BT Smart Customs Customs clearance made easy

Transcription

1 BT Smart Customs Customs clearance made easy

2 Welcome and introduction Mike Routh Sales Manager, Air & Logistics Programme, BT Global Services

3 Agenda Registration and refreshments Welcome and introduction Mike Routh, Sales Manager, Air & Logistics Programme, BT Global Services Legislation update Martin Goodwin, Customs and Air Logistics Consultant, Good Data Ltd Electronic security requirements and their impact on the freight forwarding community Marco Sorgetti, Director General of CLECAT

4 Agenda The carrier s view Andy Burrows Independent Consultant, A.B. Consulting Services Ltd Lunch 1.30 BT Smart Customs Ian Grant, Business Manager, Air & Logistics Programme, BT Global Services 2.30 Benefits of the approach outlined today Guy Thompson, CCS-UK User Group 2.45 Panel discussion - All 3.30 Close

5 Legislation update Martin Goodwin Customs and Air Logistics consultant, Good Data Ltd

6 The EU Multi Annual Strategic Plan (MASP) Legislation The Security Amendment Modernised Customs Code Implementing Provisions NCTS SAD Harmonisation ICS Operational Systems NCTS (TIR) NCTS (Safety & Security) Automated Import System ECS Phase 1 ECS Phase 2 Automated Export System EORI Customs Tools AEO Phase 1 Full System Risk Management Framework Registered Exporters System Integrated Tariff Environment Trade Access Customs Information Portal Single Electronic Access Points Single Window

7 Import Control System Governed by EU Regulation 648/ The Security Amendment Implementing Provisions (EU regulation 1875/2006) Legislation sets out new security requirements for goods entering the EU, notably: Empowers member states to require declarations for security purposes Declarations to be electronic Duty on carriers to ensure Entry Summary Declarations are made prior to arrival of goods Sets out the data set required Electronic exchange of data between member states Implementation date by 1 July 2009 Transition period until 31 December member states now have ICS available Norway and Switzerland are also adopting safety and security provisions

8 The Modernised Customs Code Adopted April 2008 Sets out Customs procedures for the future Removes national and local simplifications (will allow EU-wide simplifications) Requires electronic trading Aims to create simpler and more coherent rules across the EU Requires inter-operability of Customs across the EU Implementing Provisions now being developed Vote on Implementing Provisions March 2011

9 ICS - key features Legally the Carrier is responsible for ensuring ALL goods onboard are covered by an ENS, but with the carrier s knowledge and consent the ENS can be made by an exporter or agent Diversion Notification Arrival Notification with a reference to ENS for all cargo onboard either using unique key or MRNs Summary Declaration for goods being unloaded from aircraft with reference to ENS The Carrier is notified of intention to control if goods are selected for examination

10 ICS - national variations ENS Diversion EU specification EU specification Arrival Notification National Administration Summary Declaration National Administration Control Notification National Administration

11 ICS - Entry Summary declaration Declarations apply to all imports, transhipments and FROB Declaration is called an ENtry Summary declaration (ENS) Declaration to first office of entry into the EU prior to arrival Item level declaration: Air (Long haul) at least four hours prior to arrival (Short haul) at least by the time of actual take off Deep sea (Containerised cargo) at least 24 hours prior to loading (Bulk/Break bulk) at least four hours prior to leaving the port of export Short sea at least two hours prior to leaving the port of export Road at least one hour prior to arrival at first port of entry Declarations assigned a Movement Reference Number (MRN)

12 ICS ENS data elements Annex 30A data Unique consignment reference Transport document number Consignor Consignee Flight Routing details Carrier Person lodging the ENS Notify party Commodity item level detail ID and nationality of transport Conveyance reference number Country(ies) of routing codes First port of arrival Date/time of arrival at first port Place of loading Place of unloading Goods description Shipper Type of packages Number of packages Packing details Shipping marks Container numbers Commodity code Gross mass Consignee UN dangerous goods code Seal numbers Transport charges method of payment Specific circumstance indicator

