Starting from January 4, 2021, eHBL becomes mandatory, and there are several consequences if the regulations are not followed. For instance, if a freight forwarder fails to transmit or provides incorrect eHBL data under their 8000 code, the Administrative Monetary Penalty (AMP) would be charged against the company.

For marine shipments, the cargo will only load overseas if the eHBL data is filed within the designated timeframe. If a “foreign/non-Canadian” forwarder files the eHBL, the shipment may arrive in Canada and get cleared before the Canadian forwarder even knows about it. In such cases, the Canadian forwarder named on the master bill of lading could still be liable to the steamship line as the consignee. Thus, CIFFA recommends that Canadian forwarders instruct their agents not to consign any cargo to their company without their express approval, and their company determines whose 8000 code is used to file the eHBL.

For air freight, if the eHBL transmission is not sent within the specified timeframe (i.e., four hours before arrival), there will be delays on arrival, and the CBSA will not have any risk assessment data available. This non-compliance could result in an AMP, in which case the freight forwarder would have to argue that they had not received any alert from the origin.