaches the port of destination specified in the cargo document. Depending on the location to which the shipment is manifested, the cargo could be arrived at First Port of Arrival (FPOA) by a Conveyance Arrival Certification Message (CACM) or at an in-land warehouse by a Warehouse Arrival Certification Message (WACM). A shipment will be eligible for release only if all the associated cargo is in arrived status.
2. When can we expect the eManifest changes and the new time frames for release to be implemented?
   • At present time, the CBSA has not finalized an implementation schedule for the eManifest changes. Customs Notice 18-09 - Time Frames for Release of Commercial Goods has been published in advance to ensure all importers and brokers are aware of the upcoming change in policy with respect to the time frames for release of commercial goods. As more information becomes available, the CBSA will update the Customs Notice (CN) to reflect the exact date clients can expect the system changes to occur and the new policy to be active. In addition to the CN, further meetings will be held with impacted stakeholders to ease the transition.
3. What other changes are planned for the eManifest implementation?
   • The majority of the changes being implemented by eManifest will impact freight forwarders and the processing of consolidated shipments. In addition to changes to arrival processing mentioned above, importers and brokers will also be impacted by one new validation rule for release requests. This new validation rule will result in a release request being rejected if it is associated to a cargo document with a movement type of “in-transit” or “FROB” (freight remaining on board).
4. Will the new time frames change when I can submit Pre-Arrival Review System (PARS)?
   • No. When the new time frames are implemented, you will not see any changes to when you can submit a PARS.
     Note: A PARS can be sent to the CBSA up to 30 days prior to arrival and 40 days after the shipment has been arrived.
5. Will the new time frames impact when I can submit Release on Minimum Documentation (RMD)?
   • No. The new time frames will allow importers and brokers to submit RMDs like they do today. CBSA systems will accept and validate the RMD, but the RMD will not be eligible for release until all the related cargo(s) attain arrived status. Please see Question #1 to find out how a cargo reaches arrived status.
6. If I submit an IID, which release time frames are in effect - the proposed new ones or the ones currently listed in D17-1-4?
   • The IID has been designed to function in combination with the new timeframes. If using the IID today, you’ll notice release is triggered only when the related cargo attains “arrived” status.
     Note: An IID can be sent to CBSA up to 90 days prior to arrival and 40 days after the shipment has been arrived.
7. What will happen if the warehouse I use does not have the capability to transmit Warehouse Arrival Certification Messages (WACM)?
   • According to the Customs Sufferance Warehouse Regulations, warehouse operators are required to transmit a WACM electronically when a shipment arrives in their warehouse. In the event a warehouse is not electronic and once the eManifest systems changes have been implemented, border services officers (BSOs) will have the ability to arrive shipments on behalf of a warehouse in extenuating circumstances.
   • The CBSA will continue to monitor for cases of WACM non-compliance and will take the necessary corrective actions.
   • Carriers or warehouse operators who fail to transmit a WACM electronically may be subject to an Administrative Monetary Penalty.
8. Will I need to make systems changes to prepare for the new time frames for release?
   • No. With the shift to cargo centric arrival processing, a release can be transmitted as it is today. The CBSA will accept and validate the release request and wait for the associated cargo(s) to be transmitted, accepted and attain arrived status before a release decision is transmitted.
9. Will I continue to receive Release Notification System (RNS) messages?
   • Yes, RNS messages will continue after eManifest implementation. Note: Some clients may experience delays receiving RNS “Declaration Accepted” messages depending on the sequence that documents are captured in CBSA systems. If the release document is transmitted and accepted before the associated cargo document, the Declaration Accepted message will be delayed until the cargo is transmitted and validated in CBSA systems.
   • Clients who wish to receive RNS messages must contact the CBSA Technical Commercial Client Unit (TCCU).
10. What is the Reported Notice, and how do I make sure I receive it?
    • The Reported Notice is a new eManifest notice that is transmitted to clients when the shipment arrives and is processed at FPOA. The intent of this notice is to provide visibility into the status of the shipment as it moves through Canada (in-bond). Currently, this notice is only available to carriers, freight forwarders and warehouse operators. However, the CBSA is working to make this notice available to importers and brokers after the eManifest changes are implemented. Please contact the TCCU if you would like to sign-up (when this notice is available to importers/brokers) or have technical questions related to this notice.
11. What is a mismatch, and how do I correct it?
    • A mismatch is a discrepancy between the port of destination on a cargo/house bill and the release office on a release request. In this scenario, when the ports do not match, the release request will be placed in reject status in CBSA systems and a reject notice (Y50) will be issued to the client. Note: Only the release request will be placed in reject status in the event of a mismatch.
      1. To correct a mismatch with an incorrect release office, a new version of the release request must be submitted using an EDI “change” to match the cargo port of destination.
      2. To correct a mismatch when the cargo is in error, a new version of the cargo document must be submitted as must the release request. The CBSA requires resubmission of the release request because the original version of the release was rejected due to the mismatch.