13 ICS Diversion Handling Only required if diversion is to another member state which is not on the original ENS itinerary Diversion request is made to the original first port of entry Can be based on the unique key (flight number/date) or MRNs The MS forwards the risk for the movement to the new MS Arrival notification at the MS of diversion links the risk with the movement and allow controls to take place if required

14 ICS Arrival Notification Exact process depends on MS Possible to arrive the unique key (flight/date) or by MRNs May be part of an existing process, or a new one Advises Customs that the goods have arrived Allows Customs to advise the carrier about controls

15 ICS Summary Declaration This is the existing process where goods are to be placed in temporary storage Adapted to make reference to the ENS, or for the safety and security data to be included Implementation depends on the member state: UK will not change their Summary Declaration procedure Other MS may require the MRN to be added to the Summary Declaration The Summary Declaration is the subsequent procedure to the ENS, and so after this, no further reference to the ENS MRN should be required

16 ICS summary Legislation in place Transition phase expires 31 December onwards - ICS mandatory Enforceable via fines mechanism Complex information processing requirements Item level data required in declarations Across 27 + countries

17 Electronic security requirements and their impact on the freight forwarding community Marco Sorgetti Director General of CLECAT

18 The CLECAT menu CLECAT snapshot LSP: what is it? Value-added services Customs and service to services Advance information issues Dual filing, advantages and constraints ECS and ICS open issues Conclusions

19 CLECAT at a glance CLECAT is a non-profit association established in Belgium. It is registered in the EU register of interest representatives CLECAT has 26 members with EU and continental coverage: Freight forwarders and logistic service providers, national federations and confederations Customs representatives national federations Related Interest representatives are non-voting members Policy scope: EU legislation in transport, logistics and customs

20 CLECAT at a glance The type of companies Global players SMEs and regional operators Small & family businesses Our numbers (full members only): Over 19,000 companies Over one million direct FTEs Business coverage: 90% of customs, 70% maritime, 90% air, 50% road and rail operations in Europe If you d like to become a member, just give us a call.

21 LSP as a trade facilitator Logistics services has evolved: today LSPs are the main facilitator of trade: By using all transport modes to their full potential (road transport still accounts for some 80% of the total) By providing a direct link between production and markets, with increased efficiency and contained costs (this requires quality of services, with compliance well above 90%) By enlarging the commercial horizon of manufacturers, making far away markets accessible to SMEs

22 LSP as a trade facilitator By providing a practical single window for all those who wish to use LSPs services By beating inflation and enhancing return on investments: Logistics costs have gone down in the last 25 years from over 13-14% of delivered goods to 5-7% or less in recent times Air services are just one of the many diverse products offered by a modern LSP, in a rather expanded logistics picture.

23 Enabling SMEs to grow in foreign markets The challenge Distribution through wholesalers eats into margins Current infrastructure does not allow enough consumers to be reached Wider access to customers necessary to beat the competition Security concerns because of high-value products The approach Partner with logistics service provider to limit wholesalers involvement and reach more consumers Joint strategy to build necessary infrastructure Trusted partner to counter security concerns Grow by 70-80% in five years A European exporter wishes to grow sales of its high-value product in a developing market Source: DHL

24 CLECAT, Customs and services CLECAT was created immediately after the Treaty of Rome, with an identified Customs agenda CLECAT followed the creation of a Customs Union from its very inception in 1968 The MCC and e-customs work has been central in our policy remit since its inception

25 CLECAT, Customs and services The idea that e-customs will bring specialised Customs service providers to an end is wrong Logistics and Customs service providers are a very large market for IT and communication services Is the idea of services to service industry more or less important than services to traditional industry?

