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July 07, 2014

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INTERNATIONAL MARITIME 44 THE JOURNAL OF COMMERCE JULY 7.2014 By Greg Knowler I T ' S A FO RWA R D E R ' S g uessi ng g a me. China's General Administration of Cus- toms reportedly has ordered all Chinese ports to implement a new 24-hour advance manifest reporting system, but no official notice on the enforcement of the reg u- lations has been released, according to German logistics company DB Schenker. Forwarders shipping goods via Shanghai are trying to decipher the customs agency's 24-hour advance manifest reg ulations that either were implemented on June 3, on June 28 or on July 1, or will be strictly enforced from Oct. 1, depending on the source. The regulations appear to apply to all containerized cargo discharged or trans- shipped at Shanghai, the pilot city for a rule that will be expanded to all ports once the implementation has been smoothed out. According to DB Schenker, the General Administration of Customs' head office in Beijing ordered all Chinese ports to imple- ment a new CCAM system that would be effective from July 1. "Unfortunately, there is still no useful official publication or state- ment available which we can use or show to determine what exactly is required, by whom and when," the German forwarder said in a note to its customers. "As far as the Chinese authorities are concerned, every- thing that is needed has been communicated and published already." DB Schenker said no official notice has been released on enforcement of the regula- tions. "However, actions from China Customs indicate stricter enforcement to commence as of Oct. 1. From that date onward, shipments that have no approval or receive a 'do not load' notice from Chinese Customs can't be loaded on any vessel calling China," it said. If the submission of the advance mani- fest were rejected, it would be placed on a manual review list at Shanghai Customs House that would incur penalties and delays, Hong Kong-based container line OOCL said in a statement. It said the line had been informed by customs authori - ties that the regulations would be strictly enforced from June 3 and apply to all cargo discharged or transshipped at Shanghai. As Kuehne + Nagel understands it, the new rule means Customs would require 24-hour advanced filing of the bill of lading and cargo details for all cargo from June 28. Shanghai's Customs office will be the first station to implement the regulation, the Switzerland-based forwarder said in a note to customers. "We anticipate that all other ports in China will implement (advance manifest) rules in the near future," its statement said. The forwarder told customers the rul- ing would apply to all cargo is discharged or transshipped in Shanghai, but freight remaining on board will not be required to submit advance manifest information. A spokesman for Agility said the com- pany doesn't anticipate any problems with the new ruling, while Kerry Logistics said it had been notified of the regulations but isn't sure what the impact will be. One definite effect is that the ruling will add to shipper costs. Shipping lines have begun advising the market that they will charge $30 per bill of lading for advance manifest filings, and $40 for any amend - ments, effective July 1. There are also concerns over electronic submission of the advance data, and how the ruling applies to less-than-containerload cargo. The regulation considers the freight forwarder to be the "master loader," which means it's up to the forwarder to submit advance manifest data to China Customs. However, the only parties authorized to sub- mit advance manifest data to the customs IT system are eight officially appointed bonded warehouse operators in Shanghai. Only one offers an EDI service that would enable for- warders to submit secure manifest data to the operator's proprietary system that could then be passed on to Customs. The other seven merely offer a Web link for uploading data. DB Schenker told its customers it expects the technical capabilities and stan- dards of transmitting data via EDI into customs systems to change over the coming months, including the granting of direct EDI authorization to a broader group of agents. "But at this time, we are unsure about the regulatory and technical requirements put forward by customs in order for the global freight forwarder to electronically submit data," the company said. "Please keep in mind that the only official language used to communicate these regulatory and techni- cal requirements is Chinese." LCL cargo also is suffering from a lack of clarity. With no clear guidelines, DB Schenker said it is proceeding under the assumption that the advance manifest data for LCL cargo will only be required and enforced for containers offloaded in Shanghai. "We are still investigat- ing details, and therefore current operational requirements do not change — for now," DB Schenker told customers. JOC Contact Greg Knowler at and follow him on Twitter: @greg_knowler. CONFUSION IN CHINA Customs agency's 24-hour advance manifest system has forwarders scratching their heads in China

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