Monday, 31 July, 2006

Cargo Reporting Compliance - Bureau's & 'Master Co-Loaders'

Dear Firstname,

An issue has been highlighted which may be causing some of you a great deal of concern in regard to meeting your obligations under the Customs compliance requirements for accurate and timely reporting of cargo.

The following issue relates particularly to those organisations who are reporting on behalf of other forwarders or acting as a bureau for cargo reporting.

It would appear that most reporters in this situation have been approached by Customs Compliance Division to account for late reporting of cargo for which they were not the actual freight forwarder. AFIF has identified that the reason for this is that there is confusion between the Reporting Party (Bureau or Master Loader) and the Cargo Reporter (the actual Freight Forwarder - who always remains the responsible party).

The solution ? We have discovered that it is relatively simple but is not apparently being applied:

Customs identify the responsible party by the ABN number or CCID (Customs Client Identifier) number which has been entered into the Responsible Party Client ID box in either the Customs Interactive (CI) facility or your electronic data interchange software field for each Master Housebill  number (in the case of a Consolidation which includes 'sub-masters' for other Forwarders)

As there are many differing software packages, you may need to ask your software provider for the location of this field so that the correct ABN or CCID is entered. Please also be aware that your system may have been set to 'default' to the Master Reporter ABN or CCID which may mean that the ‘Reporting party’ is incorrectly identified as the Responsible party.

If this affects you please check in your software application to a) ascertain the field used to identify the responsible party as detailed above and b) if your operators are aware of this facility and whether it is being applied correctly.

Most importantly, please remember, the ONLY party responsible under the Act is the cargo reporter which means the operator or charterer of the ship or aircraft; or a slot charterer in respect of the ship; or a freight forwarder in respect of the ship or aircraft

'Cargo Reporting Bureau's'; Master Co-Load Agents and Freight Forwarders need to examine this carefully to avoid the possibility of costly effort spent unnecessarily, when you are audited for compliance.

AFIF have been in discussion with senior officials from Customs Compliance Division in Canberra and also the NSW region and the problem is serious and widespread and we are working with Customs on a general fact sheet in regard to this issue, for distribution to industry.  We are also trying to get the terminology changed to reduce the confusion between Reporting Party and Cargo Reporter! 

In the meantime, Customs have attempted to provide internal instructions to their officers in regard to who is responsible for late cargo reports - particularly covering the situation where the party with the obligation to lodge a report engages an agent (bureau) to report on their behalf. We have attached a copy of this instruction which may assist you in identifying who is the 'responsible party'.

Please click here to view Australian Customs instruction to Compliance Officers:

Cargo Reporting Compliance For Master Co-Loaders; Bureaus And Other Reporters

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