26 Advance information: where are we? ICS (Import Control System) for security: Entry summary declaration, single filing submitted by carrier, or a third party instead of or on behalf of the carrier Data elements and person responsible for lodging the declaration are frequently in different rooms The legislation does not provide proper linkage of the definitions: of the information to be provided, of the person responsible for providing it of the point in time when information must be provided LSPs and Customs service providers are often made aware of information by different parties and their cooperation will be vital. EU have adopted a top-down approach

27 Single or dual filing? EU approach for ICS security is based on single filing concept Carrier (others only with its knowledge and consent) must submit data third party lodgement was originally discouraged Dual or multiple filing is not even envisaged by June 2013 (date of implementation of MCC) For legal reasons (MCC) Reg. 450/2008 makes no room for it For IT reasons MS s made investments in single filing CLECAT and other industries suggested modifying the legislation to support dual filing (letter sent Jan 2010)

28 Single or dual filing? COM publicly admits (Prague, 25 Feb) that Reg. 648 was conceived when ideas were not so clear yet US understands that risk assessment without dual filing cannot work properly, EU is becoming aware of the same problem Yet COM is contemplating requiring carriers to provide additional data they have not got: buyer and seller (and 8+ HS digit code for temporary storage) for ENS In so doing, there is an issue of commercial confidentiality and inconsistency with long-established trade practices

29 G2G information: a dream? This is a WCO old friend : administrations show no enthusiasm for G2G, they prefer the old us (Customs) and them (trading community) At present ENS information is not exchanged between customs offices (customs office of first entry, customs offices of subsequent entry) Only the results of risk assessments are exchanged As a consequence, the information provided for temporary storage cannot be re-used

30 G2G information: a dream? A central repository would solve a lot of practical constraints, but: Prospects under the MCC are uncertain; discussion still ongoing Even office of lodgement concept (declaration lodged at customs office other than the customs office of first entry) may not be possible for April 2013 (i.e. single access point for security filing may be unavailable by 2013) These uncertainties may endanger the potential of the whole EU system.

31 AIS and centralised clearance Our view is that Centralised Clearance is in a way the epitome of the Customs Union and the single Customs area, but

32 AIS and centralised clearance Full centralised clearance seems to be pushed out into the future (transit is not in the scope): Exchange of information between supervising customs office and customs office of presentation implies well functioning G2G information exchange Doubts about governments motivation (or the possibility) to invest (additional IT and resources are required) Main constraints (i.e. big problems): VAT, national prohibitions and restrictions In 2013 Centralised Clearance will work only for the main customs procedures.

33 ECS issues Standard ECS (including security), which we have now is, in short, an exchange of information between the customs office of export and customs office of exit, but There is a big issue about open movements still pending AES (Automated Export System) is an exchange of information between the supervising customs office and the customs office where the goods are presented for export

34 ECS issues Within centralised clearance same picture? Some doubts about governments investments still exist Will system be able to cope with the growth in volume (as a result of the possible abolition of STC facilitation)?

35 The weakest link Interconnectivity ICS/ECS/NCTS was not foreseen, as this grew like a cluster without being seen as a cluster. A decision is pending, but not seen as a priority. Possible consequences: duplications, errors, mismatch resulting from unnecessary complication e.g. there may be situations that ECS and NCTS will have to run in parallel CLECAT has proposed a number of detailed amendments (1) (2) that may resolve some of these problems, eventually impacting on the MCCIP.

36 Conclusions IT is not a facilitator, but it is the enabler Without dual filing the issue of data protection and confidentiality of commercially sensitive data remains unresolved Without proper G2G information exchange (and the necessary investments) the functioning of the system may be brought into question The role of carriers and those of other actors in the SC is insufficiently protected, thus creating liability concerns both with carriers and other parties

37 Conclusions Suggestions: The experience accumulated by the trade should be treasured by modifying some aspects of the incoming legislation IT service providers should design the architecture of their products for all types of users

38 Thank you

39 The carrier s view Andy Burrows Meeting EU Legislation for Advance Reporting Requirements

40 Air Cargo: an Evolving Business Model Airline CEO issues with Air Cargo: 10% of airline industry revenues But 35% of the value of goods internationally is traded by air IATA: 2008 air cargo tonnage declined 5%; % But yields declined by 40%+ US demanding 100% cargo screening by mid 2010 Typical airline cargo unit has: manual commercial processes operations processes and IT systems poorly integrated lack of measurable process costs and quality

