Entry summary declaration - the latest buzz in the world of customs security - Part 1
The regulation states that an Entry summary declaration (ENS) containing specific details about the cargo must be submitted to the first port of call in the European Union by the carrier. The timelines for submission of ENS depend on the type of transport and the duration that takes the transport to carry the cargo into the port of entry -
For maritime containerized cargo = at least 24 hours before loading begins at the non-EU port of loading.
For maritime bulk or break bulk cargo = at least 4 hours before arrival at first EU port
For short distance maritime movements (e.g. movement that takes less than 24 hours) = at least 2 hours before arrival at the first port
Flights = at least 4 hours before arrival at the first port
Short distance flights less than 4 hours duration = at least before take off
Rail and inland water movements = at least 2 hours before arrival
Road movement = at least 1 hour before arrival
The above rule has been put into effect from 2011 at 27 member states comprising the EU. The main driver for this regulation is to enforce strict security compliance and risk assessment in line with the expectations of EU member states, as near the point of origin as possible - well before goods actually arrive at the EU, and reduce delays and bottlenecks in EU destination ports. Similar regulation has been enforced in the US and other countries through measures such as the Importer Security Filing (ISF) or 10+2.
Consequences of noncompliance with ENS can be severe - resulting in fines and penalties on carriers and parties responsible for submission, needless to say the operational delay in cargo traffic impacting the end customer / shipper and consignee. Only the customs office at the port of entry can waive an ENS filing subject to an electronic filing of customs manifest containing the data elements specific to ENS, and within the strict timelines ENS mandates.
The onus on filing the ENS lies with the actual carrier of the cargo, regardless of who is managing the logistics portion of the supply chain (e.g. a 3PL). If the carrier has a contract with another party for B/L preparations - such as alliances, freight forwarders etc. - then that party may also submit the ENS of behalf of the carrier, but must have explicit permission from the carrier to do so.
Due to the strict timelines, need for data accuracy and seriousness of the filing, freight forwarders and 3PL s managing the logistics or responsible for submissions start requesting for the ENS even as early as 5 days before due date. This brings the entire logistics chain forward, requiring importers and 3PL s to complete inspections / quality compliance checks and confirm on suppliers / vendors shipments many days ahead of the due date. Needless to say how far ahead the planning for overseas cargo must now begin to cover for all of this.
Will this measure ultimately achieve better success in reducing delays for ports or cause more hastles for end customers? - only time will tell.
In the next part, I will provide more insight into the specifics of ENS data and its implementation.
For maritime containerized cargo = at least 24 hours before loading begins at the non-EU port of loading.
For maritime bulk or break bulk cargo = at least 4 hours before arrival at first EU port
For short distance maritime movements (e.g. movement that takes less than 24 hours) = at least 2 hours before arrival at the first port
Flights = at least 4 hours before arrival at the first port
Short distance flights less than 4 hours duration = at least before take off
Rail and inland water movements = at least 2 hours before arrival
Road movement = at least 1 hour before arrival
The above rule has been put into effect from 2011 at 27 member states comprising the EU. The main driver for this regulation is to enforce strict security compliance and risk assessment in line with the expectations of EU member states, as near the point of origin as possible - well before goods actually arrive at the EU, and reduce delays and bottlenecks in EU destination ports. Similar regulation has been enforced in the US and other countries through measures such as the Importer Security Filing (ISF) or 10+2.
Consequences of noncompliance with ENS can be severe - resulting in fines and penalties on carriers and parties responsible for submission, needless to say the operational delay in cargo traffic impacting the end customer / shipper and consignee. Only the customs office at the port of entry can waive an ENS filing subject to an electronic filing of customs manifest containing the data elements specific to ENS, and within the strict timelines ENS mandates.
The onus on filing the ENS lies with the actual carrier of the cargo, regardless of who is managing the logistics portion of the supply chain (e.g. a 3PL). If the carrier has a contract with another party for B/L preparations - such as alliances, freight forwarders etc. - then that party may also submit the ENS of behalf of the carrier, but must have explicit permission from the carrier to do so.
Due to the strict timelines, need for data accuracy and seriousness of the filing, freight forwarders and 3PL s managing the logistics or responsible for submissions start requesting for the ENS even as early as 5 days before due date. This brings the entire logistics chain forward, requiring importers and 3PL s to complete inspections / quality compliance checks and confirm on suppliers / vendors shipments many days ahead of the due date. Needless to say how far ahead the planning for overseas cargo must now begin to cover for all of this.
Will this measure ultimately achieve better success in reducing delays for ports or cause more hastles for end customers? - only time will tell.
In the next part, I will provide more insight into the specifics of ENS data and its implementation.
