Entry summary declaration - the latest buzz in the world of customs security - Part 2
This is second of the two part series on Entry Summary declaration or ENS requirements to be submitted by carriers to European Union ports. In this part I shall outline the specific data elements that are mandatory for ENS submission and provide some insight into its implementation by various carriers.
Following are the data elements that need to be present in the advanced shipment notification while sending the same to customs.
* Bill of lading number
* Shipper and Consignee name and address (EORI or Economic Operators Registration and Identification number - a unique identification number for every economic operator in the EU, if available)
* Notify party (Mandatory if Consignee is "To order"; EORI number - if available)
* Acceptable goods description
* 4 digit HS commodity code (Harmonized system code, a commodity classification system where items are categorized primarily based on the nature of its material constituents / ingredients)
* Package type
* Number of packages
* Container number
* Gross mass (kg)
* UN code for dangerous goods
* Seal number
* Transport charges method of payment code (e.g. cash, credit card - to be provided only where available)
* Route details inbound, within and outbound from EU perspective
A major difference with a similar regulation enforced last year in US - The ISF (importer security filing) is that unlike ISF requirements in US, the EU regulation does not mandate dual filing or submission of eventual shipper / consignee information. It is enough if the master B/L data (ocean carrier's B/L) is filed, although freight forwarder or NVOCC is actually the shipper and consignee.
Now, carriers are employing two distinct approaches for ENS implementation. To implement the ENS requirements, carriers need to have accurate and timely inputs on several data elements, many of which come from importers, exporters and freight forwarders.
The number of data elements, the myriad sources from where they arrive, the nature of the data and multiple data formats used by different EU member states and stakeholders supplying the data makes the entire scenario quite complex. Add to this various certification processes, business scenarios and communication protocols and of different EU member states and stakeholders - and the entire implementation becomes very challenging, especially with current budgetary constraints.
Carriers who already have huge investments in IT applications and EDI/B2B technologies and networks - are going in for in house solutions, by enhancing existing system and interfaces, Most have taken the approach of testing and certifying country by country within the EU.
Other carriers have taken the approach of employing a single gateway for filing globally, procuring, translating and distributing master data from and to required formats. In many cases, this single gateway is a value added service provider (e.g. a VAN or a portal with such IT and EDI/B2B and networking capabilities), who achieve seamless data traffic across stakeholders and also takes care of disparate compliance needs of different filing situations (refer to the 1st part of this blog series). Such vendors additionally provide features such as cargo status visibility, not only for the carrier but also to other stakeholders (3PLs, shippers, consignees etc.), alerts in case of missing or erroneous data and intelligent auditing and reporting capabilities and efficient exception management mechanism.
It is a trade-off between investing in in-house solutions and paying the extra buck to 3rd party vendors with proven expertise in this field. Either way, while ENS has brought in additional security checkpoints, enhancement of customs requirements for universal security standardization, potential delays in cargo movement - depending on whether you are a proponent or critic of such moves by regulatory authorities - it certainly has added new work and projects for IT staff of carriers and potential business opportunity for 3rd party value add vendors.