41 Air Cargo: It s a Global Business Airline issues with advance reporting requirements: Consistency of treatment region-by-region Big risk of: US/Canada Europe S.E. Asian countries Each implementing a different regime... IATA airlines already spend USD $5.9 billion/year on security

42 Air Cargo: It s a Global Business Airline issues with customs reporting requirements: Consistency of treatment region-by-region? US proposal to drop known shipper programme after August 2010 UK intention to keep known shipper and selective screening IATA view: 100% screening is generally incompatible with the current business model most cargo is delivered to the carrier pre-built by the customer IATA secure freight strategy data driven risk based shared responsibility throughout the supply chain

43 Major Carriers: Data Entry Options IT Service Provider Carrier Carrier GHA FAX Forwarder Carrier options for populating IT Service Provider System Send data directly Send data to GHA for onward transmission Receive data via fax/ and send on

44 Small Carriers: Data Entry Options IT Service Provider Carrier GHA FAX Forwarder Carrier options for populating IT Service Provider System Send data to GHA for onward transmission GHA

45 Keep cargo IMP message flows

46 Airline requirements from IT Service Provider Secure, confidential, robust, reliable Certainty of lodgement Provide the airline with the ability to identify where and when a third party ENS lodgement has been achieved Arrival messages - to support proof of entry Enable airline to provide an ENS at item level using the AWB as their main reference link to forwarders HAWB data Provides the carrier with a reference between the AWB/HAWB and the MRN and to the item level Minimal system changes for users: cargo-imp extensions EU-wide implementation via one technical interface

47 Airline requirements from IT Service Provider EU-wide implementation to give a single technical interface, from carrier IT system to one services supplier Trader Customs Office National System Central Services Reference Data Customs Office National System Trader External National Common National External Domain Domain EU Domain Domain Domain

48 Airline requirements from IT Service Provider Central database, available for enquiry, enables reconciliation and resolution of lodgement and tracing issues Flight manifest details Consignment details at MAWB and HAWB level and Item level Routing data Allows airline/ground handler to work at MAWB/HAWB level whilst forwarder and customs work at MRN level Make data in the Entry Summary Declaration (ENS) available for import declarations (subject to authorisation) Carrier or forwarder can then make Entry Summary Declaration (ENS) on data which has been provided

49 Entry Summary Declaration: Send ENS to Customs Standardised electronic ICS message defined by EU (same data in all the MS) but format defined at national level Sent to: Office of first Entry Prior to arrival (legal time limits!) 4 hours prior to arrival for long haul Prior/at departure ( wheels up ) for short haul Must contain Annex 30A data including the entry key data: Mode of transport at border Identity of means of transport: IATA or ICAO flight number Expected date (and time) of arrival Office of first Entry

50 Entry Summary Declarations: Customs Register ENS Customs generate Movement Reference Number (MRN) upon registration of the ENS Confirmation of ENS registration communicated electronically by customs to: person lodging ENS and carrier declared in ENS (if connected to ICS and if EORI number declared) This confirmation contains information such as: person lodging the ENS (e.g. forwarder); carrier s transport document; MRN and other elements (e.g. local reference number = your entry number. Thus, when MRN comes back, can tie across to your own reference number. AND if entry is not processed, the rejection is sent back to you.) Enables carrier to make sure that an ENS has been lodged

51 Scenario: Forwarder Holds Carrier Consent to Make ENS Entries Make Forwarder will obtain the Unique Key information and EORI# from the carrier - Using this information, forwarder will: compose and submit the ENS to National Customs ICS System at the first airport of arrival into Europe Customs perform risk assessment and provide the MRN back to the forwarder and carrier as well as the notification of controls if applicable

