AFIF
Monday. 8 July 2013
Formal submission to ACBPS - Assembly Order cargo reporting
 
Dear All,
 
The Australian Federation of International Forwarders (AFIF) and the Freight & Trade Alliance (FTA) have made a combined submission to the Australian Customs and Border Protection Service (ACBPS) in relation to the multiple supplier / assembly cargo reporting compliance issue.
 
As a result of the May 2013 ACBPS compliance letters to industry and subsequent correspondence received, the AFIF and FTA response was based on extensive engagement with our respective memberships the wider trade sectors and advisors.
 
This approach highlighted the large number and complexity of scenarios in operation for multiple supplier consignments. It has also highlighted the level of confusion that exists in the market compounded by the recent ACBPS compliance approach.
 
The AFIF and FTA submission highlights the need for solutions that meet the Government's focus on strengthening security in the cargo supply chain, while minimising any negative impact on the Australian retail sector and maintaining the viability of established supply chain models.
 
In summary, AFIF and FTA have made two key recommendations:
 
1. The Integrated Cargo System (ICS) for sea freight LCL and airfreight must be enhanced to provide similar functionality to the FCL / "FCX" functionality, allowing multiple cargo reports and a single Import Declaration to be provided against each import consignment.
 
This enhancement to the ICS would have the benefits of:
  • providing transparency to ACBPS of suppliers' details;
  • avoiding the complexity of dealing with piece counts of packaged consignments;
  • negating the need for industry to dismantle existing business models; and
  • minimising any increase in supply chain costs.
2. A compliance moratorium is desirable and appropriate until further industry engagement has been completed and ICS functionality is enhanced. We recommended that ACBPS follow this approach with an "informed compliance" campaign to ensure that (a) industry is fully aware of requirements and (b) are operating on a "level playing field".
 
Please note that these are our recommendations only and making these submissions does not exempt members from any potential compliance action.
 
We will keep members up to date on any developments. In the interim, enquiries should be directed to brian@afif.asn.au or pzalai@FTAlliance.com.au
 
Please advise all concerned.
 
Thanks and regards,

Brian Lovell
Chief Executive Officer
Australian Federation of International Forwarders Ltd (AFIF)
Suite 403, Level 3
152 Bunnerong Road
Eastgardens NSW 2036
Tel: +61 2 9314 3055
Fax: +61 2 9314 3116