52 Scenario: Forwarder Holds Carrier Consent to Make ENS Entries Make Forwarder will send FWB and FHL including the MRNs to the carrier - which may also include the declarant s EORI number to indicate they intend to undertake third party ENS Upon arrival, the carrier then provides customs with the unique key in the arrival notification rather than the individual MRNs

53 AEO: Authorised Economic Operator Authorised Economic Operators can benefit from entering a reduced data set in the ENS and subject to less inspections The specific circumstance indicator E shall be declared (The system knows which party is AEO status and which are not.) The person lodging the ENS and all declared consignees must: be recorded in EORI and declare the EORI TIN and have an AEO certificate for safety and security or for customs simplification and safety and security Non AEO declarants enter additional data

54 IATA Airline preparations IATA has issued a Notice of Amendment for changes to its Cargo Interchange Message Procedures (CIMP) The key changes related to the EU requirements are: additional customs information identifiers a more flexible Other Customs Information (OCI) line to include new information inclusion of the OCI line in the Consolidation List (FHL) message that contains house waybill information These changes will facilitate the exchange of: the Movement Reference Number (MRN) the Economic Operators Registration Identification (EORI) number authorised Economic Operators (AEO) identification the scheduled arrival date and time at first point of entry

55 Airline Requirements from IT Service Provider Support all forms of airline cargo operations Help manage flight changes, overbooking splits, flight diversions Provide multiple distribution channels, including internet: secure, confidential, robust, reliable certainty of lodgement provide the airline with functionality to identify where and when a third party ENS lodgement has been achieved arrival messages to support proof of entry enable airline to provide an ENS at item level using the AWB as the main reference link to forwarders HAWB and MRN data

56 Airline Requirements from IT Service Provider EU-wide implementation via one technical interface Central database available for trade enquiries enables reconciliation and resolution of any lodgement, tracking, or re-routing issues

57 Lunch break

58 BT Smart Customs Ian Grant Business Manager BT Air Logistics

59 BT Air Logistics Cargo Community System UK (CCS-UK ) Launched in 1994 Community-based solution enabling UK traders to clear imports through HRMC National Export Service (NES) Launched in 2003 Enhancement to CCS-UK covering new export requirements Standard Messaging Service (SMS) Conversion and translation service Used for non-customs messaging Route Management Service (RMS) Cargo 2000 compliant CDMP Phase 1 and Phase 2 CCS21 now BT Smart Customs

60 History of the development Initial discussions began in 2007 Initial meeting September 2007 Initial funding granted January 2008 Attended IATA World Cargo Symposium March 2008 Demonstrator launched September 2008 Attended TIACA Air Cargo Forum November 2008 Held a series of presentations/demonstrations throughout 2009 CCS21 re-branded as BT Smart Customs

61 Principles of BT Smart Customs Designed to meet the requirements of ICS Initial focus on EU ICS Multimodal Community-based structure Reuse as much existing information as possible Automates as much as possible Allows for manual intervention Worldwide access Designed to minimise fines

62 Design of BT Smart Customs Central database populated by: Regular download of schedule information CargoIMP messages e.g. FWB, FHL, FFM, FBL Also other means e.g. XML Users and trusted partners can select consignments to declare Will accept ENS declarations and flat file data entry Message connectivity to all member states Returns MRN plus and Advanced Intervention messages Will send arrival notification and return control messages notifications and jeopardy management Report package

63 BT Smart Customs Functionality Part shipments and short shipments Diversion Handling of trucks Download of declaration data to GHA, forwarder etc. View/print/ of ENS for fallback

64 Populating the BT Smart Customs Database BT Smart Customs Database Carrier Agent Schedule Booking Manifest Other Data AWB Data HAWB Data Other Data Flight Schedule AWB AWB AWB AWB AWB AWB 30A 30A 30A MRN 30A MRN HAWB HAWB HAWB 30A MRN MRN The CCS Cargo Community User Group Slide 64

65 Generating the Entry Summary Declaration BT Smart Customs Database Declarant Request ENS Flight Schedule AWB AWB AWB AWB AWB AWB 30A 30A 30A MRN 30A MRN HAWB HAWB HAWB 30A MRN MRN ENS Process ENS The CCS Cargo Community User Group Slide 65

66 Generating the Entry Summary Declaration BT Smart Customs Database Flight Schedule Declarant Request ENS Response AWB AWB AWB AWB AWB AWB MRN MRN HAWB HAWB HAWB MRN MRN ENS MRN Process ENS MRN The CCS Cargo Community User Group Slide 66

67 Presentation (Arrival Notification) at Office of First Entry BT Smart Customs Database Request ARN Response Flight Schedule Declarant Status Status Status Status Status Status Status Status AWB AWB AWB AWB AWB AWB MRN MRN MRN MRN MRN HAWB HAWB HAWB MRN MRN MRN ARN Process ARN Risk Analysis Controls The CCS Cargo Community User Group Slide 67

68 BT Smart Customs Demonstration

69 Further Functionality Consignment Search and List Arrival Processing

70 Arrival Processing Member state discretion When FSU-ARR, FSU-RCF or MVT message received Ignored if outside the EU Triggers flight arrival at FPoE Other process dependant on individual MS requirement If not received ARN Divert View Up to six responses could be received

71 Further Functionality Consignment Search and List Arrival Processing Notification

72 Further Functionality Consignment Search and List Arrival Processing Notification Function Access Control Tick box list of all screen Data Function Access Control Read only access

73 Timescales Core application ready Message connectivity Most messages implemented FBLs before the end of next month Arrivals by June Customs Connectivity from June Full user trials from end of July

74 Tariff Fundamentally based on existing tariff structure Recurring quarterly charge Usage charge based on successful ENS Usage charge per line item Fixed tariff for small users Separately negotiated for large organisations

75 Summary Large development Fully compliant with ICS Automated declarations Supports concept of Dual Filing EU and beyond

76 Thank you

77 Benefits of the approach outlined today Guy Thompson CCS-UK User Group

78 Benefits of the approach outlined today Managed system Most EU member states have different technical interfaces Not all specifications ready Only some test systems presently available Technical interfaces change and develop and will be a very significant overhead to keep abreast of the changes Detailed functionality proves very complex Air Industry/Maritime idiosyncrasies in the way things are accomplished Arrival processing varies by country But all of these issues are not your problem!

79 Single system User staff trained on a single system Common look and feel and access method Functionality and process is the same for all MS Centralised control desks can manage exceptions Other business partners share the same service and can have delegated responsibility Customers technical staff One service to interface with One service to test against

80 Single system Changes to the customer network Simple to extend to another country Diversion and Arrival Processing Differs widely across the EU All information on the system wherever the aircraft/vessel arrives

81 BT Smart Customs User Group Process of putting together Legal structure Representation Role Roadmap for future direction Monitoring performance

82 Why Smart Customs? History of working collaboratively with business experts Operate on a community basis and track record of cost containment Provide robust systems BT as a CSP will have a fully engineered interface to ICS in UK Will have connections to 27 + countries System undergoing user testing with the User Group Is implementing IATA/FIATA agreed practices for ENS construction

83 Why Smart Customs? System has high level of functionality Central database built up as information about shipments is available Enables different sources of data capture and input dependant on how freight forwarder/carrier wishes to work Electronic notification of significant issues Complex user-access structure enabling business partners to have control and access to what they require Will allow carrier to resubmit declaration even if it was originally made by forwarder Will give visibility of declarations even if made by a third party system Multi-modal

84 Why Smart Customs? Addresses limitations in the implementation of the EU legislation, e.g. Dual filing Ability to cross-refer between MRN to HAWB, MAWB and Item No single European access point Variation in arrival processing

85 SMART CUSTOMS SOLUTION PRODUCED BY A COMMUNITY APPROACH

86 BT Smart Customs Customs clearance